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Updated: 10 June 2025

Qualified Electronic Signatures

BSA response to DSIT Call for Views on Authorised Trust Service Providers

Overview

Digital Identity

Policy page on the practical application of digital identity in financial services, in particular the Department for Science, Innovation and Technology's (DSIT) attempts to introduce a reusable digital identity token for identity and verification within financial services. The latest version (Gamma) of the Digital Identity and Attributes Trust Framework (DIATF) was published in November 2024 and can be found here

The basis of the DIATF is the Government's Good Practice Guidelines (GPG45)

Supplementary Codes replacing external Schemes

Following the publication of the Data (Use and Access) Bill in Autumn 2024, the Government revealed it is taking a different approach in terms of how different sectors use the DIATF. 

Previously, DSIT and Office for Digital Identity and Attributes (OfDIA)  had taken the approach of licensing external "schemes" to build their own standards on top of the DIATF. This approach has now been scrapped.

Where an additional sector specific standard is requested (such as mandating a certain level of confidence under GPG45 for a specific process) OfDIA will consult with the wider sector whether an additional Supplementary Code is required to be added to the DIATF. 

Where OfDIA identifies that there is a need for a Supplementary Code, it will be added to the DIATF.

Reusable Digital Identity propositions

Reusable digital identity propositions such as MyIdentity, SelectID, and firms developing reusable digital identity as part of legal or data services, will continue to be able to provide services under the new regime. 

Select ID has been developed for the general financial services sector as a reusable digital identity market place. 

MyIdentity scheme was being developed by Etive for the Home Buying and Selling process and was working with a growing number of building societies, specialist lenders, the Home Builders Federations (HBF) and intermediary groups to develop reusable digital identities. The BSA understands that scheme is currently on hold. 

Qualified Electronic Signatures

DSIT Call for View on Adoption of Trust Services 
September 2025 - The Department for Science, Innovation and Technology (DSIT) has sent out a Call for Views on Adoption of Trust Services. Qualified Trust Service Providers (QTSPs) are authorised providers of Qualified Electronic Signatures (QES). The BSA has put together the below response, with the following key points:

  • QTSPs are authorised in the EU not the UK. Creating a list of authorised trust service providers able to operate in the UK would improve visibility of the commercial propositions available in the market 
  • Use (and knowledge) of QES within the wider market is at a low level
  • There are concerns about a lack of case law around usage of QES
The BSA's response can be found here, any further comments please email robert.thickett@bsa.org.uk

HM Land Registry carries out second pilot on QES
May 2025 - HM Land Registry has updated lenders and conveyancers that it has addressed the technical challenge that stopped it from accepting Qualified Electronic Signatures (QES) and is now actively promoting QES within the sector. It has shared the below slides with the conveyancing sector on how it envisages conveyancers using QES to sign the TR1 document. 
April HMLR - QES - A guide for signing documents

Digital Identity Work Group - DPMSG

In summer of 2024 the Digital Property Market Steering Group (DPMSG) set up a new Digital Identity Working Group (DIWG) to help shape the Government's work on developing a reusable digital identity in the property buying process.

Jointly led by the BSA, UK Finance and PEXA, the group is working with the Office for Digital Identity and Attributes (part of Department of Science, Innovation and Technology) to encourage adoption within the housing sector of the Digital Identity and Attributes Trust Framework as an industry standard for digital identity and identify whether a supplementary code specific for the housing market is required. 

Ongoing work with OfDIA

OfDIA is of the opinion that the existing DIATF is sufficient for the property sector, but is developing a gap analysis tool to surface whether particular parts of the property market require a supplementary code. 

Feedback request for new Digital Identity Working Group

August 2024 - The Digital Identity Working Group (DIWG) requested feedback to the below 4 questions from the wider property sector (estate agents, conveyancers, mortgage brokers, mortgage lenders) to help identity what the property industry would require to adopt a single digital identity standard.

Questions:

  •  What would ‘good’ look like for a unified digital identity scheme to be adopted across the industry?

  • What are the potential blockers/challenges for implementation of a reusable digital identity?

