Digital age verification: key considerations for operators

The government has put forward draft legislation to update the mandatory licensing conditions to specifically allow the use of digital identification for age verification purposes.

The change forms part of wider efforts to modernise identity verification and, if approved, will give 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 the Challenge 21 or Challenge 25 policy in this regard.

At present, the mandatory conditions require that any identification produced to establish that a person who appears to be under 18 is in fact over 18 has a date of birth, a photograph and either a holographic mark or an ultraviolet feature. This currently excludes the possibility of digital forms of identification being utilised for these purposes.

Once in force, the new regulations will revise the mandatory conditions to specifically allow digital forms of ID to be used. For some operators, the changes may present an opportunity to modernise age-verification processes and respond to increasing use of digital credentials by consumers. However, businesses will need to consider staff training, verification procedures and the suitability of any digital verification solution they adopt. Premises will be able to choose not to accept digital ID themselves, should they not wish to do so for any reason, but they will have the option to incorporate doing so into their proof of age policies.

In order to accept digital ID, premises will need to enter into an agreement with a registered digital verification service provider. That provider/system must be able to confirm whether or not a customer is the required age and that the ID information produced relates to the person who is providing it as proof of age.

These regulations will now need to make their way through the usual parliamentary process, so there is no implementation date as yet, but premises who do wish to use digital ID once they are able to should start making preparations with preferred digital verification service providers now. Operators should also take the opportunity to review their existing age-verification policies, including any Challenge 21 or Challenge 25 procedures, to ensure they remain fit for purpose if digital ID is introduced. 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.

Whilst these regulations will update the mandatory conditions, operators should be aware that there will not be any automatic amendments made to any Annex 2 or 3 conditions contained in their licences. As such, if any such conditions restrict acceptable ID to physical documents only, operators will need to vary those conditions before they can proceed to accept digital ID.

Although there is no confirmed implementation date, operators considering the use of digital ID may wish to start reviewing their policies and licence conditions now so they are ready to take advantage of the changes when they come into force.

Any operators with queries about whether their premises licence will permit the acceptance of digital ID should contact TLT's Licensing team.

This publication is intended for general guidance and represents our understanding of the relevant law and practice as at July 2026. Specific advice should be sought for specific cases. For more information see our terms & conditions.