- 18 Nov 2026 UK Have your directors and PSCs verified with Companies House?
- 1 Dec 2026 AU Will your onboarding accept private-sector Digital IDs?
- 10 Dec 2026 AU Does your privacy policy explain your automated KYC decisions?
- End 2026 EU Is your ID verification ready for EUDI Wallets?
- 1 Jan 2027 US Can your age checks keep up state by state?
- 1 Apr 2027 JP Is your eKYC ready for the IC-chip mandate?
- 10 Jul 2027 EU Is your CDD flow ready for the AMLR?
- 1 Jan 2028 US Are your adviser clients ready for FinCEN’s AML rule?
- 31 Mar 2029 AU Is your initial CDD on the new AUSTRAC model?
- Now AU Tranche 2 is live. Is your AML/CTF program running?
The Verification of Identity Standard: what ARNECC's rules require
Every e-conveyancing Subscriber must take reasonable steps to verify who it is acting for. The Verification of Identity Standard in the Model Participation Rules is the method that is deemed to meet that duty.
- Rule 6.5 of ARNECC's Model Participation Rules requires a Subscriber to take reasonable steps to verify the identity of its clients, mortgagors in some cases, and its own signers and users.
- A Subscriber can apply the Verification of Identity Standard in Schedule 8, or verify identity another way that amounts to reasonable steps; following the Standard is deemed to be reasonable steps.
- The Standard requires a face-to-face in-person interview, original documents from a ranked set of categories, and copies of all documents produced.
- Evidence supporting verification of identity must be kept for at least seven years from lodgment.
- Version 7 of the Model Participation Rules is still listed as current. ARNECC published a Version 8 consultation draft on 25 May 2026, and no adoption has been announced.
What it is
The Australian Registrars' National Electronic Conveyancing Council (ARNECC) writes the Model Participation Rules. Under section 23 of the Electronic Conveyancing National Law, each State and Territory Registrar determines its own Participation Rules, which bind Subscribers to an electronic lodgment network such as PEXA. The model is the basis for each jurisdiction's version.
The Verification of Identity Standard sits in Schedule 8. Rule 6.5.2 lets a Subscriber either apply the Standard or verify identity in some other way that constitutes the taking of reasonable steps. Rule 6.5.6 says that following the Standard is deemed to be reasonable steps. That deemed compliance is why most firms follow it closely.
This page covers the rules and their status. For a practical walk through documents and checks, see our VOI requirements guide.
Who it applies to
The duty sits with the Subscriber, the person or firm registered to transact in an electronic lodgment network, and with mortgagees represented by a Subscriber.
- Conveyancers and lawyers acting for buyers, sellers and other clients
- Lenders and other mortgagees verifying mortgagors
- Firms providing paper certificates of title to clients or mortgagors
- Each Subscriber's own signers, administrators and users before they get access
- Identity Agents who do the check for a Subscriber or mortgagee
Conveyancers and lawyers became reporting entities under the AML/CTF Act for certain services on 1 July 2026. That brings a separate customer due diligence duty under Tranche 2. One check can collect evidence for both, but each regime has its own test.
What you have to do
These duties come from Rules 6.4 to 6.6 and Schedule 8 of Model Participation Rules Version 7. Check your own jurisdiction's Participation Rules for any local differences.
- Verify each client or client agent
Take reasonable steps to verify the identity of each client or each of their agents. If you use the Standard, this means a face-to-face in-person interview where the person produces original documents and you check that they are a reasonable likeness to the photos.
- Verify mortgagors where required
Where you are the mortgagee, verify each mortgagor. Where you represent the mortgagee, you can rely on the mortgagee's verification if you are reasonably satisfied it took reasonable steps.
- Confirm the right to deal and client authorisation
Take reasonable steps to verify that your client is a legal person with the right to enter into the conveyancing transaction, and that any client authorisation is properly signed.
- Take further steps when something looks wrong
Rule 6.5.3 requires further steps where you know or ought reasonably to know that a document is not genuine, a photo is not a reasonable likeness, or the person does not appear to be who the documents describe.
- Direct and document any Identity Agent
If you use an Identity Agent under the Standard, you must direct them to use it, and receive certified copies of the documents produced plus an Identity Agent Certification.
Outsourcing - Verify your own signers and users
Verify each signer before a digital certificate is first allocated, each Subscriber Administrator before appointment, and each other user before they get access to the network.
- Keep the evidence for seven years
Rule 6.6 requires you to retain evidence supporting verification of identity, client authorisations and the right to deal for at least seven years from the date of lodgment.
