Country-specific guidance Current
Requesting identity documents from an individual client in Hong Kong
Which document to ask for, and the standard it needs to meet.
An individual client's identity document needs to come from a reliable, independent source, not just look convincing. This guide sets out what to request and why. It is general information, not legal or compliance advice.
Action plan
1 Know when your firm has to verify an individual client's identity Accounting professionals in Hong Kong carry statutory customer due diligence duties, not just a good-practice habit.
Accounting professionals are among the persons subject to the statutory customer due diligence, ongoing monitoring, and record-keeping requirements set out in the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, reflected in HKICPA's own AML/CTF Guidelines for the profession. Where those requirements apply to the service you're providing, identify and verify the individual client's identity before relying on the relationship, rather than treating it as optional paperwork.
- Check whether the service you're providing to this individual triggers statutory CDD
- Treat identity verification as a compliance step, not just an intake formality
- Apply the same standard consistently across individual clients, not case by case
Done when: It's clear whether this client relationship falls under your firm's statutory CDD obligations
HKICPA: AML/CTF Guidelines for Professional Accountants2 Collect a Hong Kong identity card for a resident, or a passport for others The right document depends on the person's status, not a single fixed list.
For an individual who is a Hong Kong resident, a Hong Kong identity card is the standard identity document to request. For an individual who isn't a Hong Kong resident, a passport is the standard equivalent. Either way, the document needs to be current, government-issued, and capable of being checked against a reliable, independent source, not merely presented and accepted at face value.
- Request a Hong Kong identity card from a Hong Kong resident client
- Request a passport from a client who isn't a Hong Kong resident
- Confirm the document is current before relying on it
Done when: A current Hong Kong identity card or passport, matching the client's residency status, has been requested
3 Record what was requested and what was actually received A verification step that isn't recorded is hard to prove happened at all.
Keep a record of which document was requested, when it was received, and the details it showed, as a distinct step from the later verification check itself. This gives your firm something concrete to review later, rather than relying on memory or an informal note.
- Log the document type, its number, and the date it was received
- Keep the request and receipt as a distinct, reviewable step
- Don't rely on an undocumented recollection that a document was checked
Done when: The requested document and the date it was received are recorded as part of the client file
See verifying identity documents from a reliable source