A Philippine legal-context article on identity requirements, KYC/eKYC practice, and borrower rights

1. Scope and practical meaning of “accepted government ID”

In the Philippine consumer-lending market, “accepted government ID” generally means a valid, current, government-issued identification document used to verify a borrower’s identity under a lender’s Know-Your-Customer (KYC) or electronic KYC (eKYC) process. For online salary loans—typically short-term personal loans marketed to employed persons and repaid via salary, payroll deduction, bank transfer, e-wallet, or scheduled payments—identity verification is the foundation for:

Contract formation (knowing who is signing and consenting),
Fraud prevention (deterring impersonation and synthetic identity),
Risk assessment (matching identity to employment and credit data),
Regulatory compliance (privacy, consumer protection, and—when applicable—financial-sector rules).

There is no single universal list mandated for all lenders across all channels. Acceptance depends on:

the lender’s regulatory category (bank, financing company, lending company, cooperative, etc.),
the lender’s risk appetite and internal controls, and
what its eKYC technology can reliably authenticate.

That said, the market converges around a core set of “primary” IDs.

2. Key Philippine legal and regulatory context

Even when a law does not publish a single “required ID list,” multiple legal regimes shape what lenders may ask for and how they must handle it.

2.1 Identity and eKYC as part of sound onboarding

Different regulators supervise different lender types. In practice:

Banks and BSP-supervised financial institutions follow BSP rules on customer identification/verification and risk management (including when onboarding is digital).
Lending companies and financing companies are generally regulated by the Securities and Exchange Commission (SEC) under their enabling laws and SEC issuances, including rules affecting online lending operations and borrower treatment.

Regardless of regulator, lenders typically implement KYC/eKYC to avoid fraud and to confirm the borrower is a real person.

2.2 Data Privacy Act obligations (Republic Act No. 10173)

Collecting a government ID is personal information processing (often sensitive when it includes biometric images, government numbers, or other high-risk data). Under RA 10173 and its implementing rules, the lender (as personal information controller) must observe:

Transparency (tell you what data is collected and why),
Legitimate purpose (use data only for stated, lawful purposes), and
Proportionality (collect only what is relevant and necessary).

Practically, this means a lender should not demand excessive IDs or use your ID data for unrelated activities (e.g., harassment, unauthorized marketing) and must implement reasonable security measures.

2.3 E-Commerce Act and electronic signatures (Republic Act No. 8792)

Online salary loans are often contracted electronically. RA 8792 supports the legal recognition of electronic data messages and electronic signatures. This is why online lenders may combine:

ID submission,
selfie/liveness checks,
OTP confirmation,
e-signature click-wrap, and
device/account profiling to show that the borrower (1) existed, (2) was verified, and (3) consented.

2.4 Truth in Lending Act (Republic Act No. 3765)

RA 3765 requires clear disclosure of credit terms. While it does not prescribe IDs, it reinforces that onboarding and disclosure must be fair and comprehensible—especially relevant when IDs are used to finalize offers, approve amounts, or set pricing.

3. The commonly accepted government IDs (Philippine context)

Below is a practical, Philippine-market list of IDs that online salary lenders commonly accept, subject to validity and the lender’s policy.

3.1 “Primary” IDs (most widely accepted)

These are typically accepted by most formal lenders because they are photo-bearing, government-issued, and commonly used for identity proof:

Philippine Passport (DFA)
PhilSys National ID (Philippine Identification System) and, in many cases, its official digital/print counterparts used for presentation
Driver’s License (LTO)
UMID (Unified Multi-Purpose ID; historically used for SSS/GSIS—availability and issuance conditions may vary over time)
PRC ID (Professional Regulation Commission)
SSS ID (legacy where still in circulation) / GSIS ID (for government employees/retirees)
Postal ID (PHLPost) (commonly accepted when available and current)

Market reality: Many online salary loan products treat Passport / Driver’s License / National ID as the top tier because they are widely recognized and easier to verify using automated checks.

3.2 Other government-issued IDs often accepted (sometimes “secondary,” sometimes accepted as primary depending on lender)

These may be accepted alone or as support for a primary ID:

Senior Citizen ID (LGU/OSCA-issued)
PWD ID (LGU/NCDA framework)
OWWA ID (for OFWs, depending on lender segment)
Seafarer’s Record Book / Seaman’s Book (for maritime borrowers, lender-dependent)
Government Office/Agency IDs (e.g., certain LGU or national agency employee IDs) — acceptance varies because some are easier to counterfeit and not always standardized nationwide.

