Bona Vacantia RA15 ID Certification for Restored Company Repayment Applications

If you are applying to the Bona Vacantia Division (BVD) to recover money belonging to a restored UK company, you may be required to provide certified proof of identity and certified proof of residential address with your application.

Ginkgo Advisory provides an express remote solicitor certification service for individuals who need certified copies of identification documents for a Bona Vacantia RA15 repayment application in England and Wales.

Our service can cover a passport or other identity document, together with suitable proof of address such as a bank statement or utility bill. Where appropriate, remote verification can be supported by video evidence, online account verification and NFC passport-chip data, allowing the solicitor to assess the original document and its holder remotely before issuing the required certified copy.

Express same-day service is available, subject to successful verification and receipt of all required documents.

Important: This page concerns applications to the Bona Vacantia Division of the Government Legal Department in England and Wales. Scottish restored-company funds are handled separately by the King’s and Lord Treasurer’s Remembrancer (KLTR), whose certification requirements differ materially and currently require wet-ink, in-person certification.

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What is a Bona Vacantia RA15 application?

When a company is dissolved, certain assets remaining in the company’s name can pass to the Crown as bona vacantia, meaning ownerless property.

If the company is subsequently restored to the Companies House register, an eligible applicant can apply to the Bona Vacantia Division (BVD) for repayment of cash assets that were transferred to or collected by BVD when the company was dissolved. The relevant procedure is commonly referred to as the RA15 restored company repayment application.

According to current GOV.UK guidance, an application can be made by an eligible:

• company director;
• company secretary;
• creditor;
• insolvency practitioner; or
• liquidator.

The company must first have been restored to the Register of Companies before a repayment application can be made.

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Do I need certified ID for a Bona Vacantia application?

It depends on the value of the repayment and where the repayment is being sent.

Current Bona Vacantia Division guidance makes an important distinction between repayments below £10,000 and repayments above £10,000.

Bona Vacantia repayment below £10,000

Where the amount being repaid is less than £10,000, BVD states that it will generally not require proof of identity unless a third-party payment is requested.

A third-party payment means that the money is being paid into an account other than the account of the restored company.

Where payment to another account is requested, BVD requires two proofs of identity:

1. A certified copy of ID proving your name, for example a passport; and
2. A certified copy of ID proving your residential address, for example a utility bill or bank statement no more than three months old.

This is precisely where our Bona Vacantia solicitor certification service can assist.

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What if the Bona Vacantia repayment is over £10,000?

Where the repayment exceeds £10,000, the application is automatically subject to anti-money laundering checks.

BVD’s current guidance states that identity requirements apply to:

• the person signing the RA15 application;
• the majority of the company’s officers; and
• shareholders holding 25% or more of the shares in the restored company.

If a shareholder holding 25% or more is itself a company, additional company identification requirements can apply.

Therefore, a higher-value RA15 application may require certification for several directors, officers or beneficial shareholders, rather than only one applicant.

Ginkgo Advisory can assist with coordinating remote verification and solicitor certification for multiple individuals, including individuals located in different places, subject to the documents and circumstances of each person.

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What documents can be certified for a Bona Vacantia RA15 application?

Our service is designed particularly for the identity documents commonly required for BVD applications.

Certified copy of passport

A current passport can be used to prove the applicant’s name.

We can arrange remote solicitor verification and certification of a passport, subject to satisfactory identity verification.

Depending upon the circumstances, the verification process may include:

• a clear colour scan or photograph of the passport;
• inspection of the passport during a live or recorded video verification process;
• comparison of the document holder with the passport photograph;
• inspection of security characteristics visible during video verification; and
• NFC verification of the electronic passport chip, where appropriate and technically available.

NFC verification provides an additional source of electronic data from a compatible biometric passport and can assist the verification process.

It does not replace the solicitor’s professional assessment and should not be interpreted as a separate requirement imposed by the Bona Vacantia Division.

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Certified copy bank statement for proof of address

A recent bank or building society statement may be used as evidence of residential address where it meets the relevant BVD requirements.

For a remotely supplied electronic bank statement, we may ask the customer to provide:

• the statement in its original electronic PDF format where available;
• a clear copy showing the customer’s full name and residential address;
• the statement date;
• relevant bank information; and
• additional video evidence showing access to the statement through the customer’s genuine online banking account where required for verification.

