A missing document is not the end of the inquiry
Some individuals cannot obtain the information normally requested to establish identity. Others cannot access it because of circumstances beyond their control. Rules 6-10 provides a specific route for these situations. It is not a general permission to skip identity work whenever a document is inconvenient to obtain.
The provision requires reasonable steps to establish that the person is who they claim to be. When the person is the customer, further conditions concern identifying risk, collecting appropriate KYC information and taking reasonable verification steps using reasonably available data. The business must also have policies for additional risk from missing information.
- Missing information
Record why the normal information is unavailable.
- Available evidence
Consider reliable information reasonably available in the circumstances.
- Identity and risk
Apply the relevant Rules 6-10 conditions and assess additional risk.
- Conclusion or escalation
Explain what the evidence establishes and resolve remaining gaps.
Assess an alternative identity route
Missing standard ID is not permission to skip identity checks. No single alternative document combination works for every case.
Follow the process from top to bottom.
Use the actual conditions
Apply the provision to the individual's circumstances, not to a broad assumption about a group of people. Missing standard ID does not itself prove dishonesty. Equally, the business still needs a sufficient basis for the identity conclusion and the other initial CDD matters relevant to the case.
The Rules do not make one alternative document suitable for every person or service. Consider what the available information can establish and what remains uncertain. Record why the normal evidence is unavailable and how the alternative process addresses the specific gap. Avoid collecting unrelated personal history merely because the standard route failed.
Worked example: inaccessible documents
A fictional customer explains that important identity documents are inaccessible after an emergency. The business identifies which information is missing and considers what reliable information is reasonably available. It uses its alternative process and assesses any additional risk rather than recording a false successful standard check.
This example does not prescribe a particular document combination or guarantee an outcome. It shows the sequence of questions: why evidence is unavailable, what other information exists, what it establishes and what controls are needed. The business should not confuse a compassionate response with an unsupported identity conclusion.
Make the decision understandable
A practical note should allow a reviewer to distinguish the normal method from the alternative method used. State the relevant circumstance and the evidence considered without adding unnecessary sensitive detail. Explain the conclusion and any remaining limitations in plain language.
If the alternative evidence cannot establish the necessary matters, do not describe the case as complete simply because the customer has a good reason for missing documents. Escalate the unresolved issue through the business's process. This page explains the statutory route; it does not replace specialist guidance on individual circumstances or any other applicable legal requirement. Fair treatment and adequate evidence can be considered together.