Migrating accounts to Stripe

Proof of authority verification

Stripe needs to verify that the account representative has sufficient authority to open an account on behalf of the legal entity.

If we can’t verify this programmatically, Stripe returns the verification_failed_representative_authority error code. If possible, change the representative to a person with sufficient authority.

If necessary, you can allow a business representative without verifiable authority by having a person with authority authorize them in writing:

1. Add the person with authority as a Person with the authorizer relationship. You must provide their first name, last name, and identity document.
2. Have the person with authority sign a Letter of Authorization that permits the business representative to manage the account. They must create the letter using this template.
3. Provide the signed letter as the documents.company_authorization on the Person representing the business representative.

Additionally, the Letter of Authorization requirement can expose document-related errors such as verification_document_name_mismatch, or verification_document_type_not_supported. Make sure you can handle Document Verification Errors and the New verification error codes.

Legal entity verification

Stripe requires the verification of business name, UEN, and legal entity type. If we can’t verify the existence of the company, you must collect a company document.

Stripe also needs to check that the business type and business structure matches the local government records. When a mismatch in business type or business structure occurs, it generates a verification_legal_entity_structure_mismatch error, and you need to update the business type or structure, or provide a company document to verify the legal entity.

UEN information might be verified with the data made available at https://data.gov.sg under the terms of the Singapore Open Data License version 1.0.

Ultimate beneficial ownership verification

The ultimate beneficial ownership verification requirements depend on the user’s business type.

Private Companies

Stripe defines and attempts to identify any individual with 25% or more ownership as the ultimate beneficial owner (UBO). We recommend using Stripe-hosted or Embedded Onboarding to allow your users to preview and confirm the owners. Alternatively, you can collect and add all UBOs to the account as Persons with the owner relationship.

If Stripe can’t determine these individuals, a company must submit a proof of ultimate beneficial ownership document to attest to their ownership structure. This must include proof of ownership documents for any holding companies owning 25% or more shares of the connected account. Stripe-hosted or embedded onboarding automatically seeks to collect these documents, or you can collect and submit them using the Accounts API. You must add all UBOs listed on the proof of ultimate beneficial ownership to the account.

Partnerships

Partnerships must verify the relationship between the business and all partners, managers, and any other individual with 25% or more ownership. You must add all such people to the account as Persons with the owner relationship.

Exemptions

In certain situations, a business entity might not need to declare its ownership. To qualify for an exemption, you must provide a legitimate reason in the company.ownership_exemption_reason field. Valid reasons for exemption include:

• qualified_entity_exceeds_ownership_threshold: If a government, publicly listed company, or financial institution owns at least 75% of the business, the business is exempt from providing ownership details.
• qualifies_as_financial_institution: Businesses that are financial institutions regulated by the Monetary Authority of Singapore are exempt from sharing ownership details.

After submitting an exemption reason, we review the business entity’s details. During this review, the requirement moves to requirements.pending_verification. If Stripe determines that the business entity doesn’t qualify for the exemption, we display an error message, and the ownership requirement remains:

{
  "id": "{{CONNECTED_ACCOUNT_ID}}",
  "requirements": {
    "past_due": [
      "documents.proof_of_ultimate_beneficial_ownership.files",
    ],
    "alternatives": [
      {
        "original_fields_due": [
          "documents.proof_of_ultimate_beneficial_ownership.files",
        ],
        "alternative_fields_due": [
          "company.ownership_exemption_reason",
        ]
      }
    ],
    "errors": [
      {
        "code": "verification_rejected_ownership_exemption_reason",
        "reason": "The ownership exemption reason was rejected.",
        "requirement": "company.ownership_exemption_reason"
      }
    ],
    ...
  },
  ...
}

Integration details

You must add UBOs and directors to the account with the owner or director position in the API. Private companies, private partnerships, and non-profits require proof of beneficial ownership. When we can’t successfully verify the UBO, you need to collect an ID Document for the unverified UBO.

If Stripe determines that the account is missing owners, directors, or documentation of holding companies, the documents.proof_of_ultimate_beneficial_ownership.files field will be returned in requirements. You can find a complete list of acceptable documents at Acceptable Verification Documents.

Additionally, you could be asked to attest that the list of directors is current and correct by setting the following fields in the API:

• company.directorship_declaration.ip
• company.directorship_declaration.date
• (Optional) company.directorship_declaration.user_agent

If a discrepancy in your list of directors is detected, Stripe might request a new declaration by returning the company.directorship_declaration.ip and company.directorship_declaration.date requirements in the requirements field.

Both Stripe-hosted and embedded onboarding display a list of missing owners and directors, and the account user can add them to their account by clicking on them. Adding the suggested individuals fulfills the UBO requirement for companies without any holding companies in their ownership structure. For companies with holding companies, Stripe attempts to verify their owners. If we can’t, we prompt the account user to upload either an ultimate beneficial owner attestation document or relevant ownership documents to determine the account’s ultimate beneficial owners. (This also applies to other business types, such as non-profits.)

Accounts with missing beneficial owners have a verification_missing_owners error code in the errors hash of requirements. Similarly, accounts with missing directors have a verification_document_directors_mismatch error code. Lastly, accounts where Stripe requires additional information regarding their ownership have a verification_requires_additional_proof_of_registration error code.

{
  "id": "{{CONNECTED_ACCOUNT_ID}}",
  "requirements": {
    "past_due": [
      "documents.proof_of_ultimate_beneficial_ownership.files",
    ],
    "errors": [
      {
        "code": "verification_missing_owners",
        "requirement": "documents.proof_of_ultimate_beneficial_ownership.files",
        "reason": "..."
      },
      ...
    ],
    ...
  },
  ...
}