ARNECC-Aligned Client Identity Verification Template for Sydney Conveyancers: Document VOI to a Defensible Standard
You know you have to verify the identity of every client before lodging in PEXA. You also know that “I asked for their licence and passport” is not a record that will hold up if the file is ever audited or the transaction is later challenged as fraudulent. This template gives your firm a repeatable, ARNECC-aligned record of what you checked, when, how, and why — for every client, every file.
Why it matters now
Under the Electronic Conveyancing National Law (ECNL), Subscribers — including conveyancers and settlement agents — must comply with Participation Rules made by the Registrar in each State and Territory. Those Rules are derived from the Model Participation Rules (currently Version 7, January 2024) published by the Australian Registrars’ National Electronic Conveyancing Council (ARNECC). The Model Participation Rules require Subscribers to verify the identity of their clients and to retain evidence of that verification for inspection. In NSW the Participation Rules are determined by the Registrar General and enforced through compliance examinations. Identity theft against property owners — where a fraudster impersonates a registered proprietor to extract equity or transfer title — is a recognised conveyancing fraud pattern that the Verification of Identity (VOI) Standard in the Model Participation Rules is specifically designed to mitigate.
The 5-minute view
- The ARNECC Model Participation Rules Version 7 (January 2024) is the current model in force, published at arnecc.gov.au
- Subscribers must verify the identity of clients and “take reasonable steps” to verify the identity of represented parties before lodging conveyancing transactions
- The Verification of Identity Standard set out in the Model Participation Rules describes a face-to-face identity check using categories of identity documents, plus a check that the person reasonably appears to be the person identified in the documents
- Where the VOI Standard is followed, the Subscriber has the benefit of a “safe harbour” — they are deemed to have taken reasonable steps
- Subscribers must retain evidence of identity verification for at least 7 years (per the Participation Rules retention requirements)
- The Subscriber is responsible whether VOI is performed in-house or delegated to an Identity Agent
- Compliance examinations may require production of identity verification records on short notice
What DRMO does about it
The Identity Verification Protocol Template is a productised L1 deliverable: a fixed-format PDF template a Sydney conveyancing or settlement practice can adopt as its standing record-of-VOI for every client file. The template is structured around the Verification of Identity Standard described in the ARNECC Model Participation Rules Version 7, with fields for the identity documents sighted (by category), the date and method of the face-to-face check, the verifier’s name and role, the photograph comparison step, the reason any document category was substituted, and the retention reference. It includes a one-page walkthrough explaining how each field maps to the Model Participation Rules requirements, plus a short section on when to escalate to a registered Identity Agent. This is the entry-level offer in the DRMO Identity Verification service line; it is not legal advice, and it is not a substitute for the firm’s own engagement with its practitioner regulator’s guidance.
The deliverable
- Editable PDF template (single client file), ARNECC-aligned field structure
- 4-page walkthrough mapping each field to the relevant Model Participation Rules requirement
- Escalation checklist: when to refer the VOI to a registered Identity Agent
- Retention prompt with the 7-year reference baked into the footer
- Delivered via email immediately on payment; no discovery call required
CTA
Buy the Identity Verification Protocol Template — AUD $149
A one-time productised purchase. Suitable for sole-practitioner and small-team conveyancing firms in NSW who want a defensible, repeatable VOI record-format aligned to the ARNECC Model Participation Rules.
Sources
- Australian Registrars’ National Electronic Conveyancing Council — Model Participation Rules (Version 7, January 2024): https://www.arnecc.gov.au/publications/model-participation-rules/
- ARNECC — Participation Rules by Jurisdiction (entry point to the NSW Participation Rules determined by the Registrar General): https://www.arnecc.gov.au/
- NSW Land Registry Services and the Office of the Registrar General publish jurisdiction-specific guidance for Subscribers; see https://www.arnecc.gov.au/ for current cross-references.
DRMO capability references:
- Identity Verification Protocol Template (L1 service shape, productised)
- DRMO Identity Verification service line (entry-level template; L2 and L3 packages available)