  • Are there specific levels of complexity in the homeowner journey in relation to sharing, consumer self-sovereignty (authority to share), time that ID can be held by an entity etc?

  • Are there any specific reasons why a unified standard for digital identity would be a concern for your organisation?

The BSA's response can be found using the below link:

BSA feedback to Digital Identity Working Group questions Aug 2024

MyIdentity and SelectID - reusable digital identity propositions

MyIdentity Pilot gains access to the FCA's regulatory sandbox

March 2022 - The MyIdentity digital identity scheme has been accepted on the FCA's regulatory sandbox - more information can be found here

BSA MyIdentity Pilot presentation - recording and slides

1 Feb 2022 - Digital ID scheme provider eTive and specialist lender Bluestone Mortgages provided a presentation to BSA members on 1 February on the MyIdentity Digital ID pilot. Link to the recording and slide are below. Any further information, please email robert.thickett@bsa.org.uk

Mortgage lender joins MyIdentity pilot

Specialist mortgage lender Bluestone Mortgages has joined the MyIdentity digitial identity scheme pilot. The full press release is available here. Using the MyIdentity scheme, home buyers can verify their identity and then share it with all participants in the house buying process (estate agent, broker, conveyancer, lender etc) as part of their respective KYC processes.

Bluestone Mortgages and scheme providers eTive will be speaking at the BSA's webinar about the MyIdentity scheme pilot on Tuesday 1 February. The webinar is open to all BSA members, if you would like to attend, please email robert.thickett@bsa.org.uk.  

BSA virtual webinar on MyIdentity pilot on Tuesday 1 February 2022

Dec 2021 - The BSA will be hosting a webinar on Tuesday 1 February 2022 to update members on the MyIdentity pilot (formerly eTive) which is looking to develop an interoperable digital ID scheme for the homebuying and selling process. 

The MyIdentity digital ID scheme has been set up by a company called eTive and is designed to be one of multiple schemes sitting under the Government's Trust Framework for digital ID. Using MyIdentity, consumers will be able to share a digital ID with estate agents, brokers, conveyancers and lenders. 

The pilot currently has 5 participating IDSPs, two mortgage lenders (Bluestone and United Trust Bank) and a number of estate agents, conveyancers and mortgage brokers. 

In addition to a presentation eTive, we are also looking to have representation from two of the participating firms (TBC in January).

If any member would like to attend the webinar, please email robert.thickett@bsa.org.uk.

MyIdentity Pilot launches with participating EAs, Mortgage Brokers, Conveyancers and Lenders

Nov 2021 - eTive's MyDigitalID pilot is now live with participating estate agents, mortgage intermediaries, conveyancers and two lenders (Bluestone Mortgages and United Trust Bank). 

Firms will be testing how consumers can share the interoperable digital ID between firms. The BSA understands that eTive is also looking to augment the identity with Open Banking data to evidence proof of funds, which is helpful for estate agents and conveyancers. It is also working with a leading supplier of Poli

eTive has also participated in a video with Legal & General explaining MyDigital ID - see here

The BSA is sitting the Governance committee for MyIdentity along with UK Finance. If any society would like any more information about this, please email robert.thickett@bsa.org.uk

Homebuying and Selling Trust Scheme rebrands as MyIdentity and launches pilots

Aug 2021 - The Homebuying and Selling Trust Scheme has been rebranded as MyIdentity and the scheme manager eTive has published details about its first pilot, which can be found here

Estate agents, licensed conveyancers, solicitors and mortgage intermediaries operating in 11 locations will be the first to take part in the trials over the next 12 months..

The 11 locations are Battersea, Chiswick, Clapham, Putney, Wimbledon, Richmond, Kew, Cheltenham, Gloucester, Harrogate and York. 

eTive is actively looking for lenders to take part in the scheme - if any members are interested in taking part, please email robert.thickett@bsa.org.uk

Digital Identity Trust Scheme Version 2.2

MyID - a Guide for Financial Services (2021)

Key stakeholder event for FS Digital ID Scheme on 11 May

On 11 May 2021 between 14:00 to 16:00, TISA will be hosting a workshop to validate its approach to the Digital Identity Trust Scheme it is setting up for the financial services. 

