Country-specific guidance Current

Requesting identity documents from an individual client

What to ask for, and when the request needs to happen.

UK firms with customer due diligence obligations generally need to identify an individual client at or before the point they establish a business relationship. This guide sets out a practical approach to requesting that evidence. It is general information, not legal or compliance advice.

Action plan

1 Request identity documents before the business relationship starts Regulation 27 ties customer due diligence to establishing the relationship itself, not a later step.

Regulation 27 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 requires a relevant person to apply customer due diligence measures when establishing a business relationship with a client. Build the identity request into the very start of onboarding, rather than treating it as paperwork to finish once work is already underway.

  • Sequence the identity request as part of establishing the relationship, not a follow-up task
  • Apply the same approach for an occasional transaction above the relevant threshold
  • Repeat the request whenever you doubt previously obtained information, per regulation 27

Done when: Identity documents are requested at, or before, the point the business relationship is established

legislation.gov.uk: Money Laundering Regulations 2017, regulation 27
2 Ask for full name, date of birth, residential address, and a primary photo document HMRC's own guidance sets out the core information and the document types that satisfy it.

HMRC's guidance for supervised businesses sets out that verifying an individual generally means confirming their full name, date of birth, and residential address, using a primary document that carries a photograph and security features, such as a valid passport, a valid photo driving licence, or a national identity card. Where a client cannot provide one of these, the same guidance allows a supplementary document in limited circumstances.

  • Ask for full name, date of birth, and residential address
  • Request a primary photo document such as a passport or photo driving licence
  • Only fall back to a supplementary document where a primary document genuinely is not available

Done when: The client has provided full name, date of birth, residential address, and a primary photo document, or a documented reason a supplementary document was used instead

HMRC: identifying and verifying your customers
3 Explain the request clearly and collect it through a secure channel A short explanation and a controlled channel generally reduce friction and risk together.

Clients generally respond better to an identity request when they understand it is a standard part of onboarding, not a one-off suspicion, and when they are told how the documents will be stored. Collect the documents through a structured, access-controlled channel rather than an open email thread, so the request and the response both become part of your firm's evidence.

  • Tell the client the request is a standard part of onboarding for a client like them
  • Explain briefly what will happen to the documents once received
  • Use a structured, access-controlled channel rather than plain email for collection

Done when: The client was told why the documents are needed, and the documents were collected through a structured, access-controlled channel

See verifying identity documents from a reliable source