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 the narrower FinCEN BOI document request when a non-U.S. person is a beneficial owner of a foreign reporting company that is not exempt. U.S. persons covered by the BOI rule's owner or applicant exemptions do not have to provide BOI. This 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. U.S. companies are exempt from BOI reporting requirements; for a non-exempt foreign reporting company, the BOI request is limited by the final rule's U.S.-person relief. The IRS's tax-reporting requirements remain a separate purpose. 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 details only for reportable non-U.S. beneficial owners Confirm foreign-entity scope, other exemptions, and the individual's U.S.-person status first.

First confirm that the entity is foreign-formed, registered to do business in any U.S. State or Tribal jurisdiction, and not covered by another exemption. FinCEN's final-rule Q&A says: Reporting companies do not need to report BOI for U.S. person beneficial owners or U.S. person company applicants. U.S. persons do not need to provide BOI to reporting companies where they are beneficial owners or company applicants. For this BOI request, ask for identifying details only for a non-U.S.-person beneficial owner whose information is reportable. FinCEN's BOI report filing instructions specify the full legal name, date of birth, current address, unique identifying number, and a complete, clear, readable image of an acceptable identifying document for a reportable person; a FinCEN identifier may be used where the instructions allow it.

  • Check the company's formation, U.S. registration, and all applicable exemptions first
  • Do not request BOI identifying details from a U.S.-person beneficial owner or company applicant
  • For a reportable non-U.S. beneficial owner, use FinCEN's current official filing instructions for required fields and acceptable evidence

Done when: Any FinCEN BOI document request is limited to a reportable non-U.S. person after entity scope and exemptions are checked

FinCEN: Final Rule Questions and Answers
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