Certified copies are a method, not the rule

The question is everywhere in conveyancing forums because certified copies were the old habit. Checked against AUSTRAC's overview of initial customer due diligence on 5 October 2026, and against the OAIC reporting-entity guidance updated on 28 August 2026. This is general information, not legal advice. This page does not reproduce that guidance. What a result needs to contain is what an AML check covers. The matters beyond the document are customer due diligence requirements. When you do the work is customer due diligence before the designated service. The sector map is /tranche-2.

What the regulator's page allows

AUSTRAC says you can use third-party digital identity services to verify KYC information if the data is reliable and independent. You are expected to consider who maintains the data, including a government body, and whether the system is secure and current. If you doubt a document, the same page points to another independent source and names the Document Verification Service. None of those sentences says “and it must also be certified”. A firm that still demands a certified copy of every passport is following its own procedure. It should be able to say why, in the program, rather than “that is what we did in 2019”.

Certification and verification are different jobs. A certified copy is a human looking at an original and stamping a photocopy. An electronic check compares details with a source. Either can support a belief that a document is genuine. Neither finishes initial customer due diligence. Beneficial owners, purpose, and politically exposed person or sanctions questions remain. Clients feel the certified-copy step because it costs them a trip. If the program does not need the trip, stop imposing it.

A sensible split

• Default to the link where the customer can complete electronic verification and your program accepts that data.
• Use a certified copy when the electronic check cannot be done, or when the program says this customer type needs the paper. Write that case down. Do not apply it to everyone because one file failed.
• Do not keep the image without a reason. The OAIC says the Act does not require the copy for Tranche 2 from 1 July 2026. A stamp on a scan is not a reason to archive the scan.
• Do not accept a photo in a personal inbox as a substitute for either method. That is neither certification nor a reliable system.
• A company still needs KYB. Certifying the director's licence does not identify the company or the beneficial owners.

Clients hear “certified” and assume a particular office must do the stamping. Your program, if it still wants paper, should name what you accept and what you will not spend a week chasing. A clear photograph of a certified copy, sent through the firm's own channel and then destroyed if you do not need the image, is a different procedure from a stack of originals in a cabinet. Write the procedure down. Do not leave it as folklore that changes with whichever staff member answers the email. And do not let the argument about paper delay the rest of the file: purpose, beneficial owners, and the question of who is acting.

Where this page stops

This page is certification. The electronic service people mean next is DVS and electronic identity verification.

What the client pays

On FreeAML the firm suite is A$0. The firm emails the client a link. Verification is client-pays. On the public list a personal KYC check is A$20 and a company or trust KYB check is A$40. There is no subscription. Confirm the live amounts on FreeAML pricing. FreeAML does not charge a certification fee. The client pays the KYC or KYB check. A justice of the peace is not part of that price.

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