Digital identity verification has been quietly reshaping how conveyancers carry out AML checks for several years.
In December 2025, it took a significant step forward: the Digital Verification Services Trust Framework was placed on a statutory footing under the Data (Use and Access) Act 2025.
For this ‘Five Minutes on…’, we take a deep dive into what that means and what it changes for your firm.
What changed when the DVS Trust Framework became law?
For several years, digital identity providers operating in the UK worked within a voluntary framework, a set of standards published by the government against which they could be assessed and certified. Choosing a certified provider gave conveyancers confidence that the technology met a recognised benchmark, but certification was optional and the framework carried no statutory weight.
That changed in December 2025. Under the Data (Use and Access) Act 2025, the Digital Verification Services (DVS) Trust Framework became a statutory framework, the first of its kind in the UK. Providers of digital identity services can now apply to be formally registered by the government, and that registration carries legal backing that was previously absent.
For conveyancers, this matters. The tools used to verify client identities are increasingly subject to a formal, legally grounded standard, rather than just an industry benchmark.
What is the DVS Trust Framework and how does it work?
The DVS Trust Framework sets out the rules and technical requirements organisations must meet to provide digital identity and attribute verification services in the UK. It covers how identity data is collected, checked, and stored, what security standards apply, and how providers must handle fraud, errors, and complaints.
Providers that meet these requirements can apply to be listed on a government register of certified DVS providers. That register is publicly accessible, meaning conveyancers, law firms, and their clients can check whether a given identity service is formally recognised.
The framework is overseen by the Office for Digital Identities and Attributes (ODIA), within the Department for Science, Innovation and Technology.
How does the DVS Trust Framework compare to HMLR Safe Harbour?
The DVS Trust Framework and the HMLR Safe Harbour standard are related but distinct, and it is important to understand the difference.
Safe Harbour is HM Land Registry’s standard for identity verification in property transactions, introduced in 2021. It sets out specific requirements around biometric checks, NFC chip reading, and evidence of connection to a property. Meeting those requirements means HMLR will treat the conveyancer as having taken reasonable steps to verify identity, providing protection if fraud later comes to light.
The DVS Trust Framework operates at a different level. It governs the identity providers themselves, the platforms conveyancers rely on to carry out checks. A provider listed on the DVS register has been assessed against the government’s standards. Using a registered provider does not automatically mean Safe Harbour has been achieved, but it is a strong indicator that the underlying technology meets a credible, legally recognised standard.
In practice, the two often work together. A conveyancer using a DVS-registered provider to carry out biometric and NFC checks in line with HMLR requirements will be well positioned on both fronts.
What does the DVS Trust Framework mean for conveyancers?
For most firms already using a reputable digital ID provider, the immediate practical change is modest. If your current provider was certified under the previous voluntary framework, they will likely be working towards registration under the statutory version, or may already have it.
The more meaningful shift is what the framework signals for the future. Making DVS statutory reflects a broader government intention to establish digital identity as a trusted, legally grounded part of UK infrastructure. Lenders, regulators, and professional bodies are likely to place increasing weight on whether firms use registered providers.
It is worth checking whether your digital identity provider is listed on the government’s DVS register, or has confirmed its intention to register. If you are evaluating new providers, DVS registration should form part of that assessment.
What has not changed under the DVS Trust Framework?
The DVS Trust Framework does not make digital identity verification compulsory. Manual identity checks remain legally permissible, provided they meet the requirements of the Money Laundering Regulations.
It also does not replace the HMLR Safe Harbour standard, or make it compulsory. Safe Harbour remains optional. However, as expectations around identity verification continue to rise, the practical case for meeting it becomes stronger.
Taken together, the DVS Trust Framework marks a shift towards more formalised standards for digital identity verification. Now set in law under the Data (Use and Access) Act 2025, it establishes the criteria providers must meet to be listed on the government’s public register, giving conveyancers a clearer way to assess whether a provider is formally recognised.
While DVS registration and HMLR Safe Harbour serve different purposes, one governing providers and the other the verification process, they are closely connected in practice. Using a DVS-registered provider does not automatically mean Safe Harbour has been achieved, but it provides a strong foundation.
Importantly, digital identity checks remain optional, and manual verification is still permissible, though expectations are clearly evolving. As a result, firms should be considering whether their current provider is registered, or actively working towards it.
