https://docs.confirmo.net/docs/api-updates-for-travel-rule-compliance

```

([Gist][1])

In short: for **every payment and every refund**, the following details must be provided:

* A **unique user ID** (e.g., email address or identification number)

* **First and last name**

* **Residential address**

* **Date and place of birth**

* **Email** (recommended for communication) ([Gist][1])

However, this basic information may not always be sufficient. Confirmo may request more detailed **KYC** verification at any time (including identity documents or proof of wallet ownership). This check may take place **after** the payment is received, which means the transaction may remain in a “**waiting for verification**” state. ([Gist][1])

## How will the changes appear in Qerko?

Before starting a bitcoin payment, Qerko will display a form where the customer fills in the required details. These details will be stored locally on the device (for future payments on the same phone/tablet), but Qerko will **not store them centrally**—it will only pass them to Confirmo **once**. ([Gist][1])

The same process applies to refunds (returning money). ([Gist][1])

Because it is not clear how often Confirmo will trigger additional verification, Qerko is monitoring the situation closely. If it turns out the process is too complicated or unpredictable, Qerko is prepared to temporarily suspend bitcoin payments. The goal is to minimize negative impact on the user experience—after gathering more data, Qerko plans possible app adjustments. ([Gist][1])

## Why can’t verification be done in advance, outside the payment process?

Confirmo performs verification only within an active payment flow. If it enables verification through another method in the future, Qerko will improve the integration. ([Gist][1])

## What happens if false details are entered?

Entering incorrect or someone else’s details (e.g., the details of your favorite politician) is not recommended. If the transaction moves into the detailed verification phase, there is a risk the payment will be rejected and funds could be lost. The regulation requires truthful data to prevent money laundering. ([Gist][1])

## Why doesn’t Qerko process bitcoin payments itself?

An independent **BTC → CZK** conversion would require a license under **MiCA** (Markets in Crypto-Assets Regulation), which is too demanding for Qerko. The no-conversion option (merchants holding BTC directly) would see minimal use—most restaurants want to receive crowns. In addition, handling bitcoin in-house could complicate Qerko’s relationships with banks and financial partners. ([Gist][1])

## Why don’t card payments require the same personal information?

They do. But the customer’s bank provides the personal data on the customer’s behalf. So while the customer experiences a smooth payment, in the background their personal details are automatically transmitted. ([Gist][1])

## What’s next?

The current solution was implemented as simply as possible due to time pressure, Confirmo’s technical limitations, and uncertainty about future user behavior. Unfortunately, this means some level of inconvenience for customers. Qerko will continuously monitor and evaluate the situation. Based on real-world experience, it plans possible improvements so the process is as non-invasive as possible. The goal remains to keep bitcoin as a payment option, as long as regulation and practice allow it. ([Gist][1])

[1]: https://gist.github.com/pepakriz/96e120cc15d04f9ece56bd6be3fee68c "Qerko-TravelRule.md · GitHub"