6.2 RON Identity Verification

The Multi-Factor Standard

For an online act, Ohio Administrative Code Rule 111:6-1-05 requires the online notary to identify the remotely located individual through a combination of factors that, taken together, replace the in-person look-at-the-license check:

All three must succeed. If any one fails, the notary cannot proceed.

Acceptable Identification

The individual presents an unexpired government-issued identification credential bearing a photograph and signature - a U.S. or foreign passport, a U.S. state driver's license or state ID, or a comparable government photo ID. House Bill 315 (effective April 4, 2025) eliminated the older "satisfactory evidence" route for online acts, so an oath of personal knowledge or a single credible witness alone will not establish online identity the way it can in person.

Trap: the in-person rule allowing an ID expired up to several years does not loosen the online standard - online credential analysis works from an unexpired government credential. When the exam contrasts in-person versus online ID rules, remember the online channel is the stricter one.

Credential Analysis in Detail

Credential analysis is an automated process run by the platform's verification provider. It captures images of the front and back of the credential and checks:

• security features (microprint, holograms, ultraviolet patterns, barcodes);
• internal data consistency (the barcode data matches the printed data);
• evidence of tampering, splicing, or digital alteration;
• that the document format matches a known, valid template for that issuer.

The provider must give the notary a result the notary records in the journal, including the credential's issue or expiration date.

Identity Proofing by Dynamic KBA

Identity proofing confirms the live human is the credential holder, performed by dynamic knowledge-based authentication (KBA) unless the Secretary of State has approved another method. Ohio's specific, tested thresholds:

Questions are generated in real time from public and proprietary databases - prior addresses, former vehicles, account-opening years - so the signer cannot prepare them in advance.

Worked example: A signer answers 3 of 5 correctly (60%). That is below the 80% threshold, so the attempt fails. The platform offers a retake; the signer scores 4 of 5 (80%) within the 2-minute window on the second try - a pass. Had the signer failed the second attempt, a 24-hour lockout would apply before any further attempt with that notary or provider.

The Notary's Role and Credible Witnesses

Even after the automated checks pass, the notary must still visually compare the on-screen person to the ID photo over the live feed and may ask clarifying questions. The notary retains discretion to decline if not satisfied that the signer is who they claim to be. A credible witness may be used in RON only if the witness appears over the same audio-video technology, is themselves identified, and takes the oath on video - with full documentation in the journal.

Putting the Three Factors Together

The exam loves to ask which factor catches which fraud. Map them:

No single factor is sufficient. A real ID in the wrong hands sails through credential analysis but should fail KBA; a stolen identity dossier might pass KBA but the face on screen will not match the ID photo for the notary's visual check.

Recording the Evidence of Identity

For every online act the notary must record, in the electronic journal, a description of the evidence relied upon, including the credential's date of issuance or expiration and the results of credential analysis and identity proofing. This is not optional bookkeeping - it is the proof the notary followed the multi-factor rule if the act is later challenged.

Worked example - the impostor: A caller presents her sister's valid Ohio driver's license over video. Credential analysis passes because the license is genuine. But the dynamic KBA pulls questions about the sister's former addresses and prior vehicles, which the impostor cannot answer within the two-minute window; she scores 2 of 5 (40%) and fails. The notary correctly declines, records the failed identity-proofing result in the journal, and may still charge the technology fee.

Quick Reference: In-Person vs. Online Identity

The takeaway the test rewards: the online channel is the stricter identity channel, and HB 315 removed the looser "satisfactory evidence" shortcut for it.