If you would like to attend, please email Marita.Holland@tisa.uk.com.

Areas to be covered will include:

  • Introductions 
  • Demo of the prototype journeys 
  • Technical approach 
  • Benefit analysis
  • Commercial model 
  • Opportunities to engage 
  • Next steps 

Progress updates on Homebuying and FS Digital ID Schemes

Both eTive and TISA are continuing to develop and test its digital ID propositions for the Homebuying and Selling process (eTive) and general financial services (TISA). Both companies are bringing together ID Providers (IDPs), lenders, brokers, conveyancers and a range of different regulatory stakeholders to input into the process. 

Presentations on Homebuying Digital ID scheme (eTive and FS Digital ID scheme (TISA)

In January 2021 the BSA's Digital Innovation Panel hosted two separate presentations from the main digital ID schemes focused on the building societies sector. 

Please click on the below links to view the video and slides from each presentation:

Homebuying and Selling Digital Trust Scheme (eTive) January 27 2021

Video 

Slides

eTive has also answered a number of questions submitted by members about digital identity in the below Q&A:

FAQ

Financial Services Digital ID Scheme (TISA) January 28 2021

Video

Slides

HM Land Registry Digital Identity Standard

Publication of final HMLR Digital ID Standard

HM Land Registry has published its own digital identity standard following a consultation in 2020. The standard builds on existing anti-money laundering (AML) guidance and the Government's own Good Practice Guidelines on digital identity (GPG45)

The full standard can be found using the below link:

Practice Guide 81: encouraging the use of digital technology in identity verification

More information can be found on HMLR's website here, but key elements include:

  • Cryptographic biometric requirement from either smart phone or UK epassport (issued from 2006 onwards) 
  • Alignment with GPG45 on AML/KYC guidance
  • Acceptance that digital solutions linking clients with a specific property are not yet in the market, although Open Banking viewed as a promising source of validation
  • HMLR is exploring the idea of a list of certified ID providers in the market who meet the requirements of its Standard
  • It is working with the Department for Digital, Culture, Media and Sport (DCMS) on the development of its Trust Framework and a specific digital ID for the Homebuying and Selling process 

Regulatory guidance on Digital ID - FCA, JMLSG, LSAGAML

Financial Conduct Authority 

15 Feb 2021 - 'Unleashing the potential of Digital ID: a sandbox observation' - The FCA discusses the current challenges and opportunities for Digital ID and provides insights from its Sandboxes where it has tested Digital ID propositions. 

It says despite AML rules allowing customer/client due diligence to outsource the delivery of checks to someone who isn’t liable to AML rules, like a digital ID provider, fear of civil or criminal liability was stopping firms adopting these tools. 

This issue was highlighted in the FCA’s Sandbox tests and AML rules had been changed to make it explicit that electronic identification processes could be used including digital ID solutions where these are independent of the person whose identity is being verified.

6 May 2020 - Financial crime systems and controls in the Coronavirus situation - In response to the first Lockdown, the FCA provided an update on how firms should manage their financial crime obligations in the pandemic. This included a section on client identity verification and flexibility in existing requirements. The page no longer applies as of 7 February 2021 but can be viewed here

Joint Money Laundering Steering Group (JMLSG) 

Section 5.3.29 to 5.3.53 of Part 1 of the JMLSG's guidance - 'Characteristics and evidence of identity' - talks through the steps firms should take to satisfy their own client due diligence (CDD). Section B - Electronic Evidence and Digital Identity - 5.3.79 to 5.3.84 explicitly states that firms can use electronic verification services. 

Legal Sector Affinity Group - Anti Money Laundering Guidance 

The Legal Sector Affinity Group, representing all major legal bodies, provides guidance on the usage of electronic verification and digital ID. Regulations cover use of technology (specifically EID/&V), training and client due diligence (CDD). The latest guidance can be found here and is the basis of the updated financial fraud guidance for conveyancers in the BSA's mortgage instructions. 

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