Digital Proof of Age: Development of Standards

PASS Opens New Consultation on Standards for Digital Proof of Age

PASS, the scheme that audits and accredits proof of age schemes to assure retailers of which cards they can accept, is asking for views on how digital proof of age should be presented and verified in shops, pubs, cinemas and other places selling age restricted products and services.
Download the full consultation document

With digital proof of age becoming more prevalent and familiar to consumers, business accepting it need to know what to look for and how to verify that the information presented is valid and relates to the person carrying it. PASS has published a consultation paper open to anyone who has a view on this important topic, and particularly aimed at digital proof of age providers, retailers, publicans, entertainment venues, users of digital proof of age, technology and data experts, public sector and enforcement bodies, and groups working with young people.

The key elements of the proposed solution are:

Verification of valid digital proof of age through the retailer scanning a QR code on the customer’s phone;

  • The retailer being able to programme common code into their till systems, or as a minimum to download a free app to use on their own phone;
  • No exchange of data from the customer to the retailer;
  • A defined focus on using digital proof of age in a physical retail environment, not online;
  • Mirroring of the same PASS standards for verifying the age of an applicant before a physical card is issued, for digital proof of age companies.

PASS Chair, Baroness McIntosh, said: “Twenty years ago, retailers said they were confused by the multitude of proof of age cards, and so they set up PASS to audit schemes, accredit those that met the highest standards, and give guidance to retailers on how to tell which cards to accept. Now, we face exactly the same challenge with digital proof of age: consumers want to prove their age through their phone, and retailers need to know how to verify that the information they are shown is valid and relates to the person in front of them.

“A robust, practical and universal set of standards will allow companies offering digital proof of age to develop in the knowledge that their schemes will be accepted by retailers and endorsed as valid proof of age by enforcement bodies, and allow retailers of all kinds to train their colleagues to accept only valid proof of age, following a defined process for verifying digital proof of age when they are presented with it.

“We have worked on a set of standards that we think meet these needs, but we want to hear from all interested parties to ensure that the PASS digital proof of age standards are effective. I would encourage everyone who has an interest in this important challenge to respond to the consultation and help us create the best system we can.”

The consultation will close on 30 April 2020. The consultation paper and invitation to respond can be found here LINK. PASS will be running a consultation event before 30 April.


Does this proposal cover proving age online?

No, this new system is designed specifically to help customers prove their age digitally in a physical retail environment like a shop, cinema or pub. The development of processes to verify age online is separate to this work by PASS, and the latest government call for evidence on digital identity closed last year and can be viewed here:

Is digital proof of age currently accepted by retailers?

Retailers can accept digital proof of age but it cannot be used to verify age for the sale of alcohol. The basis on which retailers ascertain the legitimacy of a proof of age will vary by different proof of age companies and is still open to interpretation by local enforcement.
Will digital proof of age replace physical proof of age cards bearing the PASS hologram?
No, proof of age cards with the PASS hologram are still acceptable. This consultation concerns the development of physical presentation of digital proof of age.

Will retailers be able to take and use data from customers with digital proof of age?

Not under the proposed system. A retailer would scan a QR code on the customer’s phone and this would reveal their photograph and proof of age. This data is not transferred from the digital proof of age provider to the retailer.

How can PASS be sure that digital proof of age companies are accurately checking that customers are the same person, and have the same date of birth, as their digital proof of age shows?

PASS has a long established system of auditing the processes used by accredited card issuers, including reference checking, data security and fraud prevention. Digital proof of age providers would be subject to the same standards and auditing processes, but first there needs to be a universal system for verifying proof of age at the point of sale, which this consultation addresses. PASS’s standards for schemes are periodically reviewed by the PASS board.

Who is running this consultation process?

The PASS board is running this process and will consider responses once the consultation has closed on 30th April 2020. The board has delegated this work to a standards working group chaired by James Lowman, chief executive of the Association of Convenience Stores (ACS), and ACS is using its survey platform for administering the process. The consultation is being managed by an independent consultant Katharine Walters, who has been appointed by the PASS board.

For any queries, please contact Katharine at

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