Practice guide 67: evidence of identity

Question 1

1. Introduction

Accepted Answer

To reduce the risk of registration fraud, HM Land Registry relies on the steps that conveyancers take, where appropriate, to verify the identity of their clients.

In certain circumstances HM Land Registry requires an application to include confirmation of identity or rule 17 identity evidence. This helps us to decide what checks, if any, we may need to take before completing a registration.

This guide explains when confirmation of identity or rule 17 identity evidence is required and how it should be given.

The information in this guide relates only to the evidence of identity that must be given to HM Land Registry. It does not deal with identity checks required by regulatory or representative bodies, or required by law, such as under the money laundering legislation.

If, when lodging an application, you dishonestly provide information or make a statement that you know is, or might be, untrue or misleading, and intend by doing so to make a gain for yourself or another person, or to cause loss or the risk of loss to another person, you may commit the offence of fraud under section 1 of the Fraud Act 2006, the maximum penalty for which is 10 years’ imprisonment or an unlimited fine, or both.

Our requirements are not intended to impose any new liabilities on conveyancers. HM Land Registry has a statutory right of recourse to recover amounts paid for indemnity under paragraph 10 of Schedule 8 to the Land Registration Act 2002 but this right is not used automatically or routinely. The right of recourse will not be used where a conveyancer has been neither fraudulent nor negligent.

Please note that your application will, depending on the circumstances, be cancelled if identity evidence is not provided when this is required.

Question 2

2. Confirmation of identity or rule 17 identity

Accepted Answer

HM Land Registry require this to prevent registration fraud.

Land and buildings are usually the most valuable assets people own. They can be sold and mortgaged to raise money and can therefore be attractive targets for fraudsters. HM Land Registry and others involved in property-related transactions have procedures in place to safeguard against fraud and the requirement for confirmation of identity for certain types of transactions and applications help us to do this.

In most instances of fraud it is the purported disponor, rather than the applicant, who acts fraudulently. To tackle fraud effectively, we consider that it is essential that the identity of the disponor (and certain others) be verified before transactions take place and, therefore, that conveyancers lodging applications for registration should provide evidence of this.

So, as a conveyancer, in respect to most transactions you may be affected by our identity requirements in 2 ways.

as the conveyancer sending an application to HM Land Registry on behalf of a client
as a conveyancer providing evidence of identity for an unrepresented person involved in a transaction, - using form ID1, form ID2 or form ID5.

A non-conveyancer providing evidence of identity for an unrepresented person involved in a transaction will need to complete form ID3.

Form ID4 (for corporate bodies) was withdrawn on 5 February 2024.

Form ID4 will not be accepted for applications lodged on or after 6 May 2024.

Question 3

3. Definitions

Accepted Answer

3.1 Conveyancer

When we refer to a ‘conveyancer’ we mean an authorised person within the meaning of section 18 of the Legal Services Act 2007 who is entitled to provide the conveyancing services referred to in paragraphs 5(1)(a) and (b) of Schedule 2 to that Act, or a person carrying out those activities in the course of their duties as a public officer. It also includes an individual or body who employs or has among their managers such an authorised person who will undertake or supervise those conveyancing activities (rule 217A of the Land Registration Rules 2003). Please note that to come within the definition of conveyancer in rule 217A of the Land Registration Rules 2003 an individual must be authorised under the Legal Services Act 2007 to provide conveyancing services; in effect they must have a practising certificate.

We will accept verification of identity in forms ID1 and ID2 by a Scottish solicitor.

A paralegal is not a conveyancer. A paralegal is someone who assists legal firms – they may sign application forms on behalf of a conveyancing firm that is an authorised person if they are authorised to do so by that firm. They cannot, however, verify identity.

Not all Chartered Legal Executives are conveyancers, only those who have been authorised by CILEx Regulation to undertake reserved instrument activities. We have agreed with the Chartered Institute of Legal Executives (CILEx) and CILEx Regulation, however, that all Chartered Legal Executives can verify identity even though some may not be conveyancers.

While all Chartered Legal Executives may verify identity, only CILEX Conveyancing Practitioners can provide certificates to comply with Form LL restrictions. Please note that it is not sufficient for the person giving the certificate to describe themselves simply as CILEX Practitioner; this must always be CILEX Conveyancing Practitioner.

We have agreed with the Council for Licensed Conveyancers (CLC), that CLC-regulated licensed probate practitioners can verify identity even though they may not be conveyancers or solicitors.

