Primary ID documents are examples, not the whole KYC test

You will be asked for the official list, as if a blog could settle every document a client might hold. It cannot. Checked against AUSTRAC's initial customer due diligence guide for individuals, the AML/CTF Act, and the AML/CTF Rules 2025 on legislation.gov.au on 14 October 2026. This is general information, not legal advice. This page does not reproduce that guidance. Why a points score is a different question is the 100-point check against AML verification. Certified copies are their own question. Checking data rather than paper is electronic identity verification. The sector map is /tranche-2.

The test is the data, not the stationery

Section 28 says you verify, using reliable and independent data, the KYC information that is appropriate to the customer's risk. The 2025 Rules are the current rules instrument. This page does not pretend they contain a 100-point table, and it does not copy a closed catalogue out of them. The examples below are AUSTRAC's. You follow that guide, the Act, the Rules, and your program.

AUSTRAC says you collect enough to tell this person from another with a similar name. Its examples are the full name, any other name they use, date of birth, residential address, and a unique identifier if they have one. Collection is not verification. A name on the file can still be unverified.

Primary photographic documents

AUSTRAC's examples of a primary photographic identification document are a current driver's licence, a passport, a proof of age card, or a foreign national identity card. The guide says you could verify full name and date of birth from that document, and you could match the person to the photograph in person, on a video call, or with biometric technology. Could is AUSTRAC's word. Your program chooses the path. An expired card is not automatically acceptable, and a photograph alone is not customer due diligence.

A foreign document you cannot read is a practical problem, not a loophole. Your program should say how you get a version you can rely on. This page does not name a translator panel, and it does not invent a rule that any bilingual staff member's note is enough. If the document is not independent of the customer, it is not doing the section 28 job, whatever language it is in.

When there is no photograph

The other example path is a primary non-photographic document, such as a birth certificate, a citizenship certificate, or a concession card, together with a secondary document that shows name and address. AUSTRAC's examples of that secondary document are a utility bill, or a notice from a Commonwealth, state, territory, or local government body. A birth certificate on its own is not that path. A secondary document is not a points top-up.

• Use the path your program chose. Photographic, or non-photographic plus secondary. Do not invent a third path because the client is in a hurry.
• Keep what you relied on. The document or the electronic data, and what you verified. A tick that says ID sighted is not the data.
• Match the person to the photo when you have one. In person, on a video call, or with the biometric step your program uses.
• An entity file does not stop at one licence. Beneficial owners are a separate identification.
• Missing documents are not an automatic refusal. AUSTRAC points to alternative identification guidance. This page does not reproduce it, and it lists no substitutes.

Electronic data can verify the same information, if it is reliable and independent. A picture of a card in a message is not that data merely because it is digital. From 1 July 2026 the new designated services put this work on professional files. You do not commence a designated service until initial customer due diligence is done, subject to the special cases and exemptions the Act and Rules set out. Enrolment sits on AUSTRAC Online. FreeAML does not enrol you.

Where this page stops

This page is the document examples for an individual. The reason a points total is not the test is the 100-point check against AML verification. Who you still have to see on a company or trust is a beneficial owner. A wider KYC walk-through is the KYC check guide.

What your client pays

FreeAML is a full AML/CTF platform for firms of every size. On FreeAML you pay $0 for the suite. There is no subscription. Your client can pay, and you can add a per-verification service charge. Verification is client-pays. On the public list a personal KYC check is $20 and a company or trust KYB check is $40. Confirm the live amounts on FreeAML pricing. FreeAML does not decide that a document is primary, and it does not replace section 28.

Frequently Asked Questions