1. About this Framework
1.1 Purpose
This Schedule sets out the identity verification framework that governs what each Member must verify, when, and what each level of verification unlocks. The framework is risk-proportionate: low-risk participation (joining a Circle, posting in the Plaza, building a Standing record) is open with a minimal level of verification; higher-risk activity (administering funds as a Treasurer, receiving payouts from cross-border Circles, accessing higher-trust verified records) requires correspondingly higher verification.
1.2 Regulatory posture
Circlworld is not a custodian of Member funds. Where Treasurers operate dedicated accounts, those accounts are held by Members directly with regulated payment institutions (banks or credit unions); Circlworld is the payment-services interface, not the account-holder. The identity verification framework here reflects the platform's own risk obligations under UK money laundering regulations and the equivalent regimes in the jurisdictions Circlworld operates in. Where partner banks, lenders or employers impose higher verification standards for their own purposes (for example, opening a bank account as a Circle), those institutional requirements operate alongside this framework, not as part of it.
1.3 Identity verification provider
Circlworld uses Didit as its identity verification provider for Levels 2 through 4. Didit performs document authentication, biometric matching, and watchlist screening against published sanctions and politically-exposed-person lists. Members upload their documents to Didit directly; Circlworld receives the verification outcome (pass / fail / refer for manual review) plus the structured data fields necessary to record the verification level achieved. Document images are retained by Didit per its own retention schedule and are not stored on Circlworld systems.
2. The four levels
2.1 Level 0 — Account verification (open)
The minimum verification any Member completes at sign-up. No documents required.
Verified: email address (clicked confirmation link), phone number where provided (SMS code), name as self-attested.
What it unlocks:
- Browsing and reading Circlworld
- Posting in the Plaza and Forum
- Joining the Crossroads and expressing interest in Circles
- Standing record begins building from observed activity
Not unlocked: participating in any Circle that handles money; receiving any payout; being matched to a Treasurer for an active Circle.
2.2 Level 1 — Basic identity (default for active Members)
The default level for any Member actually participating in a Circle.
Verified: government-issued photo identity document (passport, national ID, or driving licence), liveness check (selfie matched to the document photograph), residential address (utility bill, bank statement, or government letter not older than three months).
Provider: Didit document + liveness flow.
What it unlocks:
- Joining and participating in any Circle as a contributing Member
- Receiving payouts up to £1,000 GBP equivalent per Circle cycle
- Being matched to a Treasurer at any tier
- Authoring peer attestations
- Holding an Explorer or Builder subscription tier
Source-of-funds: not required at this level.
2.3 Level 2 — Enhanced verification (for higher-value Circles + Pro tier)
Required when Members participate in Circles where individual cycle payouts exceed the Level 1 ceiling, or when the Member subscribes to Pro and uses cross-border Circle features.
Verified: everything in Level 1, plus:
- Confirmation of country of tax residence
- Source-of-funds attestation for any cycle payout exceeding £3,000 GBP equivalent (free-text Member declaration; not documentary at this level)
- Watchlist screening (sanctions lists, politically-exposed-persons lists) refreshed monthly
Provider: Didit enhanced flow.
What it unlocks:
- Cycle payouts up to £5,000 GBP equivalent
- Cross-border Circles (Pro tier feature)
- Sponsoring a family member's participation (Pro tier feature)
- Being matched to a Treasurer for higher-tier participation
2.4 Level 3 — Treasurer-grade verification
Required before any Member can act as a Treasurer administering a Circle.
Verified: everything in Level 2, plus:
- Detailed background screening (criminal record check at the level of disclosure permitted in the Member's jurisdiction)
- Professional referee check (two referees who attest to the Member's suitability for the Treasurer role)
- In-person or video interview with a senior Treasurer or platform representative
- Treasurer Code of Conduct acknowledgement
- Foundation Course completion in Circl Academy
Provider: Didit enhanced flow + Circlworld-managed referee + interview process.