3.2 Non-conveyancer

Our current practice allows a non-conveyancer to verify identity in form ID3 (see also Verification by non-conveyancer). For this purpose, a non-conveyancer is an individual from one of the following professions only.

Medical doctor
Dentist
Chartered or certified accountant
Regulated financial adviser
Member of Parliament
Member of the Senedd

We will keep this list under review and may add or remove certain professions if it is considered appropriate to do so.

See Evidence as to identity in form ID3 for further information on professions that have been removed.

3.3 Confirmation of identity

Where the application is sent to HM Land Registry by a conveyancer, confirmation of identity involves the conveyancer providing details of a conveyancer (sometimes themselves) who represented the person in respect of which confirmation of identity is required.

In any case where that person was not represented by a conveyancer, the conveyancer sending the application must:

confirm that they are satisfied that sufficient steps have been taken to verify the identity of that person, or
enclose ‘evidence of identity’ in respect of that person, or
state the exemption from supplying identity evidence being claimed under Exceptions and enclose any evidence required

3.4 Evidence of identity

‘Evidence of identity’ (in the title to this guide and as used up to and including section 1, evidence of identity refers to both confirmation of identity and rule 17 identity evidence) is defined as evidence provided in accordance with any current direction made by the Chief Land Registrar under section 100(4) of the Land Registration Act 2002 for the purpose of confirming a person’s identity.

The current direction provides for either forms ID1 and ID2 where verification is by a conveyancer or forms ID3 where verification is by a non-conveyancer to be uploaded with the relevant application, unless an exception applies, see When confirmation of identity or rule 17 identity evidence is required. Additionally, form ID5 must be completed where a conveyancer has verified a person’s identity by way of an online video call.

For the purpose of this practice guide, when referring to the forms prepared and published under section 100(4), (forms ID1, ID2, ID3 and ID5) we will use ‘ID form(s)’.

3.5 Rule 17 identity evidence

Rule 17 of the Land Registration Rules 2003 allows us to ask for more documents or evidence to help us complete an application. We may cancel an application if you do not provide what we need. In this guide we use the term ‘rule 17 identity evidence’ to refer to the extra documents or evidence we may ask for.

We set out in this guide and elsewhere some instances where we are likely to ask for confirmation of identity or rule 17 identity evidence. However, we may require you to provide rule 17 identity evidence in other cases, sometimes even where a conveyancer has already confirmed they are satisfied that sufficient steps have been taken to verify someone’s identity.

You may find it difficult in practice to obtain identity evidence from a seller or other disponor after a disposition has completed. This may be the case even where the disponor has warranted they will do all they reasonably can to pass title to the disponee (as will usually be the case where a full or limited title guarantee has been given). We will not therefore ask you for additional evidence unless we are satisfied this is necessary or desirable.

In many cases we ask for rule 17 identity evidence because of the circumstances of an application rather than because of specific intelligence we have received. We often will not explain the exact basis for our concern. This helps protect our procedures from fraudsters. We do understand this may be frustrating and will prevent you from providing a full explanation to your client.

Question 4

4. When confirmation of identity or rule 17 identity evidence is required

Accepted Answer

Confirmation of identity or rule 17 identity evidence is required where indicated in the following table. Exceptions A to E referred to in the table are described immediately after the note to the table.

Where you or another conveyancer have represented a person then the exceptions do not apply and you must, where confirmation of identity applies, provide details of the conveyancer’s name, address and reference, or, where rule 17 identity evidence is required, provide the equivalent information.

