Verifying a client has two parts: checking their identity document, and checking their details against ATO records. Seamlss and Stripe help with the first. The second is done in Online services for agents. Then you record what you checked in Seamlss.
In Seamlss: the contact’s Identity Verification tab.
The ATO’s rule. Unless you sight a primary photo ID with the person in front of you, in person or on video, you need two separate proofs. A Stripe check of a licence is one. Checking the client’s details against ATO records is usually the second. See the ATO’s agent client verification methods.
Before you start #
- Work out who you’re verifying: the client, and anyone instructing you for them, such as a director, trustee or attorney.
- Have the client’s written authority before you link them at the ATO. Your signed engagement letter does this.
- Companies and other entities with an ABN must nominate you in Online services for business first. You then have 28 days to add them.
Check their ID document #
Request the ID check
Add Identity Verification to a client request, or select Request Identity Verification on the contact. We recommend DVS via Stripe Identity. With Visual Identity + ATO Source Identity, hold a short video call to compare the person with their licence: an uploaded photo on its own isn’t a visual check. See Choose an ID check method.
Review what came back, within 14 days
Open the contact’s Identity Verification tab and select Review Identity Verification. Check the name, date of birth and address match what the client entered in their entity details. Seamlss deletes ID documents after 14 days.
Check their details against ATO records #
Add or link the client in Online services for agents
Use their TFN and date of birth, or ABN and name. Confirm the name they gave matches the ATO record, and check their date of birth and address.
Match two more details the client gave you
The ATO wants two more details on top of the name match. Ask the client for each one, then match it against the ATO record. Use any of: the reference number on their Notice of Assessment, an activity statement DIN, an ATO correspondence reference number, their bank details compared with the bank account on the ATO record, or an amount such as a recent balance, refund or PAYG instalment (close is fine, within about 5%). Take the two from different sources. One uploaded NOA is one detail, so pair it with something else, such as the bank account they entered in their details.
Only use details the client gave you
Never read ATO information out to the client, and never take a number from the portal and record it as their evidence. That isn’t verification, and the ATO logs every access.
Check any ATO document they uploaded
With Visual Identity + ATO Source Identity, the client uploads an ATO document. Match its reference number or DIN against the ATO record for that client. A document that doesn’t match isn’t proof.
If something doesn’t match
Don’t tell the client which detail failed. Ask for more information. If you suspect fraud, delink the client and contact the ATO. Don’t change their bank or contact details at the ATO until verification is finished.
Record it in Seamlss #
Choose the Document Type
Record each check: Primary photographic ID has been provided for the ID, and Notice of Assessment (NOA) number, Activity statement DIN, ATO correspondence reference number, Bank account details or ATO account details for what you matched at the ATO. Note what you matched, and record only the first or last few digits of any number.
Choose the Document Sight Method
Electronically for Stripe and ATO portal checks, In Person for a face-to-face or video check, or Combination.
Confirm, then mark as verified
Tick Document Confirmation and select Mark as verified. You’re recording that your firm checked and was satisfied.
Keep the record, not the copies. Seamlss keeps the record of what was checked, by whom and when, and deletes the ID documents. The TPB expects that record kept for at least five years after the engagement ends, and recommends not keeping copies of ID. See TPB(GS) 42/2022.
Companies and trusts #
Confirm the entity exists, from an ASIC extract, the ABN record or the trust deed. Confirm the person acting for it has authority, from the ASIC officeholder record, the trust deed or minutes. Then verify that person’s identity with Stripe or a video check. Only use ATO records for them if they’re also your client.
When to check again #
When a client’s bank or contact details change, when the person acting for an entity changes, or after a break in the engagement. A client referred by another practitioner still needs your own checks. Client-to-agent linking isn’t identity verification.
If you also provide the client an AML designated service, AML customer due diligence applies as well, and an ID check is only one part of it. See We already do ID checks. Is that enough for CDD? AML customer due diligence records are kept for 7 years, longer than the TPB’s five. See How long do I keep client due diligence records? Then run the AML risk assessment.
Prefer video? #
Something not working? #
The request is complete but the contact is still Not verified
Nobody has reviewed it yet. Open Review Identity Verification and record the decision.
The documents are gone
They’re deleted after 14 days. If the review wasn’t done in time, request verification again.
Stripe returned Unverified
Read the error reason. An invalid or unreadable document is common, and asking for a different one usually fixes it. You decide what happens next.
The details don’t match the ATO record
Don’t say which detail failed. Ask the client for more information, and if you suspect fraud, delink them and contact the ATO.
The client is under 16
Stripe won’t verify them. Use Visual Identity + ATO Source Identity with a video check.
Still stuck? Contact support and tell us what you see.
