What is secondary identification?
Secondary identification consists of supporting documents that can help verify a person’s identity but can’t establish identity independently. Unlike primary identification documents such as passports or driver's licences, secondary identification serves a supplementary role in the verification process.
Some examples of secondary ID documents include utility bills, bank statements, student IDs, social security cards, and health insurance cards. All of these can provide additional confirmation of an individual's personal information, though they may be less reliable or comprehensive than primary identification documents.
Secondary identification helps financial institutions build a more complete picture of a customer’s identity, and it may be required to meet certain regulatory requirements. The distinction between primary and secondary identification is crucial for regulatory compliance and risk management, as each serves different verification purposes.
The purpose of secondary identification
Secondary identification serves several important functions in identity verification, though its validity and utility can vary depending on the industry, institution, and regulatory environment. Secondary identification may be used for the following situations:
Address verification
Address verification represents one of the most common uses for secondary identification documents. Utility bills, bank statements, and official correspondence can provide proof of address and proof of residence. This supports anti-money laundering (AML) efforts and helps detect potential fraud.
Additional data validation
Secondary ID documents make it possible for institutions to cross-reference data provided during customer onboarding. When customers submit multiple documents containing consistent personal information, it increases confidence in the accuracy of the provided data and reduces the likelihood of identity fraud.
Regulatory compliance
In some jurisdictions, regulatory compliance demands secondary documents that go beyond primary identification.
Yessica Correa, Daily Operations Analyst at Fourthline, provides an example: "Currently, Fourthline requires a secondary document to comply with Italian local regulations, since they ask for validation of the tax number," she notes. While this may change in the future, the example illustrates how specific regulatory requirements can mandate additional documentation.
Risk-based verification
Some customer categories may trigger secondary identification requirements. Higher-risk customers or those seeking access to enhanced services, for example, may need to provide secondary documents as part of Enhanced Due Diligence (EDD) procedures.
Common types of secondary identification
Secondary identification documents span various categories, each of which serves a specific verification purpose and carries a different level of reliability.
Financial documents
Financial documents offer strong secondary identification because they typically require prior identity verification to obtain. Bank statements are generally seen as especially reliable, because banks verify their customers’ identity before issuing statements. Credit card statements, loan documents, and investment account statements can also be used to demonstrate established financial relationships.
Utility bills
Utility bills are widely used to establish proof of address. Electricity, gas, water, telephone, and internet bills typically display customer names and service addresses. These documents are particularly useful and not especially hard to come by, as most adults use some form of utility service.
Government cards and correspondence
Government-issued cards and correspondence provide reliable secondary identification, though they may fall short of primary identification status. Social security cards, health insurance cards, and tax documents contain official information, but may lack the comprehensive identity proof required for primary identification.
Proof of education or employment
Educational and employment documents may serve as secondary identification in certain contexts. Student IDs and employment verification letters can provide institutional backing for identity claims, though their acceptance varies significantly between organisations and use cases.
When is secondary identification required?
The requirements for secondary identification vary based on risk assessment, regulatory environment, and institutional policies.
Risk-based requirements determine when secondary identification becomes necessary. "ID verification requirements often vary based on the customer's risk level or the type of account being opened," explains Correa. Low-risk accounts may require only primary identification, whilst medium- and high-risk scenarios often mandate secondary documentation.
Regulatory mandates in specific jurisdictions require secondary identification, regardless of the risk level. These requirements reflect local regulatory frameworks that mandate additional verification beyond primary government-issued documents.
Enhanced Due Diligence (EDD) procedures for high-value customers, politically exposed persons (PEPs), or complex business relationships typically require secondary identification as part of a comprehensive verification process.
Incomplete primary verification also may trigger secondary identification requirements — especially when primary documents raise questions or cannot be fully verified through standard processes.
How digital verification has changed the need for secondary identification
Though secondary identification documents have played an important role in identity verification up until now, modern digital verification technologies have significantly reduced reliance on secondary identification — mainly by enhancing primary document verification capabilities. Here are some processes at the heart of this change:
Advanced document authentication enables more thorough verification of primary identification documents, reducing the need for secondary documentation to build confidence in customer identity.
Database integration allows for real-time verification of primary documents against government databases, providing immediate confirmation that previously required secondary document support.
Biometric verification creates direct connections between individuals and their primary identification documents, which reduces reliance on secondary documents for confirmation.
Despite these advances, secondary identification remains important for some specific regulatory requirements and EDD procedures.
Implementation considerations
Financial institutions must carefully balance secondary identification requirements with customer experience and operational efficiency.
Clear policies should define when secondary identification is required, which documents are acceptable, and how they integrate with primary verification processes. These policies must account for regulatory requirements whilst maintaining reasonable customer expectations.
Regular staff training helps to ensure that secondary identification requirements are applied with consistency. It can also help teams understand when additional documentation is strictly necessary versus optional.
Most modern identity verification providers, including Fourthline, have streamlined verification processes to minimise secondary identification requirements whilst maintaining regulatory compliance. Nevertheless, secondary identification continues to serve important regulatory and risk-management functions in some contexts.
Secondary identification FAQs
When is secondary identification typically required?
Secondary identification is usually required for Enhanced Due Diligence (EDD) procedures, specific regulatory compliance (such as address verification), higher-risk customer categories, or when additional validation is needed beyond primary identification. Requirements may vary by jurisdiction and institution.
Can digital copies of secondary identification be used?
It depends on the specific institutional policies and regulatory requirements. Some organisations accept digital copies of utility bills or bank statements, whilst others require original documents. Most organisations and jurisdictions are trending toward digital acceptance, but specific requirements continue to vary by use case and risk level.
What should I do if I don't have secondary identification documents?
If you need to verify your identity, but don’t have any secondary documents, some alternative verification methods may include bank statements, employment verification letters, government correspondence, or digital verification through trusted third-party services. Many modern verification systems have reduced secondary identification requirements, focusing mainly on robust primary document verification.
This article incorporates insights from Yessica Correa, a Daily Operations Analyst at Fourthline. It is for informational purposes only and does not constitute legal advice.