Application	Person in respect of whom confirmation of identity evidence or rule 17 identity evidence is required	Possible exceptions
1. Transfer of (i) a registered estate or (ii) a registered charge – application to register the transferee as proprietor. (Covers transfers whether or not for value, including those relating to the appointment or retirement of trustees and transfers under a power of sale. See also 2. Covers also assents by personal representatives)	- Transferor and transferee - An attorney of either	- Exception A - Exception B - Exception C - Exception D - Exception E
2. Surrender of a registered lease – application to close registered leasehold title. Note: The surrender will be an express transfer or a transfer by operation of law and so within 1 above.	- Landlord and tenant - An attorney of either	- Exception A - Exception B - Exception C - Exception D
3. Lease (whether or not for value) of a registered estate – application to register the lease.	- Landlord and tenant - An attorney of either Note: Confirmation of identity or rule 17 identity evidence is not required if a lease is merely being noted, or the application is merely to note easements in a non-registrable lease. electronic discharge	- Exception A - Exception B - Exception C - Exception D - Exception E
4. First registration of freehold or leasehold land – application based on compulsory first registration and triggering event is on or after 10 November 2008.	- Transferor and transferee or landlord and tenant - An attorney of either	- Exception A - Exception B - Exception C - Exception D - Where one of the three lost or destroyed title documents exceptions set out at 7 applies
5. Legal charge – application to register a legal charge¹of a registered estate or registered charge (a sub-charge of it) or on first registration of the land.	- Borrower⁴ and lender - An attorney of either Note: Confirmation of identity or rule 17 identity evidence is not required if a charge is merely being noted.	- Exception A - Exception B - Exception C - Exception D - Exception F
6. Discharge or release of a registered charge in paper form (form DS1 or DS3) – application to give effect to²	- Lender Note: For paper forms DS1 or DS3 used to discharge a registered charge, or for a deed of substituted security, evidence of identity is required for the lender, but not for the attorney of the lender or other agent.	- Exception A - Exception B - Exception C - Exception D
7. Voluntary application for first registration where the title documents have been lost or destroyed.	- Applicant for first registration as proprietor of the land - Any attorney of the applicant	- Exception B - Exception C - Exception D - The title documents were lost or destroyed while in the custody of the conveyancer sending the application. - The title documents were lost while in the custody of a major mortgage lender who is applying for registration because the title documents were being held as security for the lender’s mortgage³. - The conveyancer sending the application acts for a local authority, government department or nationally well known body which is applying for registration because title documents relating to their land, or to land on which they hold a mortgage, were lost while in their custody.
8. Application to alter the register following an individual’s change of name by deed poll, statutory declaration or statement of truth.	- The person who has changed their name (in their new name)	- Where the application is combined with any other application. But if the application is one within 1 to 7 above, then evidence of change of name may be required as part of the requirements for those applications.

¹ This table sets out the requirements where a conveyancer lodges the application with HM Land Registry. There is another exception to 5 but it applies where the Legal Aid Agency makes the application in its own name to register a legal charge.

² This table sets out the requirements where a conveyancer lodges the application with HM Land Registry. There are 2 other exceptions to 6 but they apply where:

the lender:
- is the applicant and makes the application in its own name, as appropriate, and
- is a bank incorporated, or building society formed, in the United Kingdom
the Legal Aid Agency is the applicant and makes the application in its own name:
- to discharge a registered charge
- to release a registered charge

³An applicant is entitled to assume that a lender is a ‘major mortgage lender’ if the lender is a member of UK Finance or the Building Societies Association.

Note: In respect of any other application the registrar may in a particular case require evidence as to identity, under rule 17 of the Land Registration Rules 2003. We may also extend the requirement to other types of applications at short notice.

⁴Evidence of identity is not required for borrowers or guarantors who are not, or are not becoming, a registered proprietor.

4.1 Exceptions

In all cases below applicants must still account for the excepted party. This can be done by selecting the option in our digital services which confirms identity evidence is not required and uploading the relevant evidence according to the exception, as outlined below.

On first registration applications, the excepted party should still be included in panel 15(1) of the form FR1.

The exemptions relate to the additional evidence normally required when a party is not represented by a conveyancer.

A. The low-value exception

An ID form in respect of an unrepresented party is not required where the true value of the land which is the subject of the disposal, discharge or release is £6,000 or less. In these cases, the conveyancer must instead upload a certificate confirming the value of the land by someone qualified to give property valuations; such as an estate agent, a surveyor, a land and property valuer or auctioneer who holds a qualification from the Royal Institution of Chartered Surveyors or some other person who is similarly qualified.

You may still supply evidence of identity if you prefer and HM Land Registry reserves the right to require evidence of identity in form ID1 or form ID2, in any particular case.

B. The insolvency official, etc, exception

Forms ID1 and ID3 are not required in respect of someone who is acting in one of the following capacities:

as a trustee in bankruptcy, liquidator, supervisor, administrator or administrative receiver appointed under the Insolvency Act 1986
as a receiver under the Law of Property Act 1925
as a deputy appointed under the Mental Capacity Act 2005
as a guardian appointed under the Guardianship (Missing Persons) Act 2017

Please note that evidence of their appointment must still be uploaded with any application.

