Identification answers who you are dealing with. Customer due diligence examines the service’s context and risks. Neither an identity document nor a detailed questionnaire alone completes both duties.
Identification includes verification
Section 5 specifies identification data and Section 7 its triggers. In-person identification under Section 8 includes recording data, checking it against the document where included, and comparing appearance. Corporate customers require verification of existence and identification of the person acting for them.
Lawful alternatives have their own conditions. Bank identity under Section 8a differs from an emailed ID copy. Record the method and its completion. Section 8(8) identification also addresses relevant PEP and sanctions matters.
Due diligence assesses substance
Section 9 requires due diligence under specified triggers. Its content includes purpose and intended nature, business activity, beneficial ownership, structure and relevant sanctions links, ongoing monitoring and funds review. A relationship with a PEP also requires proportionate measures to establish the origin of their wealth.
Individuals and corporate customers naturally differ: an individual does not have a corporate ownership chain. Proportionality determines the depth and method of necessary measures; it is not a general permission to omit due diligence.
Read the triggers separately
Basic identification has an exceeding-EUR-1,000 threshold and threshold-independent situations. Due diligence has other values and reasons. A small price cannot postpone identification at relationship commencement, and necessary due diligence must precede the transaction at the latest. Special professional rules may modify the scope.
Simplified identification and due diligence under Section 13 differ from Section 13a statutory exemptions. A low score alone authorises neither. Mandatory Section 9a enhancement requires specific further measures.
One file can record both
Separate forms are unnecessary if the records demonstrate both tasks. Distinguish “customer stated”, “verified using source” and “assessment”. Note irrelevant questions with reasons and outstanding evidence.
Where identification or due diligence cannot be completed and Section 15 applies, refuse the transaction or follow the conditions for ending the relationship. Promised later evidence does not override a prohibition where prerequisites remain unmet.
Practical steps
- Identify separate identification and due diligence triggers.
- Complete a lawful identification method.
- Assess required due diligence elements in the service context.
- Retain sources, scope reasoning and the decision.
Illustrative scenario
An accountant identifies the managing director in person, then verifies the company and owner, understands the service purpose and business, assesses funds and sets monitoring.
When the situation differs
A customer sends a completed questionnaire with an ID number, but the practice performs no lawful identification method or assessment.
What to document
- Identification method, time and performer.
- Customer answers, verification sources and substantive assessment.
- Proportionality, escalation and decision reasons.
Common pitfalls
- Equating due diligence with an ID copy.
- Presenting a filled questionnaire as verified information.
Frequently asked questions
May I use one form?
Yes, if it distinguishes necessary measures and evidence. The form’s name or number does not prove compliance.
Does every identification require due diligence?
Triggers differ. Examine Section 9 for the case, including relationships, suspicion, value and special rules.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
Complete client information online
Where to go next
- New customers: from initial information to documented due diligence — A practical onboarding timeline from the legal trigger through verification, decision and records.
- Remote identification: lawful options and their conditions — BankID, document copies with a verification payment, qualified signatures and reliance are distinct methods.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 5, § 7–9a, § 13, § 15–16 · accessed 2026-10-04
Editorial work and source checks are not independent legal approval of your particular process. Compare the conditions and exceptions with your own circumstances.