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Onboarding · 8 min read

Certified true copies explained: who can certify and what the wording should say

A certified copy is a photocopy that someone accountable has compared with the original and signed. It sounds simple, yet poorly certified copies are one of the most common reasons an onboarding file is sent back.

What "certified true copy" actually means

When a payments provider asks for a certified true copy, it wants a copy of a document that carries a statement from an independent, identifiable professional confirming two things: that they have seen the original, and that the copy is a complete and accurate reproduction of it.

The certification transfers some of the verification work from the provider to the certifier. The analyst reviewing your file has never met you or held your passport. The certifier has. By signing, the certifier puts their professional standing behind the claim that the original exists and matches what has been sent.

That is why the identity and qualifications of the certifier matter as much as the stamp. A certification is only as useful as the provider's ability to confirm who made it and to contact them if needed.

A certified copy is different from a notarised document, an apostilled document or an original issued by a registry. Those are separate concepts with their own uses, and our guide to translations, apostilles and legalisation explains how they fit together.

Who can certify a document

There is no single global list. Each provider sets its own policy, usually reflecting guidance from its regulator and the practice of its banking partners. In general, providers accept certification by people in regulated professions with a public register that can be checked. Commonly accepted certifiers include:

  • Lawyers, solicitors, barristers and attorneys who hold a current practising certificate.
  • Notaries public.
  • Chartered or certified accountants who are members of a recognised professional body.
  • Commissioners for oaths or justices of the peace, in jurisdictions where those offices exist.
  • Officers of a regulated bank or other regulated financial institution.
  • Embassy, consulate or high commission officials.
  • Directors or senior staff of a licensed corporate service provider or registered agent, particularly for corporate documents they administer.

People who are usually not acceptable include family members, business partners, fellow directors of the applicant company, employees of the applicant, and anyone who is themselves a party to the structure. Independence is the point. A director certifying their own passport, or a shareholder certifying the company's register, adds nothing.

Some providers also restrict certifiers by location, for example preferring certifiers in countries with comparable anti-money laundering standards. If your adviser is based somewhere unusual, check before paying for the work.

The wording certifiers should use

The wording does not need to be elaborate, but it needs to be complete. A sound certification on a passport copy would say something close to:

"I certify that this is a true and complete copy of the original document, which I have seen, and that the photograph is a true likeness of the holder, whom I have met in person."

Alongside the statement, the certifier should add:

  • Their full name, printed clearly.
  • Their profession or capacity, for example "Solicitor" or "Chartered Accountant".
  • Their professional registration or membership number, where one exists.
  • Their firm name, business address, telephone number and email address.
  • Their signature and the date of certification.
  • An official stamp or seal, if they use one.

For non-photographic documents, such as a utility bill or a certificate of incumbency, the likeness wording is dropped, but the "true and complete copy of the original, which I have seen" statement remains.

For multi-page documents, the certifier should either sign or initial every page, or certify the bundle with a statement such as "this is a true and complete copy of the original document comprising 14 pages" and number the pages. A certified first page followed by thirteen loose uncertified pages is a common reason for rejection, because nothing proves the later pages belong to the same original.

Certifying identity documents properly

Passports and identity cards need extra care because the provider is relying on the certification for both document authenticity and face matching.

  • The copy should show the full photo page, including the machine-readable zone at the bottom. Cropped copies are routinely rejected.
  • For identity cards, both sides should be copied and certified.
  • The copy should be in colour where possible and legible at normal zoom. A dark scan where the photograph is a black rectangle cannot be used for likeness checks.
  • The certifier should meet the person, compare them with the photograph and say so in the wording.
  • The passport should be valid on the date of certification and ideally for some months after, so it does not expire during onboarding.

Many providers now offer electronic identity verification, where the individual photographs their passport and takes a live selfie through a secure link. Where that is available, it often replaces the need for a certified passport copy altogether, and it is usually faster.

Certifying corporate documents

Corporate documents follow the same principles, with a few practical differences.