C. The not practicable exception

Situations may arise where it is not practicable to provide an ID form, such as where the parties exchanged contracts before 10 November 2008 (the day on which the requirement for confirmation of identity was introduced) without providing for these forms, or where a tenant has ‘walked away’ from their lease and application is now being made to close the leasehold title following its surrender by operation of law. In these or other situations the conveyancer who is lodging the application should upload a covering letter with the application explaining why they are not able to provide an ID form.

It may also not be possible to provide form ID1 or ID3 for a person who lacks capacity. However, where that person has made either a lasting power of attorney (or an enduring power of attorney that has not been registered with the Office of the Public Guardian) but it appears the person lacks capacity, HM Land Registry would require proof that the donor lacks capacity, such as a letter or report from a medical doctor. (Where the person has made an enduring power of attorney that has been registered with the Office of the Public Guardian, such medical evidence will not be necessary.) In all cases, identity evidence for the attorney would still be required.

Similarly, where a person is missing, we will not require evidence of their identity where an application is made relating to their property by a guardian appointed pursuant to the Guardianship (Missing Persons) Act 2017.

HM Land Registry does not consider ‘inconvenience’ sufficient reason for not providing an ID form. For example, the fact that a person is resident overseas is in itself not an acceptable reason. Please see Verification of identity of persons resident overseas for more information where a person is resident overseas.

Please also note that where contracts were exchanged on or after 10 November 2008 HM Land Registry would expect, where appropriate, provision to have been made for confirmation of identity or rule 17 identity evidence.

D. The HM Land Registry facility letter exception

HM Land Registry has issued facility letters in respect of the identity of a limited number of people who deal regularly with HM Land Registry. A copy of the facility letter may be uploaded with any application in place of an ID form in respect of such a person.

‘Facility letters’ are issued to private individuals and corporate bodies who regularly deal with low value (under £100,000) land transactions such as the sale of ground rents and souvenir land. The £100,000 limit relates to the value of the land involved in the transaction.

HM Land Registry is currently accepting applications for facility letters which will be valid for a period of 12 months. If a facility letter is to be renewed after the 12 months we will require a further form ID1 or form ID2 to be provided.

If approved, HM Land Registry’s Head Office will issue a facility letter to confirm the details of the arrangement. You should lodge a copy of the facility letter with applications for registration.

If you consider that your client may benefit from an arrangement, please contact the Commercial Arrangements Section at HM Land Registry’s Head Office for further advice as follows:

HM Land Registry Croydon Office
Commercial Arrangements Section
PO Box 2079
Croydon CR90 9NU

or

HM Land Registry Croydon Office
Commercial Arrangements Section
DX 8888
Croydon 3

Or you can email CommercialArrangements@landregistry.gov.uk

E. The retained evidence of identity (following HM Land Registry approval of a draft transfer or lease of part) exception

HM Land Registry provides a service for the approval of draft forms of transfers and leases of part for specific developments. For information about this please see practice guide 41, supplement 3: developing estates: registration services – approval of draft transfers and leases. Rule 17 identity evidence for any attorney acting for the transferor or landlord does not have to be uploaded with each individual transfer or lease for registration where, as part of this service, that evidence has been lodged with the draft for approval and has been retained by HM Land Registry.

F. Legal charge up to £10,000 to a local authority in respect of a service charge loan

No identity evidence is required for any party, including the applicant, where an application is made to:

register a legal charge to a local authority
the value of the charge as stated in the application or on the charge deed or application form is up to £10,000
the charge is in respect of a service charge loan and this is clearly stated within the application or the charge deed

A local authority may be required under the housing acts or other legislation to maintain and keep in repair the fabric of buildings, including those where a tenant has acquired a lease under the right to buy legislation. The authority is statutorily obliged to secure the cost of this work by way of a charge.

Question 5

5. Confirmation of identity

Accepted Answer

5.1 How to provide confirmation of identity

When making an application using our digital services, you will be prompted, when required, to input confirmation of identity evidence which will populate the application summary document.

If lodging a first registration, this information should be provided by completing the first box in panel 15(2) of form FR1). See Appendix: examples of completed identity panels.

If there is insufficient room in the panel, use form CS or include the information in a covering letter.

5.2 Discharges in paper form DS1 or releases in form DS3

We do not require confirmation of identity where a discharge is sent to HM Land Registry electronically, that is by EDs or e-DS1s.

Confirmation of identity for the lender is only required for discharges in paper form DS1 or DS3.

