Digital identity checks and the DVS register

Digital checks are allowed

Regulation 28 allows verification using electronic identification processes, as long as they meet the conditions in the Regulations, including being secure from fraud and misuse.

What HMRC says

Any digital verification service provider which is not on the DVS register cannot reliably be deemed suitable for identity verification in compliance with the Regulations.

What the CCAB guidance says

Paragraph 5.5.12 of the CCAB guidance says digital verification services must be on the GOV.UK register of certified services to be used for these checks, and that services not on the register cannot reliably be deemed suitable. It says a firm would then need to obtain paper documents instead.

Paragraph 5.5.13 adds that the brand name of an electronic checking provider may not appear on the register even though the software it uses does. In that case, the guidance suggests getting confirmation from the provider, ideally in your contract with them.

How to check a service

• Search the digital verification services register for the provider's name.
• If the name isn't there, ask the provider in writing which registered service carries out the check.
• Keep a note of what you checked and when, as part of your records.