❓ What are the ARNECC requirements for verifying identity?
ARNECC outlines two accepted methods for Verification of Identity (VOI) under the Model Participation Rules (MPRs):
The VOI Standard – a prescriptive, in-person method
The Reasonable Steps approach – a flexible method used when the VOI Standard isn’t practical
❓ What is the VOI Standard?
The VOI Standard is the preferred method and requires:
A face-to-face interview, either by you or a trusted Identity Agent (e.g., Australia Post)
The person presenting original, physical identity documents
Use of specific document combinations from VOI Categories 1–7
Retention of a VOI record showing:
The verifier's details
The date and location
The documents sighted
Confirmation that the VOI Standard was followed
🔹 Biometrics and electronic verification are not required under the VOI Standard.
❓ Can I verify someone’s identity online?
Yes — but ARNECC doesn’t specifically mention “online verification.” Instead, it allows for a Reasonable Steps approach when in-person verification is not possible or practical. This flexibility has become more relevant since COVID.
❓ What is the Reasonable Steps approach?
The Reasonable Steps method allows you to verify identity in alternative ways (including digitally) — as long as the steps taken are reasonable in the circumstances and provide a high level of confidence that the person is who they claim to be.
❓ What should an ARNECC-compliant online VOI process include?
To be considered compliant under the Reasonable Steps framework, an online identity verification process should include:
✅ Verification of name, date of birth, and address from two or more independent and reliable data sources
✅ Biometric face matching with liveness detection (e.g., a selfie or video matched to the ID photo)
✅ Consent from the individual being verified
✅ Secure storage of:
Match results
Timestamps and IP/geolocation
Verification method
Risk decisions
✅ Clear justification for not using the in-person VOI Standard (e.g., remote client, international location)
✅ Optional risk checks like PEP & sanctions screening, and fraud flag detection (e.g., VPN usage)
❓ Is Realaml's online VOI compliant with ARNECC?
Yes — Realaml’s identity verification process can meet ARNECC’s Reasonable Steps requirements, provided:
Two independent data sources are used to verify name, DOB, and address
Biometric facial matching and liveness detection are included
Full audit trails are maintained
Consent is obtained
The online method is used in situations where in-person verification is not practical
❓ How does ARNECC VOI compare to AUSTRAC KYC/CDD?
ARNECC VOI is narrowly focused on identity verification for land transactions.
In contrast, AUSTRAC’s KYC/CDD (Know Your Customer / Customer Due Diligence) obligations are more robust and comprehensive, covering:
Customer risk profiling
Source of funds and wealth
Ongoing monitoring and due diligence
Suspicious matter reporting
👉 VOI can form part of AUSTRAC compliance — but not a substitute for full KYC/CDD processes.