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one for david maybe!

if you outsource all payroll for clients, what id checks does the payroll outfit need to do.  would it be me/company or each of my clients?

If the latter i could provide certified copies of passports etc with clients permission.



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02nd Mar 2011 20:25

Questions for you

Is the business to whom you are outsourcing based in the UK?

If the business is in the UK is it registered with a supervisory body under the MLR 2007?

What are the contractual arrangement for the client (i.e. does the client get a bill from you or from the company to whom you outsource)?


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03rd Mar 2011 08:32


Hi David

Yes uk based firm who are ml reg with HMRC.

I am billed by payroll bueau, and i bill my clients direct.

Many thanks

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03rd Mar 2011 14:39

Their client is you


It seems to me that the payroll bureau's client is you.  Therefore they have to perform Client Due Diligence on you (which should not be a problem - if you co-operate!).

But they are providing the service ultimately to your clients and so they have to be satisfied that they know who these ultimate clients are.

In practice you will have done CDD on these clients.  So you have two options, either you can supply them with copies of the ID documents you have for the ultimate clients (i.e. your clients, the employers in respect of the payrolls) or (subject to one query - see below) you can reach an agreement with the payroll bureau that they can rely on you to have done sufficient CDD.

The latter is permitted under Reg 17 MLR 2007 only if you are supervised by a body listed in Part 1 of Schedule 3 to the MLR 2007.  Those bodies are:

1.  Association of Chartered Certified Accountants

2.  Council for Licensed Conveyancers

3.  Faculty of Advocates

4.  General Council of the Bar

5.  General Council of the Bar of Northern Ireland

6.  Institute of Chartered Accountants in England and Wales

7.  Institute of Chartered Accountants in Ireland

8.  Institute of Chartered Accountants of Scotland

9.  Law Society

10.  Law Society of Scotland

11.  Law Society of Northern Ireland


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03rd Mar 2011 15:39


Thanks David.  ACCA so no problems there.

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