Onboarding starts by identifying the service and customer, proceeds through lawful identification and necessary due diligence and ends with a documented decision. Collect information for the chosen procedure instead of sending an unrelated universal document package.
Determine the regime before collecting data
Check that the service falls within your Section 2 category. Distinguish relationships from occasional transactions, value and other triggers, and specify the completion point. A low monthly fee for continuing registered-office services does not justify waiting.
Identify the contractual customer, its representative and other relevant persons. For a company, the director’s ID copy alone is insufficient: establish the company, its existence and representation rules.
Choose a method and collect securely
Explain purpose, scope and secure delivery. Choose in-person identification or a specific lawful alternative. BankID does not require the same documents and payment as Section 11(7); do not combine incomplete pieces of different methods.
Record when and how information was verified. Establish the representative’s authority within the needed scope. Separate customer declarations from your proportionate PEP and sanctions findings.
Assess the actual service
Establish purpose, business nature and expected activity. For companies and trusts examine beneficial ownership and structure; where registration is required, verify ownership against at least the register and one other source. Review funds related to the case.
Assess risks together: unexplained purpose, opaque structure or third-party financing may change the required depth. A low score cannot remove statutory enhancement reasons. Translate uncertainty into specific questions and evidence requests.
Decide and manage the continuing customer
Before the relevant act, classify the case as completed, requiring information, refused or escalated. Do not execute where Section 15 conditions apply; escalation alone is not permission to proceed. Handle suspicion separately under the statutory procedure.
For accepted customers, retain reasons and sources and set risk-based updates. Changes to representatives, ownership, service or financing may require earlier checks. Your own archive must include the full verification trail, not merely the latest questionnaire.
Practical steps
- Define the customer, service, relationship and trigger.
- Complete lawful identification and representative-authority checks.
- Obtain and assess purpose, ownership, structure and funds.
- Resolve contradictions, decide and create a complete file.
- Set ongoing updates and secure retention.
Illustrative scenario
A new importer requests a registered office. The practice verifies the company, representative, ownership chain, address purpose and financing, and waits for evidence resolving conflicting registers.
When the situation differs
The service starts once the invoice is paid and the practice only seeks identification documents afterwards. Payment did not create an exemption.
What to document
- Timeline and completed-measure list.
- Documents and assessments including contradictions.
- Decision and future-check triggers.
Common pitfalls
- Accepting a customer while essential conditions remain unmet.
- Making every field mandatory regardless of customer or method.
Frequently asked questions
Can customers send details before a meeting?
Yes. Prefilling helps, but verification still requires completing the chosen statutory method.
Must everything be repeated for every invoice?
Not automatically. Keep information current, verify identity appropriately for subsequent transactions and monitor changes in risk.
Put this guidance into practice
Choose a record for the step you are working on. Adapt it to your profession and actual case.
- New bookkeeping client checklist · PDF / Word
- External accountants →
- Real estate intermediaries →
- Lawyers and notaries →
Complete client information online
Where to go next
- Remote identification: lawful options and their conditions — BankID, document copies with a verification payment, qualified signatures and reliance are distinct methods.
- Legal entities and their representatives — Four separate checks: company existence, personal identity, representation authority and beneficial ownership.
Sources and legal references
- Zákon č. 253/2008 Sb. — aktuální znění e-Sbírky ↗
§ 2, § 7–9a, § 13, § 15–16 · accessed 2026-10-04 - Zákon č. 37/2021 Sb. — aktuální znění e-Sbírky ↗
§ 2, § 4–10, § 12, § 16–17 · 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.