Certifying ID documents for client due diligence

A certified copy is a photocopy of an identity document that a suitable professional person has compared with the original and signed as a true copy. HMRC accepts certified copies for client due diligence when the original is not produced or cannot be validated, but the firm must check that the certifier exists and is appropriate, and certification on its own is not enhanced due diligence.

When are certified copies acceptable for client due diligence?

Regulation 28(18) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) says that verifying identity means verifying on the basis of documents or information obtained from a reliable source independent of the person being verified. Documents issued by an official body, such as a passport, count as independent even when the client hands them over. The Regulations do not mention certified copies; the rules on them come from supervisors’ guidance.

HMRC’s manual at AMLG11400, section 14.4, says original identity documents should be produced wherever possible. If originals are not produced or cannot be validated with the issuing source, a firm can accept copies certified as true copies of the original by a professional person, such as a solicitor. ICAEW’s client due diligence helpsheet takes a similar line: where there is no face to face relationship, it suggests asking for an original or a certified copy of photo ID together with an additional piece of evidence, or using an appropriate electronic identification process.

ICAEW has also said that an online video meeting counts as meeting the client. For a lower risk client the firm has met, an identity document sent electronically may be enough; where the firm has not met or seen the client, ICAEW would usually expect the document to be certified by someone of standing.

Who should certify the document?

HMRC requires the firm to ensure that the person certifying the copy exists and is an appropriate person to certify it. ICAEW recommends that certification is by someone in the categories a firm could rely on under regulation 39, such as a lawyer, auditor, external accountant, insolvency practitioner or tax adviser who is regulated for anti money laundering. That choice has a practical advantage: the firm can confirm the certifier on a public register of the relevant professional or supervisory body.

The general GOV.UK guidance on certifying a document lists a wider range of people, including a bank or building society official, councillor, minister of religion, dentist, chartered accountant, solicitor or notary, and teacher or lecturer. It says the certifier should not be related to the person, live at the same address or be in a relationship with them, and that the organisation asking for the copy may set its own rules. A practice’s own AML procedures should state which certifiers it accepts and when.

What should the certification say?

HMRC’s guidance sets out what a correctly certified copy contains. The certifier must:

1. write “Certified to be a true copy of the original seen by me” on the document;
2. sign and date it and print their name;
3. add their occupation, address and telephone number.

For photographic ID, many firms also ask the certifier to confirm that the photograph is a true likeness of the person, which links the document to the individual rather than just to an original document. That is a sensible addition rather than a stated HMRC requirement. A firm should ask for the certification on every page that carries identity details.

What checks does the firm still need to make?

Certification does not transfer responsibility. HMRC expects firms to check every identity document, including:

• spellings and expiry dates;
• that the photograph is of the client;
• that addresses agree across documents and the date of birth looks realistic;
• signs of forgery, such as misaligned text or missing security features.

With a copy, some security features cannot be seen at all, which is why the firm should confirm the certifier independently, for example by checking their professional listing and calling the number on the firm’s website rather than the one written on the copy. HMRC states expressly that certifying a copy does not by itself constitute enhanced due diligence. For higher risk clients, see enhanced due diligence.

What about documents in another language?

HMRC expects that if the firm does not understand the language of a document, a certified translation should be obtained, and it can require certified translations of CDD records when inspecting under regulation 66. GOV.UK guidance says a certified translation should carry the translator’s written confirmation that it is a true and accurate translation of the original, the date and the translator’s full name and contact details. Overseas clients raise other issues too, covered in due diligence on overseas and remote clients.

Is electronic verification a better alternative?

Often it is. Regulation 28(19) allows information from a secure electronic identification process to be treated as coming from a reliable independent source. HMRC says digital identity services certified against the UK digital verification services trust framework and on the DVS register can be used, and that providers not on the register cannot reliably be treated as suitable. ICAEW’s summary of the 2026 CCAB guidance confirms that uncertified services cannot be relied on alone. ICAEW has also suggested measures such as a photograph of the client holding their open passport, or posting a letter to the address and asking for it back, as extra steps for higher risk clients. See electronic identity verification for clients.

What does this look like in practice?

Illustration only. A practice takes on a new client who lives 200 miles away and prefers not to use the firm’s electronic ID app. The firm asks her to have her passport and a recent bank statement certified. She returns copies certified by a solicitor, each marked with the HMRC wording, a signature, date, printed name, occupation, office address and telephone number. The firm checks the solicitor on the Law Society’s register, telephones the office number shown there to confirm the certification, checks the passport details and expiry date, and records each step on the CDD file.

What mistakes do firms make?

• Accepting a copy signed by a friend or relative of the client.
• Accepting the words “true copy” without a name, occupation or contact details.
• Never checking that the certifier exists.
• Treating a certified copy as automatically satisfying higher risk procedures.
• Accepting a certified copy of an expired document. For the wider requirements, see customer due diligence for accountants.

Solar Protect runs fee protection schemes for accountancy and bookkeeping practices. See how our accountant schemes work or read fee protection schemes for accountants.

Related Accountapedia entries

• Client due diligence when a client has no photo ID
• Verifying beneficial owners of corporate clients
• AML record keeping: what to keep and for how long
• When client due diligence must be completed
• The CCAB AML guidance for the accountancy sector
• Duplicate employment records from payroll ID changes

Sources

• legislation.gov.uk: SI 2017/692, regulation 28
• GOV.UK: Manual page AMLG11400
• ICAEW: Anti money laundering client due diligence
• ICAEW: Customer due diligence webinar q and a
• legislation.gov.uk: SI 2017/692, regulation 39
• GOV.UK: Certifying a document
• ICAEW: 2026 ccab aml guidance for the accountancy sector

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 19 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.