Digital age verification now in force: key considerations for operators

New legislation has come into force today (15 September 2026) to give licensed premises the option to accept digital proof of age for alcohol sales.

The change forms part of wider efforts to modernise identity verification and gives operators the option of accepting certain digital forms of ID as part of their age-verification policies.

What's changing?

The mandatory conditions currently require that an age verification policy is adopted in all premises licensed to sell alcohol for consumption on and off the premises. Such policy must require all individuals who appear to be under 18 years of age (or such older age as specified in the policy) to produce identification to establish that they are in fact over 18 years of age. Most commonly, premises adopt a Challenge 21 or Challenge 25 policy in this regard.

Traditionally, the mandatory conditions required that any identification produced as proof of age included a date of birth, a photograph and either a holographic mark or an ultraviolet feature. This effectively limited acceptable forms of identification to physical documents.

With effect from 15 September 2026, the mandatory conditions have been amended to permit the acceptance of digital forms of identification. Licensed premises are not required to accept digital ID, but they now have the option to do so should they wish.

For some operators, the change may present an opportunity to modernise age-verification processes and respond to increasing consumer use of digital credentials. However, businesses will need to consider staff training, verification procedures and the suitability of any digital verification solution they adopt.

In order to accept digital ID, premises will need to enter into an agreement with an approved digital verification service provider (DVSP). The provider must be able to confirm both that a customer meets the relevant age requirement and that the digital identification relates to the person presenting it. A list of approved providers can be found on the government register.

However, operators should not assume they can immediately begin accepting digital ID as a result of the legislative change. Whilst the mandatory conditions have been updated, there will not be any automatic amendments made to any Annex 2 or Annex 3 conditions contained in their premises licences. Where such conditions prescribe the forms of identification that may be accepted, they may prevent the use of digital ID unless a variation is approved first.

Examples of the kind of condition that would require amendment to allow for the use of digital ID will include terms such as 'the only forms of acceptable ID are…'. Where terms provide options as to forms of ID that can be used, such as where a condition states: 'types of ID that may be acceptable', then no change would be required. We would expect any variation to allow for digital ID to be a minor variation where needed.  

Operators considering the adoption of digital ID should now review their premises licence conditions, age-verification policies, including any Challenge 21 or Challenge 25 policies in operation, to ensure they remain fit for purpose. Consideration should also be given to staff training requirements, particularly around recognising and verifying digital forms of identification and applying age-verification procedures consistently across the business.

The implementation of digital age verification is therefore not simply a matter of adopting a new technology solution. Operators should review their existing licensing permissions, age-verification policies and operational procedures before deciding whether to introduce digital ID.

Any operators with queries about implementing digital age verification, or whether their premises licence will permit the acceptance of digital ID, should contact Rebecca Lowe.

Note: this article has been updated to reflect the legislation that came into force on 15 September 2026.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at September 2026. For more information see our terms & conditions.