Know Your Customer (KYC) is the cornerstone of any effective anti-money laundering and counter-terrorism financing framework. Under Australia's AML/CTF Act 2006, KYC is not merely a box-ticking administrative task—it is a binding legal obligation. Following the commencement of the Tranche 2 reforms, these obligations now apply directly to professional service firms and other non-financial businesses.
If your business provides designated services—whether you are a lawyer, accountant, conveyancer, real estate agent, trust and company service provider, precious metals dealer, or virtual asset service provider—you must verify your customers' identities before establishing a business relationship. This guide provides a detailed breakdown of the 2026 KYC requirements, acceptable identity documents, and digital verification standards.
What is KYC?
KYC is the process of collecting and verifying a client's identifying information. Under the Act, the objective is to establish with reasonable certainty that a client is who they say they are. This prevents individuals from operating anonymously or under false names to hide the proceeds of crime.
The KYC process involves two main parts:
- Collection: Gathering key information from the client (such as their full name, date of birth, and residential address).
- Verification: Confirming that this information is accurate by comparing it against reliable, independent documents or electronic data sources.
Acceptable Identity Documents
AUSTRAC rules specify which documents are acceptable for verifying an individual's identity. These are divided into primary and secondary documents:
Primary Photographic Identification
These documents contain both a photograph and a signature, making them the most reliable form of ID. You can verify a client using a single primary photographic ID:
- An Australian driver's licence (current).
- An Australian passport (current, or expired within the last two years).
- A foreign passport issued by a sovereign government (containing a translation if not in English).
- An Australian proof of age card.
Secondary Non-Photographic Identification
If a client does not have a primary photographic ID, you must verify their identity using a combination of **one** primary non-photographic ID and **one** secondary document:
- Primary Non-Photographic ID: An Australian birth certificate, citizenship certificate, or a Medicare card.
- Secondary ID: A utility bill (gas, electricity, water) or council rates notice issued within the last 3 months showing the client's name and residential address, or a notice from the ATO or Centrelink issued within the last 12 months.
Warning: Photocopies of documents are not considered 'original' or 'reliable' unless they have been certified by an authorised person (such as a Justice of the Peace). Alternatively, digital verification tools must be used to scan the original document directly.
Digital and Biometric Verification
Manual verification—such as asking clients to bring physical documents into your office to photocopy—is increasingly obsolete, highly insecure, and inconvenient for remote clients. In 2026, the industry standard is digital identity verification.
Digital KYC platforms (like CompliDesk) integrate with the Australian Government's **Document Verification Service (DVS)** to check the validity of passports, driver's licences, and Medicare cards against government databases in real time. Combined with **biometric facial matching** (where the client takes a selfie to match against their ID photo), digital verification meets AUSTRAC's 'reliable and independent' source requirement and can be completed in under two minutes.
KYC for Corporate and Trust Clients
Verifying a business entity (often called Know Your Business or KYB) requires a multi-layered approach:
- Verify the Entity: Collect and verify the company name, registration number (ABN/ACN), registered address, and principal place of business using an ASIC search. For trusts, obtain and review the trust deed.
- Verify the Individuals: Identify and verify the identity of the directors (for companies) or trustees (for trusts).
- Trace Beneficial Ownership: Identify any individual who ultimately owns or controls 25% or more of the entity (the Ultimate Beneficial Owners) and perform standard KYC checks on them.
Important: If a company is owned by another company, you must trace the ownership chain upwards until you identify the actual living individuals who hold the ultimate control.
Timing and Risk-Based Approach
Under the Act, you must complete the KYC process **before** you provide the designated service. If you are unable to verify the client's identity, you must not proceed with the transaction, and you should consider whether the client's reluctance to provide ID warrants submitting a Suspicious Matter Report (SMR) to AUSTRAC.
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Related reading: Customer due diligence explained · KYC/KYB for companies & trusts · 15 common AML compliance mistakes · Frequently asked questions