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HMRC internal manual

Construction Industry Scheme Reform Manual

Register and maintain subcontractor: the registration process: identification documents

CISR42600 Action guide contents


You need to be sure that the person presenting themselves is who they say they are. This is why the applicant needs to bring at least two identifying documents for an identification check, one of which should be the applicant’s passport and one document should include the applicant’s current address.. You need to be satisfied about the adequacy of the identity documents being presented to you, and you should not register the person unless you are satisfied. If necessary ask the applicant to supply further evidence.

It is preferable that the address shown on one of the identifying documents should match that on the applicant’s application form or Self-Assessment (SA) record.

Remember that a subcontractor may be working away from home for an extended period and may want correspondence concerning their application to be sent somewhere other than their permanent address.

You will be able to check the address against that on the application form and if that matches then the identifying document is satisfactory.

Acceptable documents

Remember you are merely trying to confirm that the person making the application is who they purport to be. The following are examples of original documents you can accept. This list is not exhaustive.

* The Applicant’s birth certificate
* Current passport (UK or foreign)
* Citizen Card
* National Health Service Card
* National Savings or Building Society passbook
* Current Local Authority or Housing Association rent book (not from a private landlord)
* Bank or credit card statements dated within the last three months
* UK residence permit
* Life assurance/insurance policies
* Mortgage repayment documents
* Divorce/annulment papers
* Cheque book
* Cheque guarantee card or store/credit card
* Driving Licence (UK or foreign)
* Utility bills issued in the last three months in the applicant’s name
* Council Tax bill


The documents presented to you should be the original documents. You should only accept photocopies where there is a valid reason for the applicant not to produce the originals.

If you have any concerns regarding the documentation presented you should consult a Higher Officer for guidance.

Bogus identifying documents

You should be on the look out for bogus identity check documents. Where you have any doubt about the documents presented, you should not accept them and ask the applicant to provide other documentation.

You should not, however, seize or retain any documents presented to you that you believe to be false. We generally have no legal right to take such documents from applicants in this way and to do so may leave the Department open to legal action in certain cases.

Recording the forms of identity produced

You should record, in the appropriate box on the application form, the forms of identity provided by the subcontractor and shown to you. You also need to complete the ‘Register Subcontractor’ ‘ID Check’ window with details of the documentation that has been provided. Please note that only 1 line is provided to input details of ‘other’ documents. You may therefore, need to use abbreviations to enable you to input the necessary information.

If you are not satisfied with the documents produced you should explain to the applicant that they will not be able to register for CIS until adequate proof of identity is provided.

Photocopied documents

Photocopies of original documents should not normally be used to establish identity and you should only accept photocopies when there is a valid reason for the applicant not to present the originals.

For example, there is unlikely to be a valid reason why an applicant should produce photocopies of utility bills in preference to the original documents themselves. You should ask yourself why someone would go to the trouble of photocopying their utility bill when it must be easier to produce the original documents. It may be that the applicant never had the original bills and was given/sold the photocopies by someone else. In all cases you should insist on seeing the original documents for all utility bills and any other letters or forms that may be presented to you where no valid, acceptable explanation is offered as to where the originals are.

An exception to this rule may be in relation to an applicant’s passport that has been retained by the Home Office in connection with the applicant’s application for asylum or residency in the UK. However, in all cases where the Home Office retains an applicant’s passport for these purposes, the applicant is given a photocopy of their passport that has been officially endorsed with a Home Office stamp. If you are presented with one of these documents, check to see if the official stamp has been imprinted on to the photocopy itself - which is OK. If the stamp was imprinted before the document was photocopied you should ask to see the actual document given to the applicant by the Home Office.

Foreign documents

If you are presented with one or more foreign documents in support of an applicant’s identity, you should normally accept these where you are able to read them and are reasonably content as to their provenance. For example, if you are presented with a passport, national ID card or driving licence that bears the applicant’s details and, quite often, their photograph, you may accept this if you are reasonably content that you know what it is and that it was issued to the applicant.

On the other hand if you are presented with a document that you cannot understand, or you have reason to believe that it is not an officially issued document from the applicant’s home country, you should refuse to accept it. In such cases, the applicant should be advised to return with something more suitable. You will need to apply your judgement here and should not refuse to accept a particular document simply because you have not seen one like it before. If it looks official, perhaps because it bears an official crest and the applicant’s photograph, then generally you can accept it. If in doubt, see CISR97010 about contacting the CIS Business Helpdesk.

Miscellaneous and unacceptable documents

Quite often you will be presented with documentation in support of an applicant’s identity that is simply unacceptable. Photocopies of utility bills and other documents are generally unacceptable, as described above.

Bus or Train season tickets are also unacceptable forms of identity as are any other documents that may have been issued without the applicant having been required to satisfy the issuer as to their identity.

You should never accept a self-addressed envelope or personal letter as identification. However, if presented with a letter on the headed paper of a hotel which shows the address that the applicant is currently using, you may have to accept this as proof of that address where the applicant clearly has no other suitable documentation.

Nationality and the right to work in the UK

You should not, under any circumstances, become involved in any issues surrounding

  • nationality
  • right of entry to the UK, or
  • right to work in the UK.

We have no authority to ask questions about these matters which are for the Home Office to determine.

Further help

If you need any further guidance on which identity documents you may or may not accept, you should ring the CIS Business helpdesk. See CISR97010 for the helpdesk telephone number.