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Identification and due diligence

Individuals and sole traders: which information is needed?

Statutory personal data, additional business details and the distinction between identification and due diligence context.

Redakce eAML.czLegal position: 2026-10-04Editorial check: 2026-10-04

A sole trader remains an individual. Identify the person and add statutory business information. A trade-register extract with a business ID does not replace identity verification, and additional data needs a specific purpose.

Basic statutory scope

Section 5(1)(a) includes all given names and surnames, the birth identification number or, if none was assigned, date of birth and sex, birthplace, permanent or other residence and nationality. It also includes ID-document number and type, issuing state and where applicable authority, and validity. Do not force people without a Czech birth number to invent one.

For business individuals add business name, distinguishing addition or other designation, registered office and business ID. Distinguish personal residence from business address. They need not match, and the difference alone is not a discrepancy.

Documents and verification

Under Section 8, record and verify information from the ID where present and compare appearance with its photograph. The document must meet Section 4(6); a paper bearing a name is not automatically an identity document. Obtain absent information proportionately and record its source.

For further transactions with an identified customer, verify identity appropriately; the statute does not unconditionally require new copies. Where someone else acts for the customer, verify that person’s identity and authority too.

Additional information is not automatically mandatory

Section 5(2) permits telephone, email or employment information where justified by risk assessment. This does not authorise marketing use. Establish whether the purpose is AML, communication or a distinct purpose.

Due diligence may need business activity, service purpose and source of funds. Employment or income questions may be relevant, but explain their connection to the transaction. Do not request an ownership chart for an individual’s “business” where there is only that individual.

Proportionate and secure delivery

Explain requested evidence and the method. In-person identification may use a record and a justified copy where appropriate; methods requiring copies must satisfy their specific conditions. Do not request a complete passport including visas just in case.

Retain statutory data and documents for the applicable period. Secure access and record updates so a changed address or ID does not overwrite identification history.

Practical steps

  1. Identify the person, business and any representative.
  2. Collect statutory data without fictitious birth-number substitutes.
  3. Complete a lawful method and record verification sources.
  4. Add data according to specific purpose and risk.

Illustrative scenario

A sole trader’s business address differs from their home address. Staff distinguish both, verify identity in person and check business details against the relevant register.

When the situation differs

A system identifies a sole trader by business ID alone and fills the birth-number field with zeros because no ID was provided.

What to document

  • Identification record and document or electronic method.
  • Business-data source and address distinctions.
  • Reasons for additional information and change history.

Common pitfalls

  • Treating a business ID as verified personal identity.
  • Demanding a birth number from someone who was never assigned one.

Frequently asked questions

Is date of birth always additional to a birth number?

Section 5(1)(a) makes date of birth and sex the substitute where no birth number was assigned. Further collection needs its own reason.

Must residence and business address match?

No. They serve different functions; record and verify them correctly within the applicable scope.

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

Sources and legal references

  1. Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
    § 4 odst. 6, § 5, § 8, § 9 odst. 3, § 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.