What identity evidence HMRC and the accountancy guidance expect

What to collect

The CCAB guidance for the accountancy sector says identification information for an individual should include their full name, date of birth and residential address.

What HMRC says must be verified

The customer's full name, photograph, date of birth and residential address must be verified by ID evidence. This may require you to obtain more than one form of ID evidence. At least one form of ID evidence should include a photograph of the customer.

HMRC lists examples of ID evidence, including:

• 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.

When the client doesn't have photo ID

HMRC's guidance says you should ask for:

• a valid identity document from an authoritative source that shows the client's full name and address, such as an old style driving licence or recent evidence of entitlement to a state or local authority funded benefit; and
• a further document showing the client's 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.

Check the documents, not just collect them

HMRC says you should do more than simply obtain ID documents. You should check each one to satisfy yourself of the client's identity and that the document is genuine, including details such as spellings. HMRC also notes that certifying a copy of a document does not by itself amount to enhanced due diligence.

Clients who live outside the UK

HMRC says you should obtain the same types of identity documents for non UK residents as for UK residents, and take extra care where you have concerns about whether a document is genuine.

Your supervisor may word it differently

HMRC supervises some accountancy firms directly. Others are supervised by a professional body that follows the CCAB guidance. The two sources are closely aligned but not identical, so follow the guidance issued for your own supervisor.