For Bona Vacantia identification purposes, GOV.UK specifically gives a bank statement no more than three months old as an example of acceptable proof of residential address in the relevant RA15 circumstances.

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Certified copy utility bill for proof of address

A recent utility bill may also be suitable for proving residential address.

Examples may include eligible household utility documentation showing:

• the applicant’s name;
• residential address;
• utility provider;
• account or statement information; and
• a sufficiently recent issue date.

BVD’s RA15 guidance specifically identifies a utility bill as an example of address evidence and states that the document should be no more than three months old in the relevant identification scenario.

Where an electronic utility statement is being certified remotely, additional verification may be requested, such as evidence of the customer accessing the relevant statement through the provider’s genuine online account.

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Can a solicitor certify documents for Bona Vacantia?

Yes.

For applicants living in the UK, current BVD guidance expressly states that proof-of-identity documents can be certified either through the Post Office Document Certification Service or by a practising solicitor.

BVD states that the person certifying the documents must:

• sign and date the documents;
• state their full name;
• state their business name;
• state their business address; and
• state their professional status.

Our service is structured around these Bona Vacantia certification requirements.

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Remote solicitor certification for Bona Vacantia applications

Many applicants no longer have convenient access to a solicitor’s office, particularly where directors or shareholders are travelling, working overseas or living in different parts of the UK.

Our service allows the verification stage to be completed remotely, where the particular documents and circumstances permit.

The solicitor must still be satisfied as to the authenticity of the document and the identity of the person presenting it.

We may therefore use several layers of evidence rather than relying solely on an emailed photograph.

Our remote verification process may include

Document copy verification
You provide a clear, high-resolution copy of the passport, bank statement, utility bill or other relevant document.

Video identity evidence
You may be asked to record or participate in a short video showing your face together with the physical passport or other identity document.

Physical-document inspection by video
For passports, you may be asked to move or tilt the original document during the video so that relevant physical and security characteristics can be assessed.

NFC passport verification
For compatible biometric passports, NFC technology may be used to read information stored electronically on the passport chip as an additional verification measure.

Online bank or utility account verification
For electronic proof-of-address documents, we may ask you to demonstrate access to the relevant online bank or utility account and open the statement being presented for certification.

The precise verification steps depend on the individual case and remain subject to the certifying solicitor being satisfied with the evidence supplied.

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Same-Day Bona Vacantia Solicitor Certification

Where your RA15 application is ready and the certification of your identification documents is the outstanding requirement, we offer an express same-day solicitor certification service.

This can be particularly helpful where:

• your company has already been restored;
• you have received the Companies House restoration confirmation or court order;
• BVD has requested certified identification;
• you need to complete a Payment Authority;
• a director is outside London;
• several company officers need certification;
• a shareholder holding 25% or more needs to provide ID;
• you need a passport certified urgently;
• you need a bank statement certified as proof of address; or
• you need a utility bill certified as proof of address.

Same-day completion is subject to the necessary documents and verification evidence being supplied promptly and the solicitor being satisfied that certification can properly be given.

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What does BVD require with an RA15 repayment application?

According to current GOV.UK guidance, an RA15 application may require:

• a completed RA15 application;
• a scanned bank statement for the account that will receive the repayment;
• the court order restoring the company, or the relevant RT01 confirmation letter from Companies House following administrative restoration;
• a completed Payment Authority where repayment will be made to a third party; and
• applicable certified proofs of identity.

The Payment Authority becomes particularly important when the requested repayment is going to a personal account or another account that is not the restored company’s account.

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More than one director or company officer?

Where a repayment below £10,000 is being made to a third-party account and there is more than one company officer, BVD states that each officer must complete and sign the Payment Authority and provide certified copies of the required proof-of-identity documents.

For example, a restored company with two officers may therefore require separate certified identification documentation for both individuals.

For repayments exceeding £10,000, the AML requirements can be broader because identification applies to the person signing the RA15, the majority of company officers and qualifying shareholders.

Our team can organise the certification requirements for several individuals as part of one coordinated matter.

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Can Bona Vacantia certified documents be submitted electronically?

For England and Wales, yes: current GOV.UK RA15 guidance instructs applicants to submit applications electronically and states that the application and certified identity documents can be sent as PDF or JPG attachments by email to BVD.

This makes an efficient remote solicitor-certification workflow particularly useful for England and Wales RA15 applications.