What it unlocks:
- Acting as a Tier 1 Treasurer (Circle Treasurer) per the Treasurer Qualification Framework
- Receiving CGP allocations from active-Circle contributions via the compound subscription mechanism
- Higher Tier progression through the Member-voting attestation mechanism (Treasurer Tier Progression Charter v1.0)
Source-of-funds: documentary evidence required for any single transaction exceeding £10,000 GBP equivalent, regardless of whether the transaction flows through the platform or a partner bank.
2.5 Level 4 — Material-amount verification
Required only when a Member's combined platform activity over a rolling 12-month period exceeds material thresholds.
Verified: everything in Level 3, plus:
- Documentary source-of-funds evidence for the relevant transactions (pay slips, bank statements, asset disposal records, gift documentation, business accounts where applicable)
- Annual refresh of all Level 2 watchlist screening
- Tax-residence declaration with documentary support
- Where the activity is Treasurer-side: Multi-Jurisdictional Treasurer Certification (Treasurer Tier 4 → Tier 5 gating qualification)
Trigger thresholds (rolling 12-month):
- Cumulative Circle contributions or payouts exceeding £50,000 GBP equivalent
- Receipt of CGP allocations exceeding £25,000 GBP equivalent in a year
- Administration of Circles whose combined cycle value exceeds £250,000 GBP equivalent at any point in the year
What it unlocks:
- No additional product features — Level 4 is a compliance level, not a feature gate. Members at this level continue to use the platform with the entitlements of their subscription tier and Treasurer Tier as applicable; the verification is what Circlworld requires to operate compliantly at the activity volume the Member has reached.
3. How verification is requested
3.1 Just-in-time
Circlworld requests the verification level required for what a Member is about to do, not in advance. A Member at Level 1 attempting to join a Circle whose cycle payouts exceed £1,000 is prompted to complete Level 2 before the Circle commences. A Member at Level 2 applying to become a Treasurer is prompted into the Level 3 process at the point of application. This minimises the friction at sign-up and asks only for what is needed when it is needed.
3.2 Refreshes
Levels 2 and above refresh watchlist screening monthly (Level 2) or annually (Levels 3 and 4). Members do not need to re-verify documents at refresh; the refresh is a background check against the published lists. Where a refresh surfaces a hit, Circlworld will contact the Member to resolve before any account restriction is applied.
3.3 Failed verifications
A verification that fails is not, in itself, a restriction on platform participation at the lower level. A Member whose Level 2 verification fails can continue to participate at Level 1 in Circles whose cycle payouts stay within the Level 1 ceiling. Where Circlworld must restrict a Member account — for example, because a watchlist hit constitutes a hit on a regulated sanctions list — the restriction is communicated with the reason in plain language and the Member retains the right to challenge it through the Dispute Settlement Centre and through any external regulator with jurisdiction.
4. Data retention and rights
4.1 What Circlworld stores
Circlworld stores the verification level achieved per Member, the date of last verification, the data fields necessary to operate the entitlement framework (country of tax residence at Level 2; CGP allocation eligibility at Level 3; etc.), and a reference to the verification record at Didit. Circlworld does not store document images, biometric data, or the underlying personal data fields beyond what is necessary for the entitlement framework to function.
4.2 What Didit stores
Didit stores the document images, biometric template, and full verification record per its own retention policy. The Didit privacy notice is available at the time of verification and forms part of the consent flow. Member rights under UK GDPR (access, rectification, erasure where applicable, restriction of processing, data portability, objection) apply to data held by Didit; Circlworld will facilitate requests directed at Didit through the Help Office.
4.3 Erasure on account closure
When a Member closes their account, Circlworld removes the verification record from active systems and from the entitlement framework. The Member-Activity-Record archive retains a reference to the verification level achieved per cycle as part of the Member's audited participation record; this is retained for the period necessary to maintain the integrity of records issued to third parties (typically 7 years per the Member Activity Record Methodology). The retained record contains no document images, no biometric data, and no personal data beyond the level achieved and the cycle context.
5. Schedule changes
This Schedule may be amended to reflect changes in the regulatory framework, in the verification provider, or in the platform's risk thresholds. Material amendments (changes to the trigger thresholds, changes to what each level unlocks, addition or removal of a verification provider) are notified to Members at least 30 days before they take effect, with the prior version archived under /legal/archive for change-history.