Record keeping
What firms get wrong
The Standard is precise, and small departures change your legal position.
Rule 6.5.2 allows another method if it amounts to reasonable steps. The difference is proof: the Standard gives deemed compliance, while any other method has to stand on its own if a fraud is later questioned.
Schedule 8 says the verification must be conducted during a face-to-face in-person interview. A remote check can still form part of reasonable steps, but it does not carry the Standard's deemed compliance.
The Standard ranks document categories, starting with Category 1 (a passport or ImmiCard plus an Australian driver licence or Photo Card). You must be reasonably satisfied a higher category cannot be met before using a lower one, and documents must be current, except an uncancelled Australian passport that expired within the last two years.
As at 5 November 2026, ARNECC lists Version 7 as the current Model Participation Rules. Version 8 is a consultation draft, and each Registrar must determine any new version before it takes effect in that jurisdiction.
What happens when
- Proposed
ARNECC publishes the Model Participation Rules Version 8 consultation draft and explanatory notes Source
- Proposed
ARNECC stakeholder briefing on the Version 8 Participation Rules draft Source
- In force
Conveyancers and lawyers become AML/CTF reporting entities for certain services, adding CDD alongside VOI Source
- Not yet setProposed
Version 8 of the Model Participation Rules adopted by Registrars (explanatory notes anticipated October 2026; no adoption announced) Source
Not yet confirmed. We will update this when the date is set.
Related guides
Questions people ask
What is the Verification of Identity Standard?
It is Schedule 8 of ARNECC's Model Participation Rules. It sets out a face-to-face interview, ranked categories of original identity documents, an identifier declaration process when documents are missing, and evidence retention. Following it is deemed to be the reasonable steps that Rule 6.5 requires.
Is the VOI Standard mandatory?
The duty to take reasonable steps is mandatory. Using the Standard is the way to get deemed compliance; another method is allowed if it amounts to reasonable steps on its own.
What documents are needed for verification of identity?
Category 1 is a passport or ImmiCard plus an Australian driver licence or Photo Card, plus a change of name or marriage certificate if needed. Lower categories add birth or citizenship certificates and Medicare, Centrelink or DVA cards. Category 6 covers people who are not Australian citizens or residents. See our VOI requirements guide.
Do I need to verify a returning client again?
Not always. Rule 6.5.4 says you need not re-verify a person you verified within the previous two years, if you take reasonable steps to make sure you are dealing with the same person. Version 8 proposes clearer drafting of this exemption.
What does Version 8 change?
The consultation draft proposes, among other things, excluding a client's in-house conveyancers or lawyers from acting as Identity Agents, making clear that an Identity Agent must be directed to use the Standard, requiring multi-factor authentication in some cases, and minor drafting changes to Schedule 8. It is not yet in force.
Does AML/CTF customer due diligence replace VOI?
No. They are separate duties under separate laws. A conveyancer providing designated services must meet both. Our conveyancer AML/CTF guide explains the AML side.
Primary sources
Checked 5 Nov 2026. We review this page every 90 days and when the rules change.
- ARNECC, Model Participation Rules (publications, Version 7 current)
- ARNECC, Model Participation Rules Version 7 (January 2024), Rules 6.4 to 6.6 and Schedule 8
- ARNECC, Model Participation Rules consultation (Version 8 draft, 25 May 2026)
- ARNECC, Model Participation Rules Version 8 Consultation Draft explanatory notes
- ARNECC, News (Version 8 stakeholder briefings)
- AUSTRAC, About the reforms
Where StackGo fits
IdentityCheck runs a remote biometric check. That is not the face-to-face interview the Standard describes, so it does not give the Standard's deemed compliance on its own. A firm can use it as one part of its own reasonable steps, and for the AML/CTF customer due diligence that conveyancers and lawyers now owe. Whether a remote check is enough for a given matter is the firm's call.
- Biometric identity checks: a photo of a government ID document plus a live selfie with liveness, covering 12,500 document types from 230+ countries and territories
- DVS government document verification as an Australian add-on
- Onboarding forms, including multi-entity forms that collect each person and entity on a structure
- PEP, sanctions and adverse media screening for the AML/CTF side, with ongoing monitoring of screened clients
- Links to Xero Practice Manager, Xero, Karbon and HubSpot, where by default the connected system gets a link to the result plus the outcome and status, with no personal details written back
- It does not conduct a face-to-face in-person interview or act as an Identity Agent
- It does not issue an Identity Agent Certification or certified copies of documents
- It does not lodge documents in an electronic lodgment network
- It does not give legal advice on whether your method meets the Participation Rules in your jurisdiction
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