1. The Tax Practitioners Board’s (TPB) Official Guidance

• • The TPB Practice Note TPB(PN) 5/2022 sets out that tax practitioners must “sight” original or certified copies of identity documents—but “sighting” can be achieved electronically if physical in-person verification is not practical.
  • Acceptable methods include review via a secure website, online mailbox, or other secure electronic solution, provided that images are clear and the process allows for a detailed comparison of information and photographs32.

2. Clarifications on Sighting and “Visual Method”

• • The guidelines explicitly state:
    
    “You can use either an original or certified copy of the original documents for identification purposes. When sighting documents, make sure the name, address and date of birth all match the details provided by the client or their representative. You should also check to ensure that the photo in an ID appears to match the details of the client…”3

• • They recommend not to use email as a transmission method for these ID images due to security, instead requiring the use of secure portals or encrypted channels3.

3. Responsibility of Human Review

• • The key point is that a human staff member must “sight” and review the uploaded image, ensuring:
    • Details (name, birthdate, address) match what the client provided,
    • The photo resembles the client (as far as possible),
    • The image is high enough quality to check for authenticity and accuracy32.

4. Not Required to Store Images

• • While reviewing images is compliant, practitioners are not required (and are now discouraged) to store copies of these IDs for privacy and data-breach minimization reasons. Instead, they must record:
    • The type of document sighted,
    • When and how the ID was examined,
    • Who conducted the verification,
    • A note that the documents were clear and legitimate5.
      
      “Instead, you need to record: date and time of verification, type of documents sighted, who did the check, confirmation that documents were clear and legitimate”5.

5. Why This Satisfies the Law

• • The compliance comes from meeting the “minimum requirements for verifying a client’s identity” as set out in Table 2 of TPB(PN) 5/2022 and related ATO/TPB guidance.
  • The ability to use secure uploads and remote sighting acknowledges the modern, web-based service environment for firms like Etax, provided the correct process is followed32.

Summary Table

Conclusion:
Allowing clients to upload images of ID via a secure web portal for staff to visually verify is permitted and compliant, as long as the process allows proper “sighting” and comparison, uses secure channels (not email), and is properly documented according to TPB/ATO standards235.

1. https://www.tpb.gov.au/proof-identity-checks-tax-practitioners
2. https://www.tpb.gov.au/tpb-practice-note-tpbpn-52022-proof-identity-requirements-client-verification
3. https://www.tpb.gov.au/client-verification-process-tax-practitioners
4. https://www.ato.gov.au/tax-and-super-professionals/for-tax-professionals/your-practice/tax-and-bas-agents/agent-client-verification-methods
5. https://seamlss.com.au/news/ato-client-id-verification-process-made-easy/
6. https://argologic.com.au/how-accountants-should-tackle-new-id-verification-requirements-for-clients/
7. https://www.wolterskluwer.com/en-au/expert-insights/mandatory-record-keeping
8. https://www.argentadvisory.com.au/new-identification-requirements-for-all-clients/
9. https://www.tpb.gov.au/faqs-proof-identity-client-verification
10. https://www.tpb.gov.au/time-get-ready-comply-new-code-obligations-1-july