Client due diligence when a client has no photo ID

Q: What does a sound file look like?

Illustration only. A widow of 84 asks a practice to prepare her self assessment return after her husband's death. Her passport expired years ago and she has never held a driving licence. The practice records that standard photo ID is unavailable and why. It obtains a letter from her pension provider confirming her name, address and that she receives a pension, and a current bank statement in her name at the same address, checking the provider's letter by calling its published number. Her son, who is helping, is not treated as the client, but because he will pass on instructions the practice confirms his authority and verifies his identity from his passport. The file notes that the risk is assessed as low, the evidence obtained, who checked it and the date.

The Money Laundering Regulations do not require a passport or driving licence. They require identity to be verified from documents or information obtained from a reliable source independent of the client, so a client without photo ID can usually be verified using other official documents, letters from a professional who knows them, certified copies or a certified digital identity service. The firm must record why standard documents were not available and judge whether the gap is plausible for that person.

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What does the law actually require when verifying identity?

Regulation 28(2) of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the MLRs) requires a firm to identify the client and verify that identity. Regulation 28(18) defines verify as verifying on the basis of documents or information obtained from a reliable source which is independent of the person whose identity is being verified. It adds that documents issued or made available by an official body count as independent even if the client hands them over personally.

Nothing in regulation 28 names a passport, a driving licence or a photograph. Photo ID is the most convenient way to meet the test, but it is not the test itself. What the firm has to be able to show its supervisor, under regulation 28(16), is that the measures it took were appropriate to the money laundering risk. For the wider framework, see customer due diligence for accountants.

What does HMRC treat as standard evidence?

HMRC’s guidance for supervised businesses (AMLG11400, section 14) says that for a private individual a firm should obtain the full name, date of birth and residential address, and then verify them. Its standard list is ID issued by a recognised body with security features, showing the full name and photo with the date of birth or address, such as:

a valid passport;
a valid photocard driving licence, full or provisional;
a national identity card;
a firearm certificate;
an identity card issued by the Electoral Office for Northern Ireland.

HMRC says at least one form of evidence should include a photograph where standard documents are used. Firms supervised by a professional body follow the CCAB guidance for the accountancy sector, which HMRC’s manual at AMLG2000 describes as agreed with HMRC and HM Treasury. ICAEW reports that the 2026 edition added a hierarchy of evidence with a passport as the preferred document, alongside other acceptable documents.

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What can be accepted when there is no passport or driving licence?

HMRC’s guidance sets out a fallback where identity cannot be fully verified from the standard list. The firm should ask for two things together:

a valid identity document from an authoritative source without a photo, which shows the full name and evidence of address, such as an old style paper driving licence or recent evidence of entitlement to a state or local authority funded benefit, for example housing benefit, council tax benefit, a pension or tax credit; and
a further document evidencing the address that can be verified as true by an authoritative source, such as a utility bill, a bank, building society or credit union statement, or the most recent mortgage statement.

The documents must come from a reliable source not connected to the client, such as a bank, utility company or local authority. HMRC also notes that a record of a staff visit to the client’s home may corroborate the address, provided the firm is satisfied the property is the genuine home address.

Who typically cannot produce standard documents, and what then?

AMLG11400 section 14.3 recognises that some people, such as elderly clients or those who cannot manage their own affairs, may have let a passport or licence lapse because they have stopped travelling or driving. HMRC says firms should exhaust the standard documents first and record the reasons why they cannot be provided. Acceptable alternatives come from a reliable, independent source with knowledge of the person, for example a letter from:

a medical professional;
a legal professional;
the head of a care home with relevant professional qualifications;
a pension provider confirming the person receives a pension.

The firm should take steps to confirm such a letter is genuine, for example by checking document references or organisation stamps, or by contacting the author. HMRC also expects firms to have procedures to identify clients who cannot produce standard documents (AMLG11300, section 13.3). Where an attorney or deputy instructs the firm, regulation 28(10) requires the firm to verify that person’s authority and identity as well. Related situations are covered in deceased clients.

Can certified copies or electronic checks fill the gap?

Often, yes. HMRC says originals should be produced wherever possible, but a copy certified as a true copy by a suitable professional, such as a solicitor, can be accepted. The certifier should write that it is certified to be a true copy of the original seen by them, sign and date it, print their name and add their occupation, address and telephone number. HMRC adds that certification is not in itself enhanced due diligence.

Regulation 28(19) allows information from an electronic identification process to count as independent where the process is secure from fraud and misuse and gives an appropriate level of assurance. HMRC’s guidance on digital identities says services certified against the UK digital verification services trust framework and on the DVS register can be used, and services not on the register cannot reliably be treated as suitable. The same guidance notes that many digital services rely on passports and driving licences, so a provider will not always help a client who has neither. See electronic identity verification for how these checks work.

Should the lack of photo ID change the risk assessment?

It should prompt a judgement, not an automatic escalation. Regulation 28(12) requires the extent of due diligence to reflect the firm’s risk assessment and the risk in the particular case. HMRC lists as a warning sign a case where checking identity is difficult given the client’s demographic group and the likelihood they would have sufficient identity evidence. A housebound 88 year old with an expired passport is unsurprising; a 35 year old company director who travels for business and says they have no passport or licence is not, and deserves questions. Use the firm’s client risk assessment and, where the risk is higher, apply enhanced due diligence.

Timing does not relax because evidence is hard to obtain. Regulation 30(2) requires verification before the relationship is established, and HMRC says the narrow exception in regulation 30(3) does not allow a firm to delay due diligence because it is hard to verify a client.

What does a sound file look like?

Illustration only. A widow of 84 asks a practice to prepare her self assessment return after her husband’s death. Her passport expired years ago and she has never held a driving licence. The practice records that standard photo ID is unavailable and why. It obtains a letter from her pension provider confirming her name, address and that she receives a pension, and a current bank statement in her name at the same address, checking the provider’s letter by calling its published number. Her son, who is helping, is not treated as the client, but because he will pass on instructions the practice confirms his authority and verifies his identity from his passport. The file notes that the risk is assessed as low, the evidence obtained, who checked it and the date.

What mistakes should firms avoid?

Turning away a genuine client because a policy demands photo ID that the law does not.
Accepting a single non photo document with nothing to corroborate it.
Taking documents from a source connected to the client, such as a letter from a family member or the client’s own business.
Failing to record why standard documents were not available.
Treating a professional’s letter as genuine without checking the author exists.
Starting work before verification is complete because the evidence is slow to arrive.
Ignoring an implausible explanation for having no ID, which may itself be a red flag to report to the MLRO.

Copies of whatever evidence is used must be kept under regulation 40; see AML record keeping.

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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.