Can You Verify Clients Electronically Under Tranche 2? Online ID Checks Explained

Who this page is for

ScreenlyyID is for small and mid-sized professional firms, such as accountants, lawyers, conveyancers and real estate agencies, that need to verify clients without handling photocopies. Clients complete the check from a link on their phone, and you can start on a self-serve basis. The starting price is shown on the live pricing page; check it there rather than relying on any figure quoted elsewhere. Tranche 2 firms can also see Tranche 2 pricing.

This page covers one question: whether and how identity can be verified electronically. For who is covered by Tranche 2 and what it requires overall, read the Tranche 2 explainer. For the wider customer due diligence process, see the page on customer due diligence under the Rules.

What "reliable and independent" means in practice

The AML/CTF Rules 2025 set out how a reporting entity may verify the information it collects about a customer. The core idea, which runs through Australian AML/CTF verification requirements, is that you rely on documents, data or information from a reliable and independent source. Read the exact wording in the AML/CTF Rules 2025 on the Federal Register of Legislation and in guidance on the AUSTRAC website, because the detail and any applicable conditions matter and can change.

Two tests are useful to apply to any method:

• Reliable: is the source accurate, current and hard to forge or manipulate? A government record or a document with verifiable security features is stronger than a self-declared form.
• Independent: does the source sit outside your relationship with the client? A client typing their own details into your form is not independent evidence of anything. A database the client cannot edit, or an issuing agency's record, is.

Nothing in this approach requires the client to appear in person. What matters is that the method gives you reasonable confidence that the person is who they claim to be, and that the confidence is proportionate to the risk.

The main electronic methods and what each proves

Each method answers a different question. Treating them as interchangeable is the most common mistake.

Read the table by column: every method has a gap. That is why combining methods is the practical answer for anything beyond low-risk clients.

Electronic verification (eIDV)

An eIDV check matches the details a client supplies against independent data sources. It is quick and needs little from the client, which makes it a sensible first step for lower-risk individuals. It works best when the client has a reasonable footprint in the data sources used, so have a fallback for people who do not, such as recent arrivals or young adults. See ScreenlyyID eIDV and the explainer on how eIDV works.

Document plus selfie

The client photographs their ID with their phone, then takes a live selfie. The system checks the document for signs of forgery or tampering, runs a liveness check to guard against photos, screen replays and masks, and compares the face to the document portrait. This is the closest electronic equivalent to looking at a passport and then at the person in front of you. See document authentication and biometric verification.

Government DVS checks

The Australian Document Verification Service lets organisations check whether details on certain government-issued documents match the issuing agency's record. Information on the service is at idmatch.gov.au. Access is typically arranged through an approved provider and is subject to the service's conditions, so confirm eligibility before you build a process around it.

Combining methods by client risk

The Rules expect a risk-based approach. Your AML/CTF policies should say which verification method applies to which type of client, and why. A simple structure looks like this:

This is an illustration of the logic, not a rule. Your own risk assessment decides the tiers. If a check fails or returns a partial result, define in advance what happens next: a retry, an alternative document, or escalation to a person. Do not let a failed automated check quietly become a pass.

Verifying clients who are not in the room

Remote clients are where electronic methods help most and where the risks rise. A client you have never met, who is instructing you from another city or country, gives fewer natural cues. Two points to build into the process:

• Tie the person to the identity. A data match alone does not prove the person on the other end is the identity owner. Use a live biometric check for remote clients, especially where the matter is higher value.
• Watch for manipulation. Synthetic faces and edited documents are a real concern for any remote process. Choose tooling with liveness detection and document checks, and keep a human review step for anything the system flags. See the guide to deepfake detection.

Also consider the other side: some clients cannot use a phone-based flow, for example because of accessibility needs or lack of suitable ID. Have a documented alternative, and check the current Rules and AUSTRAC guidance on how to handle clients who cannot provide standard documents.

What the client experiences

For the client, an electronic check is short and happens on a device they already own:

1. They receive a link by email or SMS from you.
2. They open it on their phone and confirm their details.
3. They photograph their ID document using the phone camera.
4. They take a short live selfie, following on-screen prompts.
5. They see a confirmation, and you see the outcome in your dashboard.

There is nothing to install and no account to create. For you, the result appears as a case showing which checks ran and what they returned. Anything ambiguous can be reviewed by a person; see case review.

Screenshots of the client flow are not shown on this page. Ask for a walkthrough or try the flow yourself after sign-up.

What is included and what is separate

To be direct about the ScreenlyyID product:

• Core verification methods: document authentication, biometric and liveness checks, and eIDV database checks are part of the identity verification offering.
• Related checks: AML, sanctions and PEP screening, plus address, email and phone validation, are available as separate capabilities you can add to the same workflow.
• DVS: treat government DVS checks as a separate item, not something to assume is included. Confirm availability, eligibility and any extra cost on the pricing page or by contacting the team before you rely on it in your procedures.

Firms comparing options can also read the comparison of Tranche 2 KYC tools.

Keeping a record of the verification

Verifying is only half the job. You also need to be able to show what you did. For each client, keep a record that covers:

• the date and time of the check;
• which method or methods were used and which sources were relied on;
• the result, including any partial matches, failures and how you resolved them;
• the risk rating that drove the choice of method;
• who reviewed the outcome, where a person was involved.

Record-keeping periods and what must be retained are set by the Rules and the AML/CTF Act. Check the current requirements on austrac.gov.au and agree a retention policy with your legal adviser. Handling of identity data also falls under privacy obligations; see our privacy policy and security page for how ScreenlyyID treats data.

Start with the process, then the tool

Before you pick software, write down the answers to these:

1. Which client types do you have, and how do you rate their risk?
2. Which method applies to each tier?
3. What happens when a check fails or is inconclusive?
4. Who reviews exceptions, and how is that recorded?
5. How long do you keep records, and where?

The Tranche 2 compliance checklist places this step within the wider programme. Accounting practices can see how it applies in AML software for accountants; other sector pages are listed under Tranche 2 solutions.

Ready to test it? Sign up for self-serve access and run a check on yourself or a colleague, or review the pricing page first.

Important note

Last reviewed: at publication. This page is general information, not legal advice. AML/CTF requirements and AUSTRAC guidance change, and the Rules referenced here should be read directly. Check current requirements with AUSTRAC or qualified legal counsel before finalising your procedures.