Client intake Current

Requesting identity documents from an individual client in the US

There is no single federal identity checklist here, so ask for what two specific rules actually require.

Unlike some other countries, the United States does not have one federal identity-document standard that applies to accounting firm client intake generally. This guide sets out what genuinely does apply: IRS tax-reporting requirements, and FinCEN's identity requirements where a client is a beneficial owner of a company that still has to report. It is general information, not legal or tax advice.

Action plan

1 Know there is no blanket federal identity-document rule for accounting client intake Two narrower, specific rules apply, not one general federal standard.

The United States does not have a single federal law requiring accounting firms to collect specific identity documents from every individual client. What genuinely applies depends on the purpose: the IRS requires a correct taxpayer identification number for tax reporting, and FinCEN requires specific identifying information for a beneficial owner of a company that currently has a Corporate Transparency Act reporting obligation. Don't assume a document checklist built for one purpose automatically satisfies the other.

  • Don't treat any single document list as a universal federal requirement
  • Identify which of the two purposes below actually applies to this client relationship
  • Confirm any additional state-specific or firm-specific requirement separately

Done when: The specific reason identity information is being requested from this client has been identified, rather than assumed

FinCEN: Beneficial Ownership Information
2 Collect Form W-9 to get the client's correct name and taxpayer identification number This is the narrow, genuinely federal identity step that applies to a US payee.

The IRS describes Form W-9 as the form a US person uses to provide their correct taxpayer identification number to a person or organisation required to file an information return reporting income paid to them. Collect it directly from the client, signed and dated, rather than filling it out on their behalf.

  • Ask the client to complete and sign Form W-9 themselves
  • Confirm the name on the form matches the client's other records
  • Keep the completed form on file for as long as your firm's information-return obligations may require it

Done when: A signed Form W-9 is on file for a client whose taxpayer identification number your firm needs for reporting

IRS: About Form W-9
3 Request FinCEN's specific identifying details only where the client is a beneficial owner of an in-scope company This applies only when the client entity currently has a Corporate Transparency Act reporting obligation.

Under the current rule, only foreign-formed companies registered to do business in a US state or tribal jurisdiction remain reporting companies. For an individual who is a beneficial owner of such a company, FinCEN's own filing instructions call for the individual's full legal name, date of birth, current address, a unique identifying number, and a complete, clear, readable image of an acceptable identifying document (a state-issued driver's licence, a state or tribal identification document, a US passport, or, only if none of those exist, a foreign passport).

  • Confirm the company itself is currently a reporting company before asking a beneficial owner for this information
  • Request full legal name, date of birth, current address, and a unique identifying number
  • Request a complete, clear, readable image of an acceptable identifying document

Done when: A beneficial owner's identifying details and document image have been requested only where the underlying company genuinely has a current reporting obligation

FinCEN: BOI report filing instructions
4 Store what you collect securely and keep it current Identity evidence is only useful if it stays accurate and stays protected.

Once collected, treat identity documents and taxpayer information as sensitive client data requiring the same safeguards your firm applies to other tax records. Vertical Flows can structure the intake and evidence-storage workflow this relies on; it does not set your firm's data-security policy.

  • Store identity documents and forms with your other client due diligence evidence
  • Limit who in your firm can access stored identity information
  • Refresh a form or document when the client's details or status change

Done when: Collected identity information is stored securely and refreshed when the client's details change

See storing client identity evidence securely