PASS Consultation on Standards for Digital Proof of Age

PASS (the scheme that audits and accredits proof of age schemes in pubs, entertainment premises and other places selling age-restricted products and services) has commenced a consultation in which it is asking for views on how digital proof of age should be presented and verified.

You can download the full consultation document below, but the key elements of the proposed solution are described on the PASS website as follows:

  • 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.

The introduction to the consultation states as follows:

PASS (the Proof of Age Standards Scheme) accredits card schemes based on agreed standards for verification of identity and the rigour of the card issuing process, meaning that those accepting these cards can be confident these are valid documents.

A growing number of people want to prove their age through a digital system on their phone rather than or as well as using physical proof of age cards. The purpose of this consultation is to seek views on whether or not PASS should extend its remit to cover the use of Digital Proof of Age (DPoA) as well as physical forms of Proof of Age.

The consultation proposes a new PASS Standard to enable any number of Accredited Digital Suppliers (ADSs) to operate via a single open-source DPoA Retail Validation Interface (RVI).

The consultation will run until Thursday 30th April 2020 and the PASS Board welcomes views from all interested parties. All responses will be considered before PASS decides whether and how to proceed with the proposal at its meeting in July 2020.

If the Board decides to proceed, suppliers would be invited to apply for accreditation as an ADS in July 2020 and it is envisaged that the RVI would be made available to retailers & DPoA acceptors from October 2020.

If you have any queries about the consultation, then please get in touch with Katharine Walters at:

You can respond to the consultation here.

Baroness McIntosh, Chair of PASS is quoted as saying:

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 PASS website contains the following Q&As:


Q: Does this proposal cover proving age online?

A: 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:

Q: Is digital proof of age currently accepted by retailers?

A: 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.

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

A: 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.

Q: 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?

A: 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.

Q: Who is running this consultation process?

A: 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.