You can pass the cost of ID and AML checks on to clients, as long as it's in your terms and the client understands it before instructing you. The card processing part carries the risk. If it only applies to people paying by card, it's a card surcharge whatever you call it, and surcharges on personal cards are banned. If every client pays it, it's part of your price and belongs in the headline figure, not added later.
In this article
The short version
- ID and AML check costs can be passed on to clients if they're in your terms and the client understands them before instructing you.
- Any part of the fee that only card payers pay is a card surcharge, and on a personal card it falls within the regulation 6A ban.
- If every client pays it, the fee is part of your price, and since 6 April 2025 advertised consumer prices must include every compulsory fee.
- Residential conveyancing cost information must also show anything a client might reasonably expect to be included but isn't, and many would expect ID checks to be.
- Show ID checks as their own line, put pay by bank first on the payment page, and surcharge only commercial cards up to your cost.
What the fee is covering
ID checks cost money on every file, and so does every card payment. Rolling both into a £60 "digital onboarding" line on the quote looks like a tidy way to get them back.
Take a purchase for two buyers. The ID provider charges £12 a person for identity and source of funds checks, so £24. The other £36 is meant to cover card fees on the £1,500 payment on account and some admin time. Those two parts face different rules, and the second needs more care.
You can pass the cost of customer due diligence on to clients if it's clearly stated in your terms and conditions and the client understands it in advance, so they can go elsewhere if they don't agree. Decide whether you treat the check as a disbursement (a third-party cost paid for the client) or as part of your own fee, and keep that consistent across your terms, your published price and your bill.
When the fee becomes a card surcharge
Since January 2018, regulation 6A of the Consumer Rights (Payment Surcharges) Regulations 2012 has banned fees for paying by personal (consumer) credit or debit card. The ban follows the card, not the client, so it covers almost every residential buyer and seller. Only commercial cards can carry a fee, and then only up to what the card costs you to accept.
The label makes no difference, because a booking or handling fee only sits outside the surcharge rules if it doesn't differ by how the customer pays. So if the £36 falls away when a client pays by bank transfer, or only card payers are charged it, that part of the fee is a charge for paying by card, and on a personal card it falls within the ban on the wording of the Regulations.
When the fee becomes a hidden charge
If every client pays the full £60 whatever they pay with, it isn't a card surcharge, but it is part of your price.
Since 6 April 2025, section 230 of the Digital Markets, Competition and Consumers Act 2024 has required the price you advertise to consumers to include every fee they will necessarily pay, and a compulsory administration fee counts however you describe it. A website quote showing £950 plus VAT for a purchase, with a £60 onboarding fee first appearing in the client care letter, is the kind of presentation to check carefully against that section.
For residential conveyancing, your published cost information also has to include the total cost or a range, likely disbursements and VAT, and anything a client might reasonably expect to be included in the price but isn't. Many clients would assume ID checks are part of the service, so a separate charge needs saying up front.
Cleaner ways to handle both costs
Each cost has a simpler route of its own:
- Show ID checks as their own line. Put the per-person check cost in your published price and your terms, with its VAT treatment, and let the client see it before instructing you.
- Price the work as a whole. If you want one figure, make it the figure you publish and quote, with no extras added at the client care letter stage. Check the level and description of any fee with your compliance lead.
- Make the cheaper payment method the easy one. Put pay by bank first on the payment page, with card as the fallback. On Adfin's published pricing, a £1,500 payment on account costs £4.20 by pay by bank, where the percentage is capped at £4, against £15.20 on a standard card, and pay by bank money reaches you the same day.
- Surcharge commercial cards only. If a business client pays on a company card, a fee capped at your cost for that card is possible. Adfin's business-card surcharging adds and collects the card fee on business card payments, per client or for all, with your firm deciding who it applies to.
Collecting the money on account before you order searches is the other half of the job. Send a payment link with the client care letter, and if it isn't paid, Adfin's Customer Agents can follow up over email, SMS or WhatsApp on a schedule you set, with your team approving what goes out.
Common questions
Can conveyancers pass the cost of ID checks on to clients? Yes, if the cost is clearly stated in your terms and conditions and the client understands it before instructing you.
Does calling it an admin fee take it outside the surcharge rules? Only if it doesn't vary by how the client pays. A fee only card payers pay is a card fee, and on a personal card it falls within the ban.
What if the client pays with a business card? A commercial card can carry a fee capped at what that card costs you to accept. A business client paying on a personal card is paying with a consumer card.
Does an onboarding fee have to be in our website price? For residential conveyancing, published cost information must include the total cost or a range, likely disbursements and VAT, and anything a client might expect to be included but isn't.
Is an ID check fee a disbursement? It depends on the facts. A check bought from a third party for a named client may fit the SRA's definition of a disbursement, or you may treat it as part of your fee, and your VAT and published price should follow the same choice.
When did the drip pricing rules start? The total-price rules in the Digital Markets, Competition and Consumers Act 2024 came into force on 6 April 2025.
Sources
- SRA - Compliance with the regulations and preventing money laundering Q&A (accurate as of September 2026) https://www.sra.org.uk/solicitors/resources/money-laundering/aml-questions-answers/
- SRA - SRA Transparency Rules (accurate as of September 2026) https://www.sra.org.uk/solicitors/standards-regulations/transparency-rules/
- legislation.gov.uk - The Consumer Rights (Payment Surcharges) Regulations 2012 (accurate as of September 2026) https://www.legislation.gov.uk/uksi/2012/3110
- Department for Business, Innovation and Skills - Consumer Rights (Payment Surcharges) Regulations 2012: Guidance (accurate as of September 2026) https://assets.publishing.service.gov.uk/media/5b2d09bae5274a55bb5790cb/payment-surcharges-guidance-update.pdf
- Competition and Markets Authority - Unfair commercial practices: price transparency (CMA209) (accurate as of September 2026) https://assets.publishing.service.gov.uk/media/691b10065a253e2c40d705d9/Price_transparency_-_CMA209_.pdf
- Adfin - Pricing (accurate as of September 2026) https://www.adfin.com/pricing