3.3 IDs that are commonly not treated as sufficient on their own (or are inconsistent across lenders)

Barangay ID / Barangay Certification / Barangay Clearance: often considered supporting documents, not a robust government ID for online lending by itself.
TIN ID: acceptance varies; some lenders treat it as secondary due to inconsistent formats and verification challenges.
NBI Clearance / Police Clearance: generally a clearance document, not a standard identity card; may support identity but not replace a primary ID.
Voter’s ID: historically accepted, but practical acceptance depends on whether the physical ID is available and current in the market.

4. “Accepted” is not just the ID type: validity and quality rules that decide approval

Even a commonly accepted ID may be rejected if it fails typical checks:

4.1 Validity checks

Not expired (if the ID has an expiry date)
Not damaged (photo, name, and security marks legible)
Matches the applicant’s information (name, birthdate, and sometimes address)

4.2 Photo and biometric consistency

For online salary loans, lenders frequently require:

A selfie holding the ID or a selfie with a liveness test (blink/turn head/gesture),
A clear ID photo with minimal glare and no blur,
No filters or obstructions (masks, sunglasses).

4.3 Data matching and “name issues”

Common friction points:

Married names: If the ID and payroll/bank record differ, lenders may ask for supporting documents (e.g., marriage certificate) or an alternate ID reflecting the updated name.
Multiple first names / suffixes: inconsistencies across employer records, bank accounts, and IDs may trigger manual review.
Nicknames: lenders generally require legal name matching the ID.

5. Why online salary lenders ask for two IDs (and what’s typical)

Many online salary lenders request one primary ID plus one secondary ID (or an additional document) because:

digital onboarding has higher impersonation risk,
duplicate or synthetic identities are harder to detect online,
a second ID improves confidence in identity matching.

Typical combinations:

National ID + Driver’s License
Passport + PRC
Driver’s License + UMID
National ID + Postal ID

When a second government ID is not available, lenders may substitute supporting documents (policy-dependent), such as:

recent payslip, COE, or employment contract,
company ID (not government-issued but useful for employment verification),
bank/e-wallet account ownership proofs.

6. eKYC mechanics: what you are effectively consenting to when you submit an ID

Online salary lenders may employ eKYC techniques such as:

OCR extraction (reading ID fields),
document authenticity checks (template/security feature recognition),
face match (selfie compared to ID photo),
liveness detection (to deter printed-photo attacks),
device intelligence (device ID, IP risk signals).

Legally, these practices must still align with privacy principles: collect only what is necessary, keep it secure, and explain the purpose.

7. Data privacy and borrower-protection issues specific to ID collection

7.1 What a compliant lender should provide (minimum good practice)

When requesting your government ID, a responsible lender should provide, in clear language:

what personal data is collected (including ID number and image),
why it is needed (identity verification, fraud prevention, contract),
how long it will be retained,
who it may be shared with (e.g., verification vendors),
how to exercise data subject rights (access, correction, etc.).

7.2 Red flags (high risk behavior)

Asking for unnecessary permissions unrelated to lending (e.g., full contact list access for “verification” without clear necessity).
Storing or sharing ID images without a clear purpose and retention policy.
Using ID information to pressure, shame, or contact third parties.

8. Practical guidance on preparing acceptable IDs for online salary loans

Use one top-tier primary ID (Passport / Driver’s License / National ID) whenever possible.
Ensure your ID photo capture is sharp, well-lit, and glare-free.
Keep your application details identical to the ID (full legal name, exact birthdate).
If your payroll or bank record uses a different name format, prepare a second ID or a document trail that explains the discrepancy.
Avoid submitting cropped images that cut off corners, security marks, or the full card boundary—many verification systems reject partial captures.

9. Common questions

9.1 Can a lender legally require a specific ID?

A lender can set reasonable onboarding requirements as part of risk control, provided the requirement is not discriminatory and the data collection remains proportionate and properly disclosed under privacy rules. If you cannot meet the ID requirement, the lender may refuse onboarding or require alternate verification.

9.2 Is a company ID enough for an online salary loan?

Usually no by itself for identity proof, because it is not government-issued. It is commonly used as an employment verification document in addition to a government ID.

9.3 If I only have one government ID, will I be rejected?

Not always. Some lenders accept a single strong primary ID, especially if eKYC passes and employment/bank matching is strong. Others require a second ID as a hard rule.

10. Consolidated reference list: IDs most likely to be accepted

Highest acceptance (typical “primary”):

Passport
PhilSys National ID
Driver’s License
UMID (where applicable)
PRC ID
Postal ID
GSIS/SSS-issued IDs (where applicable)

Often accepted depending on lender (supporting/secondary):

Senior Citizen ID
PWD ID
Certain government employee/agency IDs
Seafarer’s Record Book (lender-dependent)

Often treated as supporting, not primary:

Barangay ID/clearance/certification
NBI/Police clearance
TIN ID (varies widely)