Country-specific guidance Current

Verifying identity documents from a reliable, independent source

A document is only "verified" if the source is genuinely independent of the client.

Receiving an identity document is not the same as verifying it. This guide sets out what makes a source reliable and independent under the UK Money Laundering Regulations. It is general information, not legal or compliance advice.

Action plan

1 Know what "verify" actually means under the Regulations Verification is defined by the source of the evidence, not just by having a document on file.

Regulation 28 of the Money Laundering Regulations 2017 defines verifying identity as confirming it on the basis of documents or information obtained from a reliable source which is independent of the person whose identity is being verified. A document issued by an official body counts as independent even where the client is the one who hands it to you, but the underlying source still has to be genuinely independent, not just any document the client happens to provide.

  • Confirm the document or data comes from a source independent of the client, not only from the client
  • Treat documents issued by an official body as independent, even when supplied by the client
  • Don't treat a self-declared or client-created document as verification on its own

Done when: Each identity document accepted has been confirmed as coming from a source independent of the client

legislation.gov.uk: Money Laundering Regulations 2017, regulation 28
2 Check the document itself, not just that one was provided HMRC's own guidance expects specific checks on the document, not a glance.

HMRC's guidance for supervised businesses expects a business to actively examine an identity document rather than simply file it: checking spellings against other information already held, checking the document's validity including its expiry date, and checking the photograph is genuinely the client's. Build these specific checks into your intake process rather than treating receipt of a document as the end of the step.

  • Check spellings on the document against other information already held for the client
  • Check the document's expiry date and confirm it is still valid
  • Check the photograph on the document is genuinely the client's

Done when: The document's spelling, validity, and photograph have each been checked against the client, not just filed

HMRC: identifying and verifying your customers
3 Use a registered digital identity service if verifying digitally Not every digital check counts, only a service on the UK's own trust framework register does.

HMRC's guidance notes that a digital identity service certified against the UK digital identity and attributes trust framework, and listed on the DVS register, counts as a reliable and independent source for verification. A digital check from a provider that isn't on that register cannot reliably be treated as meeting the Regulations' verification standard.

  • Confirm any digital identity provider used is on the DVS register before relying on it
  • Don't treat an unlisted digital check as equivalent to a registered one
  • Keep a record of which provider and check were used for each client

Done when: Any digital verification used relied on a provider confirmed to be on the DVS register

See requesting identity documents from an individual client