ID documents for AML checks: what UK firms accept
Which identity and address documents are accepted, whether an expired passport counts, how to tell whether a passport is biometric, and what to do when a scan will not work.
By Mehmood Rajoka · Last updated 2026-08-12
TL;DR: Quick Summary
- •MLR 2017 does not publish a list of acceptable documents. It asks for identity to be verified from a reliable, independent source, and leaves the firm to justify what it accepted.
- •In practice most UK firms want one photographic identity document and one document evidencing address, from independent sources.
- •An expired British or Irish passport is acceptable for a right to work check, provided it has not been clipped or cancelled. That is a right-to-work rule, and it does not automatically carry across to AML customer due diligence.
- •A biometric passport carries a small rectangular chip symbol on the front cover. UK passports have been issued in biometric form since 2006.
- •Most delay in a check comes from documents that do not match each other, not from documents being the wrong type.
Answer-first summary
What ID documents are accepted for AML checks?
The Money Laundering Regulations 2017 do not publish a list of acceptable documents. Regulation 28 requires a firm to verify identity from a reliable, independent source, and leaves the firm to justify what it accepted. In practice most UK firms ask for one photographic identity document, usually a current passport or a UK photocard driving licence, together with one document evidencing address from an independent source, such as a recent utility bill, council tax bill, or bank statement.
- No statutory list of documents exists
- Reg 28 asks for a reliable, independent source
- Usually one photo ID plus one address document
- The two should come from independent sources
What firms usually ask for
Four categories, and the reason each is asked for:
Photographic identity
A current passport is the most straightforward, because it can be validated electronically and read from its chip. A UK photocard driving licence and a national identity card from an EEA state are the usual alternatives. A firm can accept others, but should be able to say why it treated them as reliable.
Evidence of address
A recent utility bill, council tax bill, bank or building society statement, or an HMRC or local authority letter. Firms commonly ask for a document dated within the last three months, and expect it to come from a different source than the identity document.
For companies
The incorporation record, registered office, directors, and people with significant control. A company check is not a document check on one person; it is establishing the structure and then verifying the individuals behind it.
Electronic verification
Electronic checks are acceptable under Regulation 28 where the source is reliable and independent. They are not a different standard, just a different method, and the firm still needs to understand and be able to explain what the check tested.
Can you use an expired passport as ID?
The answer differs by purpose, which is why this question causes so much confusion:
Right to work: an expired British or Irish passport is acceptable
Home Office guidance treats a British or Irish passport as a List A document whether it is current or expired. The document still has to be genuine, belong to the person presenting it, and be intact.
A clipped or cancelled passport is never acceptable
A passport with the corners of pages cut off has been cancelled. It is not valid evidence for a right to work check regardless of the expiry date.
AML due diligence is a separate judgement
The right-to-work rule does not automatically transfer to customer due diligence. MLR 2017 asks for a reliable, independent source, and most firms take the view that a current document is more reliable than an expired one. A firm that accepts an expired document should record why it was satisfied.
Electronic checks usually require a current document
Document-validation technology often depends on the chip or on data that is only checkable while the document is in date, so an expired passport may simply fail an automated route even where a manual check would have accepted it.
Biometric passports and scanning
What the chip is, how to tell whether your passport has one, and why a scan sometimes fails:
- A biometric passport, sometimes called an ePassport, carries a small rectangular symbol on the front cover: a rounded rectangle with a circle in the centre. If that symbol is present, the passport has a chip.
- UK passports have been issued in biometric form since 2006, so a UK passport issued in the last two decades will almost always be biometric.
- The chip holds the same details printed on the photo page, plus a digital image of the photograph, secured so that alteration can be detected.
- Scanning is done with the NFC reader in a modern smartphone. The phone reads the machine-readable lines on the photo page first, because those supply the key that unlocks the chip.
- If a scan fails, it is usually the phone position or a case interfering with NFC rather than a problem with the document. Holding the phone flat against the photo page or the back cover and staying still generally resolves it.
FAQ
Answer-first summary
What ID documents are accepted for AML checks in the UK?
MLR 2017 does not publish a list. Regulation 28 requires identity to be verified from a reliable, independent source, and leaves the firm to justify what it accepted. In practice most UK firms ask for one photographic identity document, usually a current passport or UK photocard driving licence, and one document evidencing address from an independent source, such as a recent utility bill, council tax bill, or bank statement.
Answer-first summary
Can you use an expired passport as ID?
For a right to work check, yes: Home Office guidance treats a British or Irish passport as an acceptable List A document whether current or expired, provided it is genuine, belongs to the person presenting it, and has not been clipped or cancelled. For anti-money-laundering customer due diligence the position is different. MLR 2017 asks for a reliable, independent source, and most firms treat a current document as more reliable, so an expired passport may be refused or require a documented justification.
Answer-first summary
Is a clipped passport valid ID?
No. A passport with the corners of pages cut off has been cancelled, and it is not acceptable evidence for a right to work check regardless of its expiry date. The clipping is what marks the document as withdrawn from use.
Answer-first summary
How do I know if I have a biometric passport?
Look for a small rectangular symbol on the front cover: a rounded rectangle with a circle in the centre. That symbol means the passport contains a chip and is a biometric passport, sometimes called an ePassport. UK passports have been issued in biometric form since 2006, so a UK passport issued in the last two decades will almost certainly have one.
Answer-first summary
Where is the chip in a UK passport?
The chip is embedded inside the passport rather than visible, and its position depends on when the passport was issued: in older UK passports it sits in the back cover, and in more recent designs it sits within the photo page. You do not need to know which, because a phone reads the chip through the cover. The rectangular symbol on the front is what tells you a chip is present at all.
Answer-first summary
How do I scan my passport with my phone?
Use the app or link the firm has sent you rather than a generic scanner. It will first ask you to photograph the photo page, because the machine-readable lines at the bottom supply the key that unlocks the chip. It will then ask you to hold the phone against the passport so the NFC reader can read the chip. If it fails, remove any phone case, hold the phone flat against the photo page or the back cover, and keep both still for a few seconds.
Answer-first summary
What can I use as proof of address?
A recent utility bill, council tax bill, bank or building society statement, or a letter from HMRC or a local authority. Most firms ask for a document dated within the last three months and expect it to come from a different source than the identity document, so that two independent sources are corroborating each other. Mobile phone bills are often excluded, so it is worth checking what the firm asking will accept.
Answer-first summary
Why has my ID been rejected when the document is valid?
Usually because documents do not agree with each other rather than because a document is the wrong type. A name spelled differently, a former address on a bill, or a middle name that appears on one document but not another will all stop a check. These are resolvable, but they need an explanation and sometimes a supporting document rather than a resubmission of the same file.
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ContinueQuality standard for this guide
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Authorised Corporate Service Provider
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