Certified Copy

A certified copy is a copy of a document that an authorised person, such as a notary or a lawyer, has compared with the original and confirmed in writing to be a true copy. National law and the receiving body decide who may certify. The EU Anti-Money Laundering Regulation does not use the term.

Updated Reviewed by Tomas Zuoza, CEO of ZealiD

What is a certified copy?

A certified copy is a copy that carries a signed statement from someone who has seen the original. The statement says that the copy is a true copy of the original document. It usually gives the certifier's name, profession or office, the date and a signature, often with a stamp.

The purpose is practical. A passport or a diploma cannot be handed to everyone who asks for it. The original stays with its owner, and the recipient gets a copy that a third person vouches for.

The statement is narrow. The certifier confirms that the copy matches the document shown. The certifier does not confirm that the original is genuine, that its contents are correct, or, unless the statement says so, that the person presenting it is the person named in it. A certified copy of a forged document is a faithful copy of a forgery.

Who can certify a copy of a document?

That depends on national law and on who is asking for the copy. There is no EU-wide list of people who may certify. In different countries and for different purposes, the certifier may be a notary, a lawyer, a public official or the body that issued the original. Certification of a copy by a notary is one of the lighter forms of notarisation.

The receiving body often has rules of its own. A bank, a court, a company register or a regulator may accept only certain certifiers, may ask for particular wording, or may want the certification to be recent. The safe order is to ask the recipient what it accepts and then find a certifier who fits.

A copy going abroad can need a further step. The receiving authority cannot know a foreign notary's signature, so it may ask for an apostille on the notary's certification, or for legalisation where the country is outside the Hague Convention of 5 October 1961.

Further reading

Why do firms ask for a certified copy in client due diligence?

Firms ask for a certified copy when they cannot see the original document themselves. Anti-money laundering law requires a firm to verify a client's identity. When the client is in the office, a member of staff can look at the passport. When the client is in another country, the firm receives only an image. A certified copy puts a trusted third person between the client and the firm: someone who did see the original.

The practice comes from national rules, supervisors' guidance and firms' own procedures built up under the earlier EU directives. Those sources differ by country, so a firm should check what its own supervisor expects.

The method has a weakness. The firm then has to judge a second document, the certification itself, often signed by someone it does not know.

Does the EU Anti-Money Laundering Regulation require a certified copy?

No. The words "certified copy" do not appear in the regulation. Article 22(6) of Regulation (EU) 2024/1624 gives two means of obtaining what is needed to verify identity. The first is "the submission of an identity document, passport or equivalent and, where relevant, the acquisition of information from reliable and independent sources". The second is the use of electronic identification means at assurance level substantial or high "and relevant qualified trust services" under the eIDAS Regulation.

The record-keeping rule speaks of copies, not certified copies. Article 77(1)(a) requires a firm to retain "a copy of the documents and information obtained in the performance of customer due diligence", "including information obtained through electronic identification means". For transaction records, Article 77(1)(c) asks for "the original documents or copies admissible in judicial proceedings under the applicable national law". That is the closest the text comes to a quality requirement for a copy.

More detail is left to a lower level. Article 28(1) set 10 July 2026 as the deadline for the Anti-Money Laundering Authority to draft regulatory technical standards on the information to be collected for due diligence, including the reliable and independent sources that may be used to verify identity. The regulation applies from 10 July 2027. Until then national law applies, and it may be more specific about copies.

How do electronic identification and qualified trust services change the need for certified copies?

They give a firm a way to verify a remote client that does not start from a paper copy. Under Article 22(6)(b), electronic identification at assurance level substantial or high and relevant qualified trust services stand beside the identity document as a means of verification in their own right.

Recital 66 explains the intention. Electronic identification under the eIDAS Regulation "should be taken into account and accepted by obliged entities for the customer identification process". Where it is not available to a customer, for example because the customer lives in a third country, "verification should take place through relevant qualified trust services".

What the firm keeps changes as well. Article 77(1)(a) expressly covers information obtained through electronic identification means, so the file holds that information where it would otherwise hold a stamped photocopy.

This does not make certified copies disappear. Documents outside the identity check, such as a foreign company's constitutional documents, may still be requested as certified copies.

Is an electronic copy accepted as evidence in place of a certified copy on paper?

An electronic copy cannot be refused as evidence only because it is electronic. Article 46 of the eIDAS Regulation states: "An electronic document shall not be denied legal effect and admissibility as evidence in legal proceedings solely on the grounds that it is in electronic form."

The rule is about admissibility. It does not say that a scan is equal to the original or to a certified copy, and the weight a court gives to it is left to national law.

A document that is electronic from the start is in a stronger position. If the issuing body applies a qualified electronic seal, Article 35(2) gives the document a presumption of integrity and of correctness of origin. The recipient can then check the file itself and does not need a third person to compare it with an original.

Related questions

Is a certified copy the same as an original document?

No. It is evidence that a copy matched the original on the day of certification. Whether a recipient accepts it in place of the original is for that recipient and its national law to decide.

How long must a firm keep the copies it collects in due diligence?

Five years. Article 77(3) of Regulation (EU) 2024/1624 sets a retention period of five years from the end of the business relationship or from the date of the occasional transaction. A competent authority may require up to five further years in an individual case.

References

  1. Regulation (EU) 2024/1624 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, recital 66 and Articles 22, 28, 77 and 90. European Union, 2024. eur-lex.europa.eu/eli/reg/2024/1624/oj

  2. Regulation (EU) No 910/2014 on electronic identification and trust services for electronic transactions in the internal market (eIDAS), Articles 35 and 46. European Union, consolidated version of 18 October 2024. eur-lex.europa.eu/eli/reg/2014/910/2024-10-18

  3. Convention of 5 October 1961 Abolishing the Requirement of Legalisation for Foreign Public Documents (Apostille Convention). Hague Conference on Private International Law, 1961.

This article describes EU rules: Regulation (EU) 2024/1624, which applies from 10 July 2027, and the eIDAS Regulation. Who may certify a copy and when one is required are set by national law and by the body receiving it. It explains the term in general and is not legal advice.

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