Conveyancers have stated that they do not usually act for a discharging lender when, for example, they act for a transferor on a sale. HM Land Registry’s view though is that as they are redeeming the transferor’s mortgage, are in touch with the lender, and are willing to transfer the redemption moneys to them, they must be satisfied that they are dealing with the right person and ought to be able to confirm to HM Land Registry or to a buyer’s conveyancer that they are satisfied that sufficient steps have been taken to verify the lender’s identity. If they are not willing to do this, we will require an ID form in respect of that lender.

Question 6

6. How to provide rule 17 identity evidence

Accepted Answer

6.1 Attorneys

Rule 17 identity evidence is usually required for any attorney mentioned in the table in When confirmation of identity or rule 17 identity evidence is required, except where one of the exceptions referred to in the table in section 4 applies.

You can do this in one of these ways:

by confirming that you are satisfied that sufficient steps have been taken to verify the attorney’s identity
by uploading form ID1 or form ID2 for the attorney (as to which see Completion of forms ID1 and ID)
by uploading form ID3 for the attorney (as to which see Verification by non-conveyancer)
by confirming one of the exceptions in Exceptions applies

The following wording is suggested for the certificate:

“I confirm that I am satisfied that sufficient steps have been taken to verify the identity of ………….., the attorney of ……………..”.

You could amend the certificate in the second part of panel 15 of form FR1. Although the Land Registration Rules 2003 do not provide for the amendment of the wording in prescribed forms, HM Land Registry will not reject or question any form FR1 amended in this way.

Please note that the donor of a power and their attorney are separate persons for the purpose of our identity requirements and confirmation of identity in respect of the donor and, usually, rule 17 identity evidence in respect of the attorney must be provided, except where this guide says it not required.

Evidence of identity (or the equivalent where rule 17 applies) will be required for either or both where they are not represented. Where a power of attorney has itself been made and executed by an attorney, you will need to provide rule 17 identity evidence for each attorney in the chain.

6.1.1 Why HM Land Registry requires rule 17 identity evidence for attorneys

Where an attorney is acting, HM Land Registry needs to be satisfied that they have sufficient powers to effect what they are purporting to do. We also need to be satisfied that the power under which they are acting is genuine and the attorney is who they claim to be. We consider this is both reasonable and necessary to prevent registration fraud.

HM Land Registry has always required evidence of the existence and scope of the power, and will accept either the power or a certificate in Form 1 to Schedule 3 to the Land Registration Rules 2003.

In addition to the above, we also require rule 17 identity evidence in respect of the attorney. It is not HM Land Registry which deals with a disponor or their attorney, it is the conveyancer acting for the applicant who does and is, therefore, better placed to satisfy themselves that they are dealing with the right person.

6.2 Voluntary applications for first registration where the title documents have been lost or destroyed

Rule 17 identity evidence in respect of the applicant for registration is required for all applications for voluntary first registration where the title documents have been lost or destroyed, except where one of the exceptions referred or set out at 7 in the table in When confirmation of identity or rule 17 identity evidence is required applies. This is so even where the applicant is represented and a conveyancer is lodging the application for registration.

As there will not have been a disposal triggering first registration, the wording in panel 15 of form FR1 may be changed to refer to the applicant, rather than, for example, the transferee.

For more information about applications for first registration where the documents have been lost or destroyed, see practice guide 2: first registration of title where deeds have been lost or destroyed.

6.3 Change of name

Rule 17 identity evidence is required where an application is being made to alter the register following a change of name by deed poll, statutory declaration or statement of truth and the application is not combined with other applications.

A standalone change of name application where the supporting evidence is a deed poll, statutory declaration or statement of truth must include either a certificate confirming that you are satisfied that sufficient steps have been taken to verify the person’s identity or evidence as to identity in form ID1 or form ID3.

The following wording is suggested for the certificate which must give the person’s current name:

“I confirm that I am satisfied that sufficient steps have been taken to verify the identity of ………….. and that they are the registered proprietor or the person named in entry number [X] in the register of title ……….”.

The certificate may be given in a covering letter and should be uploaded alongside the appropriate evidence of change of name.

As mentioned, if such a certificate cannot be given, then you should upload form ID1 of form ID3 completed in the new name as well as copies of official documentation to establish a link to the person named in the register. This might be a passport, driver’s licence or utility bill that shows the former name (as to which see Completion of form ID1 and form ID2 or Verification by non-conveyancer).

