kyccost

Independent reference. Not legal or regulatory advice. Consult a qualified compliance specialist for advice specific to your jurisdiction and risk profile. See methodology.

Cluster 2 / Unit economics

What an onboarded customer actually costs in 2026.

Per-customer fully loaded is the canonical operational unit. Vendor invoice is roughly 35-55% of the total. The rest is screening cycles, ops labour, an EDD overlay weighted by the high-risk population, and the year-one share of ongoing monitoring on the active book.

Retail low-risk: £4 - £18 | EMI corporate: £24 - £78 | High-risk EDD: £45 - £180

Why per-customer is the canonical metric.

Fintech CFOs and Heads of Compliance defend operating costs in board packs against customer-acquisition cost and lifetime value. Both of those metrics share the same denominator: the onboarded customer. Per-customer KYC cost is the only compliance line that fits cleanly into the unit-economics conversation. Per-check cost cannot, because it is a sub-unit of an unknown denominator. Per-FTE cost cannot, because it has no relationship to revenue.

The per-customer figure also pressure-tests vendor RFPs. The gap between a vendor invoice (per-check) and the fully-loaded per-customer cost is where budgets routinely overrun. Surfacing the gap before contract execution is the single most useful thing a procurement team can do with this number.

The five components, costed.

ComponentLowMidHighAssumption set
Identity verification (per check)£0.80£2.00£3.50Document + biometric, single-vendor pricing tier, no SDK customisation. Public ComplyCube and Sumsub anchors.
Sanctions / PEP / adverse media (per cycle)£0.05£0.45£1.20Per-cycle vendor screening with World-Check or ComplyAdvantage data feed. Cycle frequency varies by risk tier.
EDD overlay (per high-risk customer)£25£55£90Source-of-funds review, UBO mapping, senior approval, additional adverse media review. On top of CDD baseline.
Ongoing monitoring (annual, per active)£8£22£45Refresh cadence, transaction monitoring, perpetual KYC scope. Year-1 share allocated to onboarding cohort.
Ops labour (per onboarded customer)£6£12£22Alert investigation at typical 4% sanctions / PEP / adverse media hit rate; junior analyst fully-loaded UK rate.

Sources: ComplyCube and Sumsub published vendor pricing pages (2025); LSEG / Forrester True Cost of AML Compliance (most recent edition); Lucinity AML labour-cost commentary; UK ONS KYC analyst rate benchmarks; engagement histories with UK and EU fintechs.

The volume curve.

Per-customer cost falls with volume but less than vendor commercials suggest. Ops labour scales roughly linearly with alert volume (which scales with onboarding volume); only the vendor and data-feed lines benefit from step-tier discounting at 10k, 50k, 250k and 1M cumulative verifications.

Under 10k onboardings / year
£28 - £75
fully loaded per onboarded customer
10k - 100k onboardings / year
£12 - £35
fully loaded per onboarded customer
100k - 1M onboardings / year
£6 - £18
fully loaded per onboarded customer

Risk-mix sensitivity.

Take a 100,000-customer book at £10 CDD baseline plus £55 EDD overlay. At 5% EDD population the blended unit cost is £12.75 (95% × £10 + 5% × (£10 + £55)). At 25% EDD population the blended unit cost is £23.75. The blended unit cost roughly doubles for the same customer volume because risk mix dominates. Triple the EDD population and the blend triples.

Blended cost = (1 - eddPct) × cddBaseline + eddPct × (cddBaseline + eddOverlay)
At 5% EDD: 0.95 × £10 + 0.05 × £65 = £12.75 per onboarded customer
At 15% EDD: 0.85 × £10 + 0.15 × £65 = £18.25
At 25% EDD: 0.75 × £10 + 0.25 × £65 = £23.75

Real fintech segments cluster: retail challenger banks at 3-7% EDD, EMIs at 8-30%, crypto exchanges at 15-40%, brokers at 30-60%. See the industry breakdown for cost profiles by segment.

The labour-share trap.

Lucinity and LSEG benchmarks place the labour share of total compliance cost at roughly 41% in Asia and consistently above one-third in Western markets. False-positive rates on legacy monitoring systems run as high as 95%, with the same effect at onboarding stage where sanctions / PEP / adverse media checks generate alerts that are mostly noise. The labour cost of investigating those alerts is the line vendor pricing pages cannot quote because vendors do not bear it.

A worked example: 100,000 onboardings × 4% sanctions / PEP / adverse media hit rate × £6.50 average investigation cost = £26,000 of pure ops labour, before any escalations to senior MLRO time. See the false-positive cost page for the full sizing model.

Worked example: a 50,000-customer EMI.

