For years, digital conveyancing in England and Wales has had one stubborn blocker: signing deeds. You can run most of a deal online. You can share PDFs. You can even use compliant eSigning tools. Yet many firms still end up chasing a witness – or switching back to wet ink – right before completion.
That’s why HM Land Registry’s decision to accept qualified electronic signatures (QES) matters. This is not a small update to existing eSign guidance. In August 2025, HM Land Registry said it will accept land registration applications that include documents signed with QES. It also pointed out a key benefit: QES can remove the need for paper and a witness, while adding security.
If you work in conveyancing, you’ve likely asked the same thing: what changes in practice now that HMLR accepts QES? This article breaks it down. It also shows how to adopt QES without disrupting completion, counterpart habits, lender needs, or registration rules.
The Headline Change: Witness–Free Signing for Certain Registrable Deeds
HM Land Registry’s message is clear: it will now accept applications where key documents use QES. It also encourages lawyers and clients to start using it.
The impact is bigger than it sounds.
- With QES, the signer’s identity is checked as part of the signing process. That’s why HM Land Registry says a witness is not needed here.
- Land Registry also links this change to its wider move towards digital services. The goal is simpler processes and stronger protection for people involved in property deals.
HM Land Registry has also set up a way for firms to contact its team if they want to lodge QES applications.
Why QES Isn’t “Just Another eSignature” in Land Registration
If your firm already uses electronic signing, you might think: we’ve been doing this for years – what’s new?
The new part is not “electronic.” It’s qualified.
HM Land Registry’s Practice Guide 82 makes this point clear. QES lets some electronic documents count as valid deeds for land registration. It can also remove the usual need for a witness.
The guide refers to section 91 of the Land Registration Act 2002. That law allows an electronic document to count as a deed, if it meets certain rules. One of those rules is that the deed must use qualified electronic signatures, under terms set out in a registrar’s notice.
In plain English: QES is the high–trust type of signing that lets Land Registry accept electronic deeds without a witness, because it gives stronger proof of who signed and what they signed.
What HMLR Says Is in Scope Right Now
In October 2025, HM Land Registry shared its clearest update on what it will accept today.
It confirms:
- It accepts applications signed with QES and repeats the benefit: the signer’s identity is checked, so no witness is needed.
- It is currently accepting charges, transfers, and assents lodged with QES.
- It is still early days. Over time, Land Registry wants to accept more document types. It will update Practice Guide 82 as things expand.
The key takeaway: QES is live and accepted – but it isn’t “everything, everywhere” yet. Treat it as a defined process with clear limits, set steps, and platform needs.
The QES Signing Flow (Based on the Registrar’s Notice Under Rule 54C)
To roll out QES well, you need to understand the process HM Land Registry expects.
The registrar’s Notice under rule 54C (updated 20 May 2025) sets out the model. It explains how electronic deeds should work and what roles each party plays. It also introduces a key concept: the “controlling conveyancer.” That person sets up and controls the signing.
In simple terms, the flow looks like this:
1) The controlling conveyancer sets up the signing
They upload the final agreed document to the platform. They decide the signing order. They also mark the signature fields and where the completion date and time will go, if the signing platform allows customization.
2) The platform runs ID and certificate checks
The signer goes through an ID step. The platform links them to a Qualified Trust Service Provider (QTSP) or gives them a choice.
If the signer does not have a qualified certificate, the QTSP verifies their identity and issues one.
3) Each party signs using QES
The Notice requires QES with built–in timestamps. It also requires LTV (long–term validation) to be enabled.
4) Completion: the document is dated and locked
After the final signature, the controlling conveyancer adds the completion date and time. They then sign the document.
5) The conveyancer checks the signatures before lodgement
Before lodging the application, the conveyancer confirms the signatures still validate.
This is why QES adoption is not only about picking a provider. It’s a process change. You need clear rules on who controls signing, how ID works, and how you prove completion.
The Practical Issues That Catch Teams out
HM Land Registry’s guidance includes several points that can surprise teams in real completions.
Counterparts Can Cause Problems
Land Registry accepts that counterpart signing is a challenge for QES right now. It also repeats its view that section 91 needs a single document, not separate originals and counterparts. It asks QES providers to build solutions that match how firms work.
If your completions often rely on counterpart PDFs, test this early with your signing platform. It will be one of your biggest friction points.
Mixed Signing Isn’t Supported
Land Registry is also clear on mixed–mode signing. Once the platform runs ID checks and applies QES, the document becomes secure and locked. You cannot then switch to wet ink or combine paper and digital versions.
To get the full benefit, everyone must sign using QES. Land Registry does not currently support “some QES, some wet ink” for the same deed.
That matters when one party – or a lender – is not ready. You can’t adopt QES halfway inside a single document.
Dating Is More Important Than It Looks
Land Registry also flags that dating rules matter with QES. It points firms to the registrar’s Notice for the correct approach.
Agree early on how your team will apply date and time. Make sure your platform supports it in the way Land Registry expects.
Choosing a QES Solution: What Matters Most
HM Land Registry also sets clear boundaries on supply.
- It accepts QES, but it does not provide the signing technology. Firms must source QES services from providers.
- It does not publish an “approved list” of QES providers for this use.
- Providers must align with the UK eIDAS framework. In the UK, the ICO acts as the regulator for trust service providers.
So how do you pick the right setup?
For most conveyancing teams, the key questions are:
- Can the platform create one single electronic deed that works for registration (not just a PDF pack)?
- Does it support QES with timestamps and LTV?
- Can it handle multi–party signing without forcing counterpart workarounds?
- Does it produce a clear audit trail your compliance team will accept?
A Practical “Next 30 Days” Checklist
If you want to move from interest to rollout, this order helps reduce risk:
- Choose the best “first use” case. Start with document types HMLR already accepts (like transfers, charges, and assents).
- Map your completion process. Focus on single–document signing, dating, and who controls the signing.
- Speak to your signing provider about QES, timestamps, LTV, and multi–party flows.
- Contact HM Land Registry’s QES team to understand how to lodge QES applications and what to expect.
- Update your client messages. Explain the ID and signing steps before completion week, not during it.
Ready to switch to digital workflows in your business? Don’t hesitate to reach out to our team. Evrotrust’s experts will work closely with you to identify the most convenient QES integration for your needs.
Final Thoughts: QES Is a Workflow, Not a Button
Think of HM Land Registry’s move as a new signing and registration route. It aims to remove witness delays while improving identity checks and document security.
Firms that treat QES as “just another way to sign” may struggle. Counterparts, mixed signing, and dating rules will catch them out.
On the contrary, businesses that see QES as a full workflow change – and build it into the way they complete deals – will be ready for what Land Registry has clearly signalled: wider qualified signing use over time.
