Verification of Identity for Tax Agent Clients

Verification of identity requires a registered tax or BAS agent to take reasonable steps to establish who a new client is before acting. The ATO expects verification before you add or link the client to your client list.

What the TPB and ATO Expect Before You Act

The Tax Practitioners Board (TPB) expects you to establish the client’s identity before providing tax or BAS services. Its current guidance is TPB(GS) 42/2022 Proof of identity requirements for client verification. It replaces the archived practice note.

The guidance explains how identity checks support the Code of Professional Conduct duties of honesty, competent service and reasonable care. It covers new individuals, new entities and the people instructing you for those clients.

The ATO’s verification methods govern checks when you use its online services. The TPB’s guidance applies even when you do not use those services. Client-to-agent linking establishes authority within ATO systems. It does not establish the identity of the person who engaged you.

Treat these as separate checkpoints. First establish the client and representative’s identity. Confirm the representative’s authority, then complete any required nomination and linking before accessing the client’s ATO records.

Verification of Identity Steps for Individual Clients

Verify an individual by collecting their details, examining acceptable evidence and comparing that evidence with the person. Use the TPB’s document categories to choose the correct combination.

Evidence category	Examples	How it fits
Primary photographic ID	Australian or foreign passport, driver licence, Australian government proof of age card	One original or certified primary photographic document meets the standard TPB document route
Primary non-photographic ID	Birth or citizenship certificate, government concession card	Combine it with a secondary document when photo ID is unavailable
Secondary ID	Medicare card, government notice, council rates notice or utility bill	Supports the non-photographic route; it is not interchangeable with primary photo ID

A government notice must show the client’s name and residential address and be issued within the past 12 months. Rates and utility notices use the past three months. Do not accept an old notice solely because the name matches.

Follow this order for a new individual client.

1. Collect the client’s full name and date of birth or residential address. Establish whether they act for themselves or use a representative.
2. Sight the required original or certified documents. Read the details and inspect the photo where there is one.
3. Compare the documents with the client and their stated details. Resolve a different surname or unreadable document before continuing.
4. Record the evidence, sighting method, checker and outcome while the check is fresh. Record any discrepancy and how you resolved it.
5. Complete any remaining ATO verification requirements before adding the client. The file must show a completed check, with no unresolved identity concern.

For example, a fictional individual attends their first office meeting with an original Australian passport. The staff member compares the photograph with the client. They match the full name and date of birth to the client’s details, inspect the document and record the result. The agent then completes the client-list step.

The ATO also permits methods using information held by the client and the ATO. These knowledge-based checks compare the client’s answers with ATO-held information. They require the ATO’s agent client verification method, including its required combination of checks. A familiar name, email address or a single tax figure is not an adequate substitute.

Verifying Company, Trust and Partnership Clients

For an entity, establish its existence and separately verify the person who gives you instructions. Record the entity’s legal name, ABN or ACN where applicable and the evidence connecting the representative to it.

Client	Entity evidence	Authority evidence
Company	Current ASIC company extract and matching identifiers	The extract identifies the instructing director as an officeholder; resolve any uncertainty about their authority
Trust	Executed trust deed and relevant variations	The deed and trustee changes identify the current trustee; for a corporate trustee, trace the company and instructing person
Partnership	Partnership agreement and matching registration details	The agreement identifies the instructing partner and any limits on their authority

An entity’s register entry does not identify the person holding the phone. Verify that person using an accepted individual method. For more than one client in a group, keep each entity and each relevant representative identifiable in the record.

Carry the correct legal names into the engagement letter and tax agent nomination. If the form names the trust but the engagement letter names its trustee company alone, resolve the difference before proceeding.

Tax Genie’s entity registration form collects the setup details for the practice to lodge the registration. Its number and register checks, followed by AI review, help find mistakes in those answers. Those checks do not establish the instructing person’s identity or authority. Tax Genie also has identity verification with a recorded staff determination, which is a separate check.

ID Verification Methods: In Person, Certified Copies and Electronic Checks

Identity verification is establishing that the person engaging your practice is who they claim to be. Choose a method that supplies evidence for that conclusion, including when the client is remote.

Method	Suits	What you record
Sight originals in person	A client visiting the office	Documents examined, comparison with the person and completed outcome
Receive certified copies	A remote client who cannot join a video call	Documents, certification and the accepted non-visual method used to complete the check
Electronic check with consent	A client completing onboarding online	Consent, accepted method, result and the staff determination

Certified copies establish that the copy matches the original. When you cannot visually compare the client with their ID, apply the relevant non-visual verification requirements as well. Use the certified-copy guide for certification requirements and rejection reasons.

An emailed photograph or ordinary scan is not a certified copy and does not by itself verify identity. Use a secure channel for sensitive documents. A video call can let you sight originals and compare the client with the photograph. Record that the sighting occurred by video.

Electronic checks must follow an accepted method. The digital identity guide explains that option without replacing the practice’s determination.

Australia Post ID Verification for Remote Clients

Australia Post’s listed identity services are purpose-specific, so do not send a new tax client to a post office for an assumed general check. Its ID and document services page lists property verification and identity checks for TFN applications. Those services have their own purposes and forms.