Assumptions
  • 50,000 annual onboardings, UK-domiciled EMI
  • 15% EDD population (corporate share + cross-border activity)
  • Single primary KYC platform, mid-tier vendor pricing
  • 4% sanctions / PEP / adverse media hit rate
  • Junior analyst fully-loaded rate £24/hour, average 8 minutes per alert
  • Active book reaches 90,000 customers by year-end
Build-up
Identity verification (avg)£2.10
Sanctions / PEP / adverse media (3 cycles)£0.90
Ops labour (4% × £6.50 avg + escalation)£3.40
EDD overlay (15% × £55)£8.25
Year-1 monitoring share£4.50
Fully-loaded per customer (mid)£19.15
Annual onboarding cost (50k × £19.15)£957,500
Annual recurring monitoring (90k × £22)£1,980,000
Total Year-1 KYC operating cost£2,937,500

Year-1 total is materially front-loaded by the build of the active book; in subsequent years onboarding cost falls and ongoing monitoring rises until the book matures. The full annual recurring picture sits on the ongoing cost page.

What this number is not.

Not customer acquisition cost.

CAC includes marketing spend, channel cost, content, paid media. Per-customer KYC is the compliance operating cost of getting an acquired customer onboarded. They share a denominator and they should be reported alongside each other on a unit-economics page, but they are distinct lines on the P&L.

Not the per-check vendor invoice.

Per-check is the vendor commercial. It excludes ops labour, EDD overlay weighted by risk mix, and ongoing monitoring on the active book. Treating per-check as if it were per-customer is the most common cost-modelling error this site exists to address.

Not the cost of compliance generally.

KYC sits inside a wider compliance stack: AML transaction monitoring, fraud, GDPR, PCI DSS where applicable, SOC 2 where the firm is also a SaaS provider. The RegTech cost page maps where KYC sits in the broader picture.

Per-customer cost questions

How do you calculate KYC cost per customer?+
Add five components: identity verification (£0.80-£3.50), sanctions / PEP / adverse media screening (£0.05-£1.20 per cycle), EDD overlay weighted by your high-risk population (£25-£90 per high-risk customer), ops labour for alert investigation (£6-£22 per onboarded customer at typical hit rates), and the year-1 share of ongoing monitoring (£8-£45 per active customer). Blend by your risk mix and adjust for volume. The result is a defensible unit a CFO will accept.
Why is per-customer cost different from per-check cost?+
Per-check is the vendor invoice. Per-customer is the operational unit. A single customer typically generates several checks (document, biometric, sanctions cycle, PEP screen, adverse media screen) plus ops labour to investigate any alerts those checks generate. The vendor invoice is usually 35-55% of fully-loaded per-customer cost; the rest is ops labour, EDD overlay weighted by risk mix, and the share of annual monitoring attributable to the cohort.
Does volume reduce per-customer cost?+
Yes, but less than vendor pricing tiers suggest. Vendor commercials drop 30-50% from the under-10k bracket to the 100k+ bracket. Ops labour scales roughly linearly with onboarding volume because the per-alert investigation time is fixed. Net effect: fully-loaded per-customer cost typically drops from £28-£75 in the under-10k bracket to £6-£18 in the 100k+ bracket.
How does risk mix shift the blended cost?+
Risk mix is the dominant cost variable on a fintech compliance budget. A 5%-EDD book vs 25%-EDD book shifts blended fully-loaded cost by 2-4x at the unit level. EDD overlay (£25-£90 per high-risk customer) is the largest swing factor; ops labour on EDD cases is also materially higher because senior MLRO time enters the equation.
Is per-customer cost the same as customer acquisition cost?+
No. Customer acquisition cost includes marketing spend, channel cost, and other go-to-market lines. Per-customer KYC cost is the compliance operating cost of getting a customer onboarded once acquired. They share a denominator (customers) but they are distinct lines on a fintech P&L. KYC drop-off can however inflate CAC by 30-50% because customers abandoned during onboarding still cost marketing money.
What does a 50,000-customer EMI typically spend?+
On a 15% EDD book with mixed retail and corporate customers, a UK EMI typically spends £14-£22 per onboarded customer fully loaded, plus £18-£28 per active customer per year on monitoring. At 50,000 onboardings that is £700k-£1.1M in onboarding cost, with another £900k-£1.4M annual ongoing once the active book reaches scale. The vendor invoice is roughly 40% of the total; ops labour and EDD overlay are the rest.

Sources cited on this page

  1. ComplyCube published per-check pricing
  2. Sumsub published platform pricing
  3. LSEG / Forrester True Cost of AML Compliance · labour-share benchmarks
  4. Lucinity Real Cost of AML Compliance, 2025 commentary
  5. UK ONS analyst labour-rate benchmarks (2025-2026)