7.3 RON Identity Verification
Key Takeaways
- RON identity may be established by personal knowledge, a credible witness on oath/affirmation, or at least two identity-proofing processes
- Credential analysis captures and validates a government-issued photo ID presented on camera and matches it to the signer
- Dynamic knowledge-based authentication (KBA) asks targeted personal questions that another person could not reasonably guess
- The two identity-proofing processes must be of different types — typically credential analysis plus dynamic KBA
- If identity cannot be confirmed, the notary must refuse the RON, just as with any other notarial act
The Three Identity Pathways in RON
Because the signer is not physically present, RULONA gives a Pennsylvania notary three ways to confirm the identity of a remotely located individual. The notary needs only one of these pathways for a given act:
| Pathway | How identity is established |
|---|---|
| Personal knowledge | The notary already personally knows the individual through dealings sufficient to be confident of identity |
| Credible witness | A credible witness, who personally knows the individual, vouches for identity on oath or affirmation; the notary must in turn be able to identify the witness |
| Two identity-proofing processes | When neither of the above applies, the notary relies on at least two different identity-proofing processes or services built into the technology |
The third pathway is what makes RON distinctive. "Two identity-proofing processes" does not mean showing the same ID twice — it means two different methods, almost always credential analysis combined with dynamic knowledge-based authentication. Both must succeed during the session.
Credential Analysis
Credential analysis is an automated process in which the signer presents a government-issued photo identification — such as a driver's license, state ID, or passport — to the camera, and the platform captures and analyzes the credential for validity.
| Element checked | Purpose |
|---|---|
| Document authenticity | Confirms the ID is genuine and not fabricated |
| Security features and format | Detects forgery, alteration, or tampering |
| Expiration / validity | Confirms the ID is current |
| Photo-to-person match | Compares the ID photo to the live person on video |
Credential analysis answers the question, "Is this a real, valid ID, and does it match the face on the screen?" It is one of the two required processes — but, by itself, it is not enough.
Dynamic Knowledge-Based Authentication (KBA)
Dynamic KBA asks the individual a set of targeted personal-history questions drawn in real time from third-party data sources — questions "that are targeted to the specific individual and cannot be reasonably anticipated or guessed by another individual." The word dynamic is key: the questions are generated on the spot, not pre-scripted, so a fraudster cannot prepare answers in advance.
| Feature | Typical standard |
|---|---|
| Number of questions | A set of multiple-choice questions (commonly around five) |
| Time limit | A short window (commonly about two minutes) |
| Pass threshold | The individual must answer a minimum number correctly |
| Question topics | Prior addresses, former vehicles, lenders/loans, associated names |
| Source | Public and credit-header databases, not the notary's input |
KBA answers a different question than credential analysis: "Does this person actually know the life details of the identity they are claiming?" Because the two processes test different things — a valid document and private knowledge — pairing them is what satisfies the "two different processes" rule.
Why Two Different Types Are Required
The statute deliberately demands processes of different kinds because each defends against a different fraud. Credential analysis defeats someone who lacks any genuine ID but cannot defeat an impostor holding a stolen, genuine license. Dynamic KBA defeats the impostor who has the stolen ID but does not know the victim's loan history or former addresses. Used together, an attacker would need both a genuine credential and the victim's private life data — a far higher bar.
This is why running credential analysis twice, or asking the signer to show two different IDs, does not satisfy the rule: both are the same type of process and defend against the same single threat.
Credible Witnesses in a Remote Setting
A credible witness can substitute for the two-process route. In RON, the witness may appear in either of two ways:
- Physically with the notary, while the signer appears remotely; or
- Appearing remotely alongside the signer, on the same audio-visual session.
In every case the witness must personally know the signer, must vouch on oath or affirmation, and must themselves be identified by the notary (by personal knowledge or by satisfactory evidence). A witness with a beneficial interest in the transaction is disqualified, exactly as in traditional notarization.
When Identity Fails
Identity verification is a gate, not a formality. If a credential is rejected, the photo does not match the live person, or the signer fails KBA, the notary has not established identity and must refuse to complete the RON.
| Failure | Required response |
|---|---|
| Credential analysis fails | Stop; identity not established |
| Photo does not match live signer | Stop; identity not established |
| KBA failed (below threshold) | Stop; identity not established |
| Audio-visual feed too poor to verify | Stop; cannot confirm appearance |
The notary may suggest the signer try again later or pursue an in-person notarization, but the notary may never "vouch through" a failed check.
Exam Focus
- Three pathways: personal knowledge, credible witness on oath/affirmation, or two identity-proofing processes.
- The two processes are different types — typically credential analysis + dynamic KBA.
- Dynamic KBA = real-time, unanticipatable questions; credential analysis validates a government photo ID and matches the face.
- Failed identity = must refuse the act.
When a Pennsylvania notary relies on identity-proofing processes for a RON (rather than personal knowledge or a credible witness), what is required?
What makes knowledge-based authentication 'dynamic' in a RON session?
During a RON, the signer's government ID passes credential analysis but the signer fails the knowledge-based authentication questions. What must the notary do?