The natural certifier for a BVI or Cayman company's constitutional documents is often the registered agent, because it holds the original records. A certificate of incumbency issued by the registered agent is itself an original document from that agent, and in many cases it can be supplied as an original PDF sent directly from the agent rather than as a certified copy.

For documents issued by a companies registry, such as a certificate of good standing, providers generally accept either the original registry document, a certified copy, or a version that can be verified on the registry's own system. Several registries now issue certificates with a verification code or QR code; where that exists, include it.

Where the memorandum and articles have been amended, the certifier should certify the consolidated current version, or the original plus every amending resolution. Certifying an out-of-date version creates questions about whether the current rules are the ones being relied on.

Digital and electronic certification

Practice here has moved quickly. Many providers now accept:

  • Electronically signed certifications, where the certifier applies a qualified or advanced electronic signature to a PDF of the copy and the certification statement.
  • Documents sent directly by the certifier from their professional email address, which allows the provider to confirm the source.
  • Remote certification by video, where the certifier meets the person over video, sees the original document on camera and certifies the copy. Acceptance of this varies widely, and some providers require the certifier to state explicitly that the meeting was remote.
  • Electronic apostilles, issued by some competent authorities, which can be verified online.

What is generally not acceptable is a scan of a paper certification where the scan has been altered, compressed until unreadable or combined with pages that were not part of the original certification. If you are sending a scan of a wet-ink certified copy, scan the whole bundle in one pass and do not edit it.

Some providers want the physical certified copy posted to them. If so, they will say. In most digital onboarding processes, a clear colour scan of a properly certified document is enough at application stage.

Why certified copies get rejected

From the review desk, these are the problems that come up most often:

  1. The certifier cannot be identified. An illegible signature with no printed name, profession or contact details is effectively anonymous.
  2. The certifier is not independent. A co-director, relative or employee has signed.
  3. The certifier's profession is not on the accepted list, or there is no registration number that can be checked.
  4. The wording is incomplete, for example a stamp that says "certified" with no statement that the original was seen.
  5. The copy is too old. Many providers want certifications dated within the last three to six months, particularly for proof of address and identity documents.
  6. Pages are missing or unlinked, as described above.
  7. The underlying document is unsuitable, for instance an expired passport, or a proof of address older than three months on the date it was certified.
  8. The language is not one the provider can read and no certified translation is attached.

Most providers will check a sample of certifiers against public professional registers. If the certifier is a lawyer, expect the provider to search the relevant law society or bar register. A certification that fails that check usually leads to a request for re-certification, and sometimes to wider questions about the file.

Practical tips for getting it right first time

A short brief to the certifier saves a second appointment:

  • Send the certifier the provider's wording requirements in advance, or the sample wording above.
  • Ask them to certify every document you are likely to need in one sitting: passport, proof of address, and any corporate documents they are able to certify.
  • Ask for their registration number and full contact details on each certification, not just on a covering letter.
  • Check the dates. If your proof of address is ten weeks old when certified, it may be over three months old by the time the provider reviews it.
  • Check the scan before sending: full pages, colour, readable stamp, nothing cropped.
  • Keep a note of who certified what and when. At your next periodic review, you may be able to use the same certifier again with less explanation.

Example: a Nevis company with two beneficial owners in different countries. Owner A in Hong Kong visits a solicitor; owner B in Warsaw visits a notary. Both certify passports and proof of address using the same wording. The Nevis registered agent supplies the incumbency certificate and certified constitutional documents directly. One consistent standard across all three sources means the analyst can check each certifier quickly and move on.

Getting help

This article is general information about common certification practice in financial services onboarding. It is not legal advice, and each provider sets its own acceptance criteria. If you are unsure whether a particular certifier will be accepted, ask before the certification is done.

When you apply to CCYFX, the onboarding checklist builder shows which documents need certification for your entity type, and our compliance page explains how we verify the documents we receive.

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