Question 7

7. Application is re-lodged by a different conveyancer to the one who lodged it originally

Accepted Answer

There will be occasions when an application which is withdrawn or cancelled is re-lodged for registration by a different conveyancer to the one who lodged it originally. This might happen, for example, following an intervention in the original conveyancer’s practice, where the original conveyancer has otherwise ceased to trade or where a party to a transaction has changed their conveyancer.

Where a firm has been intervened in, it is acceptable for their intervening agent, to show on the application form (FR1, AP1 or DS2) who originally acted for the parties - they do not have to show who acts for them currently - and include the evidence and statements as to identity as provided by the original conveyancer. The intervening agent should provide confirmation when relodging the application that if the original conveyancer has ceased to trade.

Where there has not been an intervention, the conveyancer lodging the application should always complete their application form to show who currently acts for parties, not who acted for them previously. It is not appropriate for the lodging conveyancer to say that a party is represented by the former conveyancer; they must state who acts for that party currently. HM Land Registry will accept, however, an identity form (form ID1 or ID2) verified by the former conveyancer or by another conveyancer provided it is no more than 6 months old at the time that the renewed application is made. We will also accept confirmation of identity where the lodging conveyancer confirms that sufficient steps have been taken to verify a party’s identity. If it is within the lodging conveyancer’s knowledge, they should also state if the original conveyancer has ceased to trade.

If you are unable to provide the above information as part of the application process in our digital services, uploading written confirmation of the above is acceptable.

Question 8

8. Completion of form ID1 and form ID2

Accepted Answer

You may submit either the original or a certified copy of the latest version of the ID form(s). Copy forms, however submitted, must always include both sides of the photo signed and dated on the reverse. Using an old version of the form may result in a requisition being raised.

8.1 Evidence as to identity in form ID1 and form ID2

If you are neither able to confirm that a conveyancer acted for them nor that you are satisfied that sufficient steps have been taken to verify their identity, you must provide evidence as to identity for each unrepresented person as explained in Confirmation of identity and How to provide rule 17 identity evidence. The evidence should be in form ID1 (for a private individual) or form ID2 (for a body corporate).

Both completed parts of form ID1 or form ID2 (and form ID5 where appropriate) lodged in support of an application must be dated and signed no more than 3 months before the time of lodgement. Our temporary guidance was to accept forms ID1 and ID2 that were dated up to 6 months before the application. We will continue to accept forms dated up to 6 months for applications made until 28 February 2023. After this date forms ID1 and ID2 must be dated within 3 months of the application.

Where a conveyancer verifies identity by way of a video call, they must complete form ID5 instead of section B or C of an ID1 or D2. The form ID5 must be kept with and lodged with the ID1 or ID2.

When completing section B the photograph to be attached to the form must be passport size, on photographic paper and in colour. The photograph must be signed and dated on the back by the conveyancer or professional who has verified the person’s identity. Applications submitted electronically will need to upload a scan of the front and back of the photograph in colour. We do not require the image to be of the same standard required by, for example, HM Passport Office. The person’s face must be clearly visible and it must not be more than 3 or 6 months old depending upon whether the application was lodged before or after the 28 February 2023, as above. ID forms may be rejected if this is not the case. If the verification was done by way of a video call and form ID5 is being completed, you must instead send us a screenshot, taken during the video call, see Verification by online video call.

Form ID1 can be used when identity is verified digitally meeting HM Land Registry’s digital identity standard. Where a conveyancer verifies identity digitally, section C must be completed, confirming that identity is verified under HM Land Registry’s digital identity standard- see practice guide 81: encouraging the use of digital technology in identity verification.

When completing section C, you should confirm what ID evidence was used to verify the ID and include the appropriate ID document number as part of the application.

Completed forms ID1, ID2 and ID5 are not open to public inspection and normally a person may not apply for an official copy of them (rules 133 and 135 of the Land Registration Rules 2003, subject to rule 140 – application in connection with court proceedings, insolvency and tax liability).

8.2 Verification of identity by a conveyancer

The identity of a person for whom form ID1 or ID2 is being lodged must be verified by an individual who is a conveyancer who must complete section B or C of the form. This can be any conveyancer. It does not have to be the conveyancer acting for any person relevant to the transaction. For example, if the transferor is unrepresented and needs to provide form ID1, it does not have to be the transferee’s conveyancer who verifies the transferor’s identity. The transferor can go to any convenient conveyancer for that purpose. Section B or C of an ID form should not be signed by an individual acting as an employee of a conveyancer unless that individual is a conveyancer in their own right.

