AML / FATCA / CRS Customer Identification Forms
AML / FATCA / CRS Customer Identification Forms
Updated: 6 May 2026
The FSC and FAAA have released updated customer identification forms to support AFS licensees, financial advisers and product providers in meeting their AML/CTF customer due diligence obligations.
These forms are designed to help standardise customer identification processes across the industry and support compliance with:
• The AML/CTF reforms commencing 31 March 2026, and
• Existing Applicable Customer Identification Procedures (ACIP) under the transitional arrangements
While the forms do not constitute legal advice, they are intended to support consistent interpretation and practical implementation of customer identification requirements across both the new and transitional frameworks.
The 2026 versions replace the previous 2017 editions and are provided free of charge to FSC members. Non-members who wish to access the forms are encouraged to contact the FSC at membership@fsc.org.au to discuss access arrangements.
Transitional Arrangements
The AML/CTF reforms commencing 31 March 2026 introduce significant changes for AUSTRAC reporting entities.
To support implementation, the Government has provided a three-year transitional period for the Initial Customer Due Diligence (ICDD) requirements. During this time, eligible entities may continue to apply existing ACIP processes until their systems are updated to meet the new requirements.
Entities relying on this transitional relief must have documented transition plans in place by 1 July 2026, including:
• The customer classes to which ACIP will continue to apply
• Planned transition timelines for each customer class
The updated FSC/FAAA forms have been designed to support both the new ICDD framework and existing ACIP requirements during this transition period.
Handling Copies of Identification Documents
The Office of the Australian Information Officer (OAIC) has issued new Privacy guidance for reporting entities under the AML/CTF Act.
During the transition period, OAIC will apply a principles-based “reasonable steps” approach to the destruction or de-identification of personal information, including copies of identification documents, once they are no longer required.
Entities are expected to maintain a documented plan outlining their approach to compliance.
The updated FSC/FAAA forms capture key identification details (including document type, number and expiry date) and support compliance with both ACIP and ICDD frameworks. Where entities continue to operate under ACIP during the transition period, copies of identification documents may be retained in addition to completing the updated forms.
Record Keeping Requirements
All copies of client identification collected prior to 31 March 2026 must continue to be stored securely and retained for seven years from the date the client relationship ends, in accordance with AML/CTF record-keeping obligations.
Guidance Note Update
The FSC and FAAA are currently updating Guidance Note 24 to further support members in understanding AML/CTF customer due diligence requirements and the use of these updated forms.