Can accountants rely on old ID documents when refreshing CDD?
Last updated: May 18, 2026
A CDD refresh does not automatically require an accountancy firm to collect fresh ID from an established client.
Existing evidence may remain usable where the original check was sound, the client details remain consistent, and the current risk assessment justifies relying on it.
Updated evidence is more likely where the old file is incomplete. It may also be needed if client details have changed or earlier checks are now in doubt.
Contents
Key takeaways
- Firms should start with the evidence already held before deciding whether fresh documents are needed.
- Existing ID may remain usable where the original check was sound and the client’s details still align.
- ICAEW guidance suggests an expired passport does not automatically require replacement, although that view requires careful consideration.
- Proof of address needs separate thought because residential address information can become out of date even when identity details remain stable.
- The file note should explain why older evidence was accepted or why updated material was requested.
What the Money Laundering Regulations require
The Money Laundering Regulations are central here. They separate the duty to keep CDD current from any assumption that every review needs a new passport, driving licence, or proof of address.
- Regulation 27 brings existing customers within CDD at appropriate times and on a risk-sensitive basis, including material changes in client circumstances.
- Regulation 28 sets the substance of CDD. It covers identifying and verifying the customer and, where applicable, those acting for the customer and beneficial owners, using reliable and independent documents, data, or information.
- Regulation 30 matters when the original verification was incomplete or unclear. A file gap is not cured simply because the client has remained with the practice for several years.
- Regulation 40 requires CDD records to be retained. The important point is that record-keeping supports the evidence trail and the judgement made at review. It does not create a routine document-replacement rule.
Taken together, these provisions make the firm’s reasoning important when earlier evidence is kept on file instead of being replaced.
CDD refreshes do not have to repeat onboarding
A CDD refresh starts with the information already held. Firms should check whether that information still gives a fair picture of the client, rather than treating the review as a new onboarding exercise.
CCAB guidance supports this approach. It recognises that refresh work may require less new information than onboarding, provided the existing file remains adequate. That said, the firm still needs to decide whether the extent of CDD matches the client’s risk.
For example, a long-standing payroll client may have unchanged ownership and contact details, with the same low-risk service profile since the file was last reviewed. In this situation, the refresh may focus on confirming the AML position and recording the judgement.
When old identity evidence may still be enough
Identity documents on file may continue to carry weight if the original verification was properly carried out.
A clear copy of an independent document, matched to the correct individual and supported by a proper onboarding note, gives the firm a stronger basis.
The file also needs to connect the document to the person the firm is relying on now.
- For an individual client, this is usually the person whose identity was verified at onboarding.
- Yet for a company, this could be the relevant person acting for the client or an individual connected with ownership or control, depending on what the file is being used to support.
Once the firm has identified whose evidence matters, the next step is checking whether the core identity details still align. This sits within the wider client risk assessment.
A simple, low-risk engagement with no apparent factual movement may call for less new material. However, a client file where the service line or facts now raise concerns may need stronger evidence before the firm relies on the old file.
This is why the quality of the original file is fundamental. A review can confirm a good file, but it cannot make sense of a poor one.
When fresh ID may be needed
- A common issue for smaller practices is the inherited paper file. A note saying “passport checked” carries limited value where there is no copy or document reference.
- New material may also be needed if the person giving instructions is different from the individual previously verified.
- The same approach applies if later information conflicts with the document or note on file.
Expired passports: What ICAEW guidance says
An expired passport can draw attention during a CDD refresh, but expiry alone does not necessarily undermine the original identity check.
ICAEW guidance says a new passport is not required solely because the original passport has since expired, provided it was valid when checked and no relevant details have changed.
Updated photo ID may be needed where later information raises concern about identity, document authenticity, or the risk attached to the relationship.
Why proof of address needs separate treatment
A passport copy might continue to help with identity, while an old utility bill or bank statement may say little about where the client now lives.
HMRC points firms towards their own PCPs for document recency. This is especially relevant for address evidence because it normally supports a present fact.
If the accountancy practice accepts older address material, the decision needs to fit the client circumstances and the firm’s usual standards. It should also be capable of explanation if the file is later reviewed.
For instance, a client’s name and date of birth may continue to align with the passport copy held from onboarding. Yet later correspondence could suggest a different residential address.
Here, the identity evidence might still have value, while the address information could need updating or further inquiry.
What the AML record note should show
When earlier identity material is accepted, the file note should explain why it remains suitable for that purpose.
It might refer to the document being valid when checked and no conflicting information being identified.
If the firm obtains updated material, the note should identify what made the previous document insufficient.
For address evidence, the record should explain why the address being used remains valid, or what additional checks supported the decision. If the firm departs from its usual document-recency standard, the reason for that exception should be clear and consistent with its policies.
The key discipline is to assess whether the file can bear the evidential weight being placed on it. Supervisory concern about weak CDD and poor records reinforces the need for care, without creating a blanket document-renewal rule.
In summary
A CDD refresh should start with the evidence already held. Fresh ID is not automatic, but the firm must be able to justify why older material remains suitable.
The safest position is to check what the evidence proves, if anything relevant has changed, and whether the AML record needs to explain the decision.
FAQs
No. Firms should assess whether the evidence already held remains suitable for the client’s current AML position.
ICAEW guidance suggests a new passport is not required solely because the original passport has since expired, provided it was valid when checked and no relevant details have changed. Firms should apply that view carefully and consider whether anything now raises a concern about the client’s identity, authenticity, or risk.
It depends on what the proof of address is being used to evidence. Address information can change, so an old utility bill or bank statement may be weaker support for the client’s current residential address than it was at onboarding.
The file note should explain why the earlier evidence remains suitable. It may refer to the original document being valid when checked, with no conflicting information identified during the review.
References and Source Material
- Money Laundering Regulations 2017 (Regulation 27, 28, 30, 40)
- HMRC, Economic Crime Supervision Handbook (ECSH33320, ECSH33325, ECSH33356, ECSH33375)
- CCAB, Anti-Money Laundering Guidance for the Accountancy Sector
- ICAEW, Client identification and verification
- ICAEW, Checking the evidence: is your client who they say they are?