Where a person’s identity is verified by way of an online video call, please see Verification by online video call.

HM Land Registry will contact conveyancers and other verifiers to check that a form completed in their name is genuine. It is therefore important for them to keep a record of anyone for whom they have verified identity and, if applicable, a duplicate of the photograph they have certified. If a verifier cannot confirm this, then a new ID form may be required. If the verification was done by way of a video call, the verifier must also take a screenshot of the person whose identity they verified during the call. The screenshot must accompany the form ID5 which should itself accompany the form ID1 or ID2. The conveyancer should also retain a copy with their records.

8.3 Verification of identity by a Chartered Legal Executive

We have agreed with CILEx and CILEx Regulation that all Chartered Legal Executives can verify identity even though some may not be conveyancers.

8.4 Verification of identity by a CLC-Regulated Licensed Probate Practitioner

We have agreed with the Council for Licensed Conveyancers (CLC), that CLC-regulated licensed probate practitioners can verify identity even though they may not be conveyancers or solicitors.

8.5 Verification of identity by a serving officer of the UK armed forces operating overseas

Where a member of the UK armed forces is serving overseas they can have their identity verified by an officer who is also serving with them overseas. In this situation the verifier must provide their passport number.

8.6 Verification of identity of persons resident overseas

Where a person is resident overseas and it is not possible for their identity to be verified by a UK conveyancer, section B of the form ID1 or form ID2 should be completed and signed by a lawyer or notary public qualified to practise in the person’s country of residence. The form must be accompanied by written evidence of the lawyer’s or notary’s authority to practise in their jurisdiction. If the evidence is not in English or Welsh, it must be accompanied by a certified translation into English or Welsh.

Form ID1 or ID2 will always be required.

8.7 Further support required

If you require further support because of your condition or circumstances, please contact us.

8.8 Corporate bodies

Corporate bodies can have their identity ‘stolen’ in the same way as private individuals, so our identity requirements apply to them in the same way. If you are verifying a corporation’s identity for the purpose of form ID2, you should always require the production of satisfactory evidence:

that the corporate body the individual represents and the registered proprietor or person entitled to be registered as proprietor are one and the same
that the corporate body still exists
that the individual representing them is authorised to act

8.8.1 Corporate bodies

In confirming a corporate body’s identity, you should take care to ensure that the party to a transaction is in fact the same body named in the register. For example, does the party to the transaction have the same company registration number, or other registration number appropriate for that type of body, shown in the register for the registered owner? If the names differ can you account for the change of name?

In the case of a company, has there been any recent change in the address of the registered office, or of the company’s officers? If changes have occurred can these be accounted for?

Is there any information in the company search, such as the date of the company’s registration, which might suggest that the party to the transaction cannot be the registered proprietor? The date of registration as proprietor is the date appearing in brackets immediately before the body’s name in the proprietorship or charges register. A discrepancy without any legitimate reason may be a risk factor.

8.8.2 Check if the corporate body still exists

Is there any indication that the corporate body has been dissolved? In the case of companies, a company search should always be made to ensure that the company still exists.

8.8.3 The individual’s connection with the corporate body

In confirming or verifying identity you will also need to establish the individual’s role within the organisation or their connection to it. Are they a director or the company secretary or do they have some agency relationship with the body, for example as their attorney? And what evidence have they produced to confirm this?

If they are not a director or the company secretary, have they produced any documentary evidence confirming their authority to act?

Please note that we do not require identity evidence for receivers, liquidators or administrators, as other evidence of their authority to act for a company will have to be uploaded with applications where they are involved.

8.8.4 Foreign corporations

If there is any indication in the register that the proprietor is a foreign corporation, are you satisfied that the party to the transaction is the same organisation? A company search will show if a UK company has been set up with the same name.

When dealing with a foreign corporate body that is not represented by a conveyancer, you should expect to see, for example, a letter from a lawyer authorised to practise in the country of the body’s incorporation confirming that it still exists and that the representative is authorised to act for them.

Question 9

9. Verification by non-conveyancer

Accepted Answer

You may submit either the original or a certified copy of the form ID3. Copy forms, however submitted, must not be altered and must always include copies of the personal details page from both people’s passports.

Form ID4 (for corporate bodies) was withdrawn on 5 February 2024 and will not be accepted for applications lodged on or after 6 May 2024.

