Additional customer data requirements for 01 February 2026

DATE: September 11, 2025

AUTHOR: The Product team at Griffin

Due to regulatory requirements, we need our customers to collect additional information from your own customers (see below) and to share it with us by 01 February 2026. This affects all of your new and existing customers with dedicated Griffin bank accounts (savings accounts, embedded bank accounts, dedicated safeguarding, dedicated client money). This does not affect members of a pooled account or bare trust savings.

This does not affect you if you only use our sandbox and do not have access to a live organisation.

Why are we asking for this?

We’re asking for this additional information to comply with requirements set by His Majesty's Revenue and Customs (HMRC), the Bank of England and the Prudential Regulation Authority (PRA), as well as the requirements set out in the United States' Foreign Account Tax Compliance Act (FATCA).

What you need to do

We've broken this down into three stages:

Stage 1 | Collect - if you don't already, start collecting the additional information (see below) from new and existing customers. Start as soon as possible.
Stage 2 | Send - send the information to us via API through your existing Griffin onboarding workflow. Start as soon as possible.
Stage 3 | Switch workflow - switch to a new Griffin onboarding workflow which mandates the additional information. More details coming soon.

All three stages must be complete by 01 February 2026.

Timeline

Now: Start collecting and sending data (stages 1 and 2)
Coming weeks: We'll share details about stage 3 and offer one-to-one support sessions
01 February 2026: Deadline for all stages to be complete

Stage 1 - collecting additional information

This applies to your customers with any of these account types:

Savings account
Dedicated client money account
Dedicated safeguarding account
Embedded bank account

Note: We do not need this information for members of pooled accounts or bare trust savings.

Additional information we need

For Individuals:

Tax residencies (all countries)
US citizen status
Tax identification number (TIN) for each country
Risk rating (if you use Reliance)

For Sole Traders:

Tax residencies (all countries)
US citizen status
Tax identification number (TIN) for each country
SIC (Standard Industrial Classification) code
Business size
Risk rating (if you use Reliance)
Balance sheet size (optional)
Number of employees (optional)

For Limited Companies:

For the Directors and Persons with significant control:
- Tax residencies (all countries)
- US citizen status
- Tax identification number (TIN) for each country
For the company entity:
- SIC (Standard Industrial Classification) code
- Business size
- Risk rating (if you use Reliance)
- Balance sheet size (optional)
- Number of employees (optional)

If you have questions about the information and the format, you can see our FAQs at the link below or reach out to us at support@griffin.com.

FAQs

Stage 2 - sending us the additional information

You can send us the data today through our existing API:

List the claims (data fields) - See the API reference linked here
Update customer information - Follow the guides in the documentation, for example this guide for individuals linked here

Stage 3 - integrate with a new onboarding workflow

The new onboarding workflow will be released by 01 November 2025, at which point you can decide when to switchover before 01 February 2026. We'll be in touch with more updates between now and 01 November 2025.

Questions?

We're here to help. Our product and engineering teams will be reaching out over the next few weeks to schedule one-to-one support sessions. In the meantime, just reach out at support@griffin.com or get in touch with your Customer Success manager.

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