ID Documents, Certified Copies and Proof of Address for Accountants

Identity checks are the part of customer due diligence that every client sees, and the part where firms most often get the paperwork wrong. Which documents do you need? Can you accept a scan? Who can certify a copy? Is a utility bill still good evidence of an address? This guide answers those questions using HMRC's published guidance on identifying and verifying customers and its Economic Crime Supervision Handbook, which explains what inspectors look at. It covers individuals, companies and the cases that do not fit the standard pattern. Guidance is updated regularly, and other supervisors such as ICAEW and ACCA publish their own, so check your own supervisor's current requirements before you change your procedures. This is general information, not legal advice.

What you need to establish for an individual

According to HMRC, you must obtain and verify the client's full name, date of birth and residential address. If you cannot verify identity, you must not proceed. HMRC says the evidence you hold, taken together, must verify full name, photo, date of birth and address, and that at least one document should show a photo. More than one document may be needed to cover everything.

Accepted photo ID includes a valid passport, a photocard driving licence, a national identity card, a firearms certificate, or an Electoral Office for Northern Ireland identity card. HMRC's inspectors' handbook also mentions digital government documents such as those held in the GOV.UK Wallet and eVisas. For people who are not UK residents, a passport valid for travel is the expected document, and a visa can be accepted to show permitted activities and conditions.

Checking the document itself

Obtaining a document is not the same as verifying it. HMRC says you should check each one for spelling, expiry, whether the photo matches the person, consistent addresses, a plausible date of birth and signs of forgery. For foreign documents, HMRC's inspectors use the PRADO register, and doubtful documents can be checked with the relevant embassy, with certified translations obtained where needed. HMRC also says inspectors ask why each document was collected, whether to confirm likeness, address or both. If you cannot explain the purpose of what you hold, your risk-based approach is open to question.

Originals and certified copies

HMRC says originals should be seen wherever possible. If originals cannot be produced or checked with the issuer, certified copies may be accepted from an appropriate professional, such as a solicitor. HMRC's guidance sets out what a certification should contain: a true-copy statement, the certifier's signature and date, their printed name, and their occupation, address and telephone number. The Economic Crime Supervision Handbook adds that inspectors ask how and why a document was certified and whether the firm checked the certifier, who should be a professional person or someone well respected in the community. HMRC also notes that certification alone does not count as enhanced due diligence.

Proof of address

HMRC says address can be corroborated by the ID documents themselves, or by a utility bill, a bank, building society or credit union statement, or a recent mortgage statement from a reliable source unconnected to the client. The handbook adds that:

• acceptable evidence includes council tax bills and other bills such as phone bills, typically in the client's name;
• inspectors check whether the document is a posted letter or an internet printout, and how the firm guards against forgery;
• a PO box does not confirm a residential address;
• recency should follow your own policy, and if a document is older than you would expect, you should be able to say why you accepted it; and
• alternative steps, such as an introductory meeting at the address, can support verification and should be documented.

Clients who cannot produce standard documents

Some clients, for example some elderly people, cannot produce a passport or driving licence. HMRC says you can use a valid, genuine document without a photo that shows name and address, such as an older-style driving licence or recent benefit or pension evidence, together with a further address document from a reliable source. Non-standard documents may also come from an independent source such as a medical or legal professional, a care home head or a pension provider. You must record why standard documents were not available and take steps to check authenticity. The handbook adds that accepting non-standard ID in low-risk cases is permitted, but you must be able to show you took reasonable steps.

Companies and other entities

For companies, HMRC's handbook lists sources such as Companies House records, certificates of incorporation, articles of association, beneficial ownership evidence, business licences, supervisory registers, electronic verification and credit checks. Register entries alone are not enough. HMRC says that under regulation 28(9) you must use other sources to confirm beneficial ownership information. Our guide to KYC and customer due diligence for accountancy practices covers the full process for entities.

Electronic and remote checks

Where you cannot see documents in person, HMRC's guidance points to electronic verification. A single check against one source is not normally enough, and digital identity services certified against the UK trust framework and listed on the DVS register can be used. Our guide to verifying client identity remotely explains what the 2026 government guidance says.

Expired documents and updates

An expired passport is not necessarily a problem on the day you verify, but HMRC says expired documents should be dealt with under ongoing monitoring. Our guide to ongoing monitoring and periodic CDD review explains when to ask for fresh evidence.

Recording what you did

HMRC says the results of each check must be recorded on the case management system. For each client, note which documents you saw, whether originals or certified copies, who checked them and when, and the result. HMRC's inspectors look at timing (when the checks were done relative to the work starting), who performed them and whether they were trained.

A short document checklist

1. Photo ID. Valid, matching the person, not obviously altered.
2. Address evidence. Recent, in the client's name, from a reliable source, and not a PO box.
3. Certification. If a copy is used, check the certifier's statement, signature, date and contact details.
4. Consistency. Names, dates of birth and addresses match across documents.
5. File note. Record what you saw, why, and who checked it.

For training on these checks, see our CPD courses.

Frequently asked questions

Can I accept a scanned copy of a passport?

HMRC says originals should be seen wherever possible and that certified copies may be accepted from an appropriate professional if originals are not available. Follow your supervisor's guidance and your own procedures.

Who can certify a copy?

HMRC mentions an appropriate professional such as a solicitor, and the handbook says a professional person or someone well respected in the community, with a statement, signature, date and contact details.

Is a bank statement acceptable proof of address?

Yes, according to HMRC, if it comes from a reliable source unconnected to the client. Check recency against your policy, and whether it is an original letter or an internet printout.

Does certification count as enhanced due diligence?

No. HMRC says certification alone does not count as enhanced due diligence.

What if my client has no passport or licence?

You may accept non-standard evidence from an independent source, record why standard documents were not available and take steps to check authenticity.