9.1 Evidence as to identity in form ID3

If you are neither able to confirm that a conveyancer acted for them nor that you are satisfied that sufficient steps have been taken to verify their identity, you must provide evidence as to identity for each unrepresented person as explained in Confirmation of identity and How to provide rule 17 identity evidence.

In accordance with the direction made by the Chief Land Registrar under section 100(4) of the Land Registration Act 2002 for the purpose of confirming a person’s identity, the following forms must always be completed where the identity has been verified by someone in one of the authorised professions below.

Medical doctor
Dentist
Chartered or certified accountant
Regulated financial adviser
Member of Parliament
Member of the Senedd

For applications lodged on or after 6 May 2024 we will only accept the new version of form ID3 verified by one of the authorised professionals above.

The person verifying the identity and the person whose identity is being verified must not be related to each other in any way. They must also not be involved in the same transaction, for example, a person who is selling or assenting a property and who is also one of the authorised persons who can verify identity cannot verify the identity of the person acquiring the property.

9.2 Verification of ID by a non-conveyancer

A form ID3 must be no more than 3 months old when lodged with an application for registration.

All of the following conditions must be satisfied.

The person whose identity is to be verified and the verifier must both hold a current valid UK, Channel Islands or Isle of Man full passport.
They must have known each other for at least one year.
They must not be related to each other in any way.
They must not be involved in the same transaction.

In addition:

They must both provide a copy of the personal details page of their passport to HM Land Registry. Please note that where the verifier verifies the identity of more than one person, they must provide an equivalent number of copies of their personal details page to the number of people whose identities they have verified. A single copy for all the people is not acceptable.

Question 10

10. Verification by online video call

Accepted Answer

It is possible for conveyancers to check identity using an online video call.

The ability for non-conveyancers to verify identity by online video call was withdrawn on 5 February 2024. We will continue to accept old versions of the form ID3 and verifications of identity for a three-month transitional period. For applications lodged on or after 6 May 2024 we will only accept the new version of form ID3 and verifications that have taken place in person.

10.1 The video call

We are not prescribing any particular service, provider or device but care should be taken to use one that is secure.

Instructions can be found online for how to take a screenshot for the device being used.

10.2 Online video call verification by a conveyancer

Where verification is by a conveyancer for the purpose of completing a form ID1 or ID2, a screenshot must be captured of the person whose identity is being verified while the video call is taking place. A printed colour copy of that screenshot must be uploaded along with the form ID5 which must accompany the form ID1 or ID2.

The screenshot should only be of the person whose identity is being verified.

Question 11

11. Registry rejection and cancellation policy

Accepted Answer

HM Land Registry will not reject applications where evidence or confirmation of identity is completely missing until further notice. We still expect customers, however, to complete applications as correctly and as fully as possible. We will send a request for information (requisition) where the evidence or confirmation required is not provided on form AP1, form FR1 or form DS2.

Applications may be cancelled where evidence or confirmation of identity requested is not provided.

Question 12

12. Appendix: examples of completed identity panels

Accepted Answer

This example assumes the application is submitted by a conveyancer. Example entries are shown in italics.

The following guidance relates to form FR1 where the application is sent to HM Land Registry by a conveyancer, but the same principles apply to form AP1 and form DS2.

Panel 14

Confirm that you are a conveyancer.

Panel 15

In the first part of this panel, enter the full names of all persons for whom confirmation of identity is required in the first column. Do not use initials. Enter each party in a separate box (for example transferor, transferee, lender) – see Example 1. Where an attorney is acting, for the sake of clarity the attorney and donor must also be listed in separate boxes on the FR1– see Example 2. Place a cross in the second column against the name of any of these persons you represent. In the third column, either enter details of the conveyancer(s) who act for any of the other persons or if any are unrepresented insert ‘none’.

You will also need to complete the second part of this panel if you wrote ‘none’ to confirm that a person is not represented, unless one of the exceptions set out in When confirmation of identity or rule 17 identity evidence is required applies, in which case you should refer to the exception and provide the relevant evidence. For example, if exception C (not practicable to provide identity evidence) applies you should refer to it and provide the necessary covering letter.

Where an exception does not apply, then for each unrepresented person you must do one of the following:

confirm that you are satisfied that sufficient steps have been taken to verify their identity
enclose evidence of their identity in form ID1 or form ID2 (as to which see Completion of forms ID1 and ID2)
enclose evidence of their identity in form ID3 (see Verification by non-conveyancer)

If you are able to give the confirmation for some but not all of the unrepresented persons, you should insert the names of those persons for whom you are giving confirmation.