Overview

Legl offers more than one way to verify a client's identity. This guide compares Enhanced CDD (NFC) with Standard CDD, so you can choose the right check for each client and know what to offer when Enhanced CDD (NFC) is not suitable.

ℹ️ Further guidance

For how Enhanced CDD (NFC) works and what it covers, see What is Enhanced CDD (NFC)?.

What this covers

The benefits of Enhanced CDD (NFC).
When Enhanced CDD (NFC) may not be suitable.
Standard CDD as a reliable fallback, and what it offers.
Best practice for client ID checks.

How this works at a high level

Enhanced CDD (NFC) reads the chip embedded in a client's biometric passport or ID card using their phone. It confirms both that the document is valid and that it matches the individual presenting it, providing a high level of assurance.

Standard CDD is browser-based and verifies a client's identity without reading an NFC chip, so it works for clients who cannot complete an NFC check.

When you would use this

Use Enhanced CDD (NFC) when the client has a biometric ID document and a modern phone. It offers the highest level of security and:

Meets HM Land Registry's "Safe Harbour" standards: it aligns with HM Land Registry's Digital ID Standard, which can help protect your firm from liability if fraud occurs despite proper checks.
May reduce insurance premiums: some Professional Indemnity Insurance (PII) providers may lower premiums for firms that adopt secure verification methods, due to the reduced risk of fraud.
Confirms document and identity: it validates the ID document and that it matches the individual presenting it.

Use Standard CDD when Enhanced CDD (NFC) is not an option. Common reasons include:

The client does not have a biometric passport.
The client is using an older smartphone or outdated software.
The client encounters technical difficulties during the process.

Standard CDD offers:

Browser-based access: no app or special device needed.
AML compliant: fully meets anti-money laundering regulations.
GPG 45 and SRA-compatible: a robust check within legal guidelines.
Audit trails: a clear record of identity checks for high-value or complex cases.

The table below summarises when to use each method:

Method	Pros	When to use
Enhanced CDD (NFC)	Highest security, regulatory protection, potential insurance savings	When the client has a biometric ID and a modern phone
Standard CDD	Reliable, accessible, still compliant	When Enhanced CDD (NFC) is not an option

Key things to be aware of

Around 20–30% of clients typically drop off at the NFC stage due to not having a biometric passport, using an older phone, or technical difficulties, so always offer Standard CDD as a fallback.
Avoid paper-based ID checks wherever possible. They introduce more risk and often do not meet regulatory best practice.
Enhanced CDD (NFC) requires the client to have a biometric document and a compatible smartphone.