Australia Post’s Digital iD app and Keypass in Digital iD are closed. A client searching for Australia Post digital ID cannot use that former app to complete your practice’s check. Do not send them an old Digital iD instruction sheet.

An Australia Post verification of identity form for a property transaction belongs to that service. It is not a tax-agent client-verification form. A result from a purpose-specific check also cannot establish someone’s authority to instruct you for a company or trust.

Consider a fictional client in regional Western Australia who has a passport but no driver licence. For a video appointment, ask the client to have the original passport available. Compare the photograph with the person on the call and read the identifying details. Record the passport sighting, video method, checker and outcome before the client-list step.

If the client cannot join a video call, arrange certified copies and the appropriate non-visual verification method. This gives the client an executable route without assuming that a local post office has a service for your engagement.

The 100 Point ID Check Compared With Current Rules

The 100 point ID check comes from the financial transaction reporting regime used for financial account identification. The historical Financial Transaction Reports Regulations 1990 set out a points-based verification procedure and document checks. That history explains the familiar term used in bank paperwork.

Tax-agent client verification uses the TPB’s evidence categories and the ATO’s accepted methods. It does not turn on reaching a generic score. Both approaches examine identifying information, but a points total alone cannot establish an entity representative’s authority.

Incorrect: mark the client verified because an internal form totals 100 points, while the person’s identity remains unresolved. Correct: record the accepted method, required evidence and completed comparison, then separately confirm any authority to act.

You can keep a points-style checklist inside the practice if it captures the applicable TPB and ATO requirements. Make the pass condition the completed evidence and checks, not the score printed at the bottom.

Clients Overseas or Without Australian ID

An overseas client can use acceptable foreign identity documents. Australian photo ID is not the only route. A foreign passport is within the TPB’s primary photographic category. An electronic method must support that document and the client’s circumstances.

Certified copies can also be arranged overseas. Smartraveller’s notarial guidance explains Australian embassy and consulate services and local notary options. Give the client the practice’s accepted certification requirements before they pay or travel. Certification still leaves you to complete the appropriate identity check.

For a recent arrival without a passport, or an older client without a licence, consider the primary non-photographic and secondary document route. A young person leaving care may need a flexible assessment because conventional documents are unavailable. The TPB permits a flexible approach in such circumstances, with detailed records of the situation and checks undertaken.

A referee statement can support the practitioner’s assessment where appropriate. Do not treat it as an automatic substitute for every required document. Record who the referee is, their basis for knowing the client and how their information supports the conclusion.

For documents in another language, obtain an English translation where needed to understand and verify them. The TPB requires an accredited translation of a foreign birth or citizenship certificate when the verifier cannot understand its language. Record the translator and retain the relevant translation with the check record.

When a Client Will Not Provide ID

Hold the engagement if you cannot establish a new client’s identity. Do not provide the tax or BAS service, lodge for the client or add them to the ATO client list. Without the check, you cannot be satisfied that you are acting for the correct person.

Admin staff can use this suggested wording.

We verify every new client’s identity before our tax agent starts work. You can use accepted identity documents, and we can arrange a remote check if you cannot attend.

Tell the client which acceptable documents they can use. Arrange an appropriate remote route if attendance is the problem.

Distinguish refusal from lack of conventional documents. The latter needs an assessed alternative, not automatic rejection. If a mismatch remains unexplained, request evidence that resolves it. Decline the engagement when you still cannot establish identity.

When the practice provides designated services, refusal combined with other warning signs also needs assessment under its anti-money laundering and counter-terrorism financing (AML/CTF) procedures. The KYC guide for accountants covers those additional customer due diligence steps.

A decline note can record the identity requirement explained, evidence requested, alternatives offered and the unresolved issue. Record who made the decision and when. State that the engagement was declined before services or lodgement, without calling the client fraudulent solely because they refused ID.

Verification of Identity Form and File Notes

A verification of identity form records how the practice reached its conclusion. Put it at the identity checkpoint in your onboarding steps, before sending the engagement letter for signature as a practice policy.

Use these fields for each individual and representative.

• Client’s full name and date of birth or residential address.
• Entity name and identifier, where applicable, with representative’s role and authority evidence.
• Each document’s type, issuer and the identifying details necessary for the chosen method. Include number and expiry only where needed.
• Method used, including in-person, video, certified-copy or electronic evidence.
• Date and time of the check, verifier’s name and position.
• Confirmation that documents were clear and legible, matched the person and raised no unresolved concern.
• Discrepancies, follow-up evidence, determination and any reason for an alternative approach.

The TPB requires a contemporaneous record and retention for at least five years after the engagement ends. It does not require or recommend retaining ID copies. The OAIC’s ID-scanning guidance also limits collection to what is reasonably necessary. Keep the check record without accumulating full ID scans merely as a precaution. Apply any separate legal retention requirement to the records it actually covers.

Tax Genie records identity-check methods and staff determinations. Its staff-correction history records who changed a client answer and when. The TFN reveal log records who viewed a TFN and when. Those histories answer different questions and cannot replace the identity-check evidence.

Before releasing the file to the agent, confirm that the identity determination is complete, authority evidence matches the client and any required ATO step is finished. A blank outcome or unresolved mismatch keeps the file at the verification step.