Not every client fits a standard app-based ID check. Here’s how to onboard the ones who don’t — with flexible, documented routes to the same verified outcome.
Quick answer
Not every client fits a standard digital onboarding flow — and forcing them to is both a compliance risk and a way to lose good business. Vulnerable clients, overseas clients with foreign documents, people with no standard UK ID, and the digitally excluded all need alternative, well-documented routes to the same outcome: verified identity and sound due diligence. The key is a flexible journey that can flex to the client without lowering the standard of the check.
Most onboarding advice assumes a straightforward client: a UK resident with a passport, a smartphone, and the confidence to take a selfie for a liveness check. But real client bases don’t look like that. What happens when the client is 84 and doesn’t own a smartphone? When they’re an overseas buyer with documents your system doesn’t recognise? When they have no passport and no driving licence at all? These aren’t rare edge cases — every firm meets them, and almost nobody writes practical guidance on handling them well.
Important: onboarding a difficult client means finding a compliant route to the same standard of verification — never lowering the standard. If you cannot satisfy your due-diligence obligations by any route, the correct answer may be not to proceed. Always follow your own firm’s policies and your supervisor’s guidance.
1. Vulnerable clients
Vulnerability takes many forms — age, ill health, cognitive impairment, bereavement, language barriers, or simply low digital confidence. A rigid, app-only flow can exclude these clients entirely, or push them into sharing credentials with a relative in ways that create their own risks.
How to handle it well
- Offer assisted routes — verification that can be completed with help, in person, or with more time, without abandoning the audit trail.
- Allow alternative evidence where a biometric selfie isn’t feasible, in line with your policies.
- Watch for third-party pressure — a relative “helping” can sometimes be a red flag, so record who was involved.
- Document the adjustment and the reason, so the file shows a considered, compliant decision.
2. Overseas clients with foreign documents
An overseas client may present documents your standard checks don’t recognise, from a jurisdiction with different ID norms and — sometimes — weaker transparency. Foreign documentation is harder to authenticate, and higher-risk jurisdictions may trigger enhanced due diligence.
How to handle it well
- Use verification that supports international documents — many document types across many countries, rather than UK-only checks.
- Apply enhanced due diligence where the jurisdiction or circumstances require it.
- Corroborate with independent sources where a document alone isn’t enough.
- Understand what’s available in that jurisdiction — knowing which records exist is half the battle.
3. Clients with no standard UK ID
A surprising number of people have neither a passport nor a driving licence — younger people, older people, those who don’t drive or travel. Building onboarding that only accepts those two documents quietly excludes them.
How to handle it well
- Accept a wider evidence set where your risk approach allows — for example other government-issued or trusted documents.
- Consider electronic verification against trusted data sources that don’t rely on a single physical document.
- Have a documented exceptions route so staff aren’t improvising case by case.
4. The digitally excluded
Some clients can’t or won’t complete a digital journey — no smartphone, poor connectivity, or low digital literacy. Digital exclusion is a real and sizeable issue, and an onboarding process with no non-digital fallback simply loses these clients.
How to handle it well
- Provide an assisted or in-person fallback that still feeds the same structured record.
- Keep the audit trail consistent across digital and non-digital routes.
- Don’t treat the fallback as second-class — it should meet the same standard, just by a different path.
A caution that applies to all four
Flexibility must never become a loophole. An assisted or alternative route should reach the same verification standard as the standard flow — and where a client is evasive, or you genuinely cannot verify them by any route, that itself is a risk indicator to act on, not a reason to lower the bar.
Add expert quote before publishing
“The instinct with a client who doesn’t fit the system is to bend the check. The better instinct is to bend the journey. A good onboarding process has more than one road to the same destination — verified identity, sound due diligence, a clean audit trail — so you don’t have to choose between compliance and serving a real client.”
— Suggested placeholder for a quote from Osman Ismail (founder input, OnBoardNow / DPS Software). Replace with a real, approved quote, or remove.
Why this is a ‘More Than ID’ problem
Every one of these cases makes the same point: onboarding can’t be a single, rigid ID gate. It has to be a journey that can flex — different routes to the same verified outcome, each fully documented. A one-size-fits-all identity check either excludes clients you could safely serve, or tempts staff to cut corners. A configurable journey does neither.
Key takeaway
Difficult clients don’t call for a weaker check — they call for a more flexible journey. Build documented alternative routes (assisted, international, non-standard-ID, non-digital) that all reach the same standard, and record the adjustment every time. That’s how you serve real clients without compromising compliance.
Onboarding that flexes to real clients
OnBoardNow supports international documents, assisted routes and alternative evidence within one configurable journey — so you can onboard vulnerable, overseas and non-standard clients to the same standard, with a full audit trail. Book a demo.Book a demo →
Frequently asked questions
How do you onboard a client who can’t do a digital ID check?
Offer a documented assisted or in-person route that reaches the same verification standard and feeds the same structured record — never simply skip the check. Record the adjustment and the reason.
Can you onboard a client with no passport or driving licence?
Often yes, using a wider set of accepted documents or electronic verification against trusted data, in line with your risk policies. Have a documented exceptions route rather than improvising.
How should firms handle overseas clients?
Use verification that supports international documents, apply enhanced due diligence where the jurisdiction warrants it, corroborate with independent sources, and understand what records are available in that jurisdiction.
Does being flexible mean lowering compliance standards?
No. Flexibility is about offering different routes to the same standard. If a client can’t be verified by any route, or is evasive, that’s a risk indicator to act on — not a reason to lower the bar.
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