However, applicants should distinguish this from the position in Scotland. Scottish bona vacantia company funds are handled by KLTR, whose published guidance currently states that certified true copies must be wet-ink certified in person and that digital or electronic certification is not accepted.

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Bona Vacantia ID Certification for Applicants Outside London

You do not necessarily need to travel to a London solicitor’s office simply because your company or adviser is based in London.

Subject to satisfactory verification, our remote process is designed for customers throughout England and Wales, including:

London, Richmond, Kingston upon Thames, Surrey, Croydon, Westminster, City of London, Greater London, Birmingham, Manchester, Liverpool, Leeds, Bristol, Cardiff, Oxford, Cambridge, Reading, Southampton, Portsmouth, Brighton, Kent, Essex, Hertfordshire and nationwide across England and Wales.

We can also assess enquiries involving individuals who are temporarily or permanently overseas, although BVD publishes separate guidance regarding who may certify documents for applicants living outside the UK. Its listed options include a locally registered Notary Public, British Embassy, Consulate or High Commission, and certain court or Justice Ministry services.

Accordingly, overseas cases should be checked individually before certification is arranged.

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Why use enhanced video and NFC verification?

Remote document certification has to provide the solicitor with sufficient evidence to reach an appropriate professional conclusion.

A simple photograph sent over WhatsApp or email may not, by itself, provide adequate assurance in every case.

Our enhanced remote verification procedure may therefore combine:

Identity document + document holder + video evidence + electronic/NFC information + source-account verification.

For a biometric passport, for example, NFC data can provide an additional way to compare electronically stored passport information with the document supplied.

For an electronic bank statement, evidence of the applicant securely accessing their own online banking platform and retrieving that statement may provide additional evidence concerning its provenance.

These measures form part of our verification methodology. They should not be confused with a statement that BVD itself requires NFC scanning or video verification: the published BVD requirement is for appropriately certified proof of identity, while the certifying professional must be satisfied that they can properly make that certification.

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Frequently Asked Questions

Does Bona Vacantia require a certified passport?

A certified passport may be required where BVD’s identification requirements apply. For repayments under £10,000, this commonly arises where repayment is requested to an account other than the restored company’s account. For repayments over £10,000, AML identification requirements automatically apply to specified individuals.

Can a solicitor certify my passport for Bona Vacantia?

Yes. For applicants living in the UK, the BVD guidance specifically lists a practising solicitor as an acceptable certifier.

Can you certify a bank statement for an RA15 application?

Yes, subject to the document satisfying the relevant requirements and the solicitor being able to verify it appropriately. BVD identifies a recent bank statement as an example of residential-address evidence.

How recent does my bank statement need to be?

For the RA15 identification requirement described by BVD, a bank statement used as residential-address evidence should be no more than three months old.

Can a utility bill be used for Bona Vacantia proof of address?

Yes. BVD expressly identifies a utility bill as an example of residential-address evidence, again referring to documents no more than three months old for this requirement.

Can you certify electronic bank statements remotely?

Potentially, yes. We can assess electronically issued statements and may require additional evidence, including video verification of the account and the original electronic statement. Certification remains subject to the solicitor being satisfied with the evidence.

Is NFC passport scanning required by Bona Vacantia?

The published BVD guidance does not state that NFC scanning is mandatory. We may use NFC passport data as an additional identity and document-verification measure as part of our remote certification process.

Can certification be completed on the same day?

We offer an express same-day remote solicitor certification service, subject to receiving satisfactory documents and completing all required verification checks.

Does BVD want my original passport?

For the RA15 procedure, the Government specifically warns applicants not to send original identity documents to the Bona Vacantia Division.

How long does BVD take to process an RA15 application?

The published BVD guidance currently states a processing period of up to 20 working days from receipt of a complete and correct application.

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Express Remote Solicitor Certification for Your Bona Vacantia Application

If you have been asked to provide certified identity documents for an RA15 Bona Vacantia repayment application, Ginkgo Advisory can assist with arranging an efficient solicitor-certification process.

We can assist with:

• Certified copy passport
• Certified copy ID
• Certified bank statement
• Certified utility bill
• Certified proof of residential address
• Bona Vacantia RA15 identity documents
• Payment Authority supporting ID
• Remote video document verification
• Electronic document verification
• NFC biometric passport verification
• Multiple director/officer verification
• Express same-day solicitor certification

Send us clear copies of the documents required for your application and we can advise on the verification evidence needed to proceed.