Challenge 25 policy for pubs: what the law asks, the ID you can take, and digital ID from September 2026

A Challenge 25 policy is the written rule that anyone who looks under 25 gets asked for ID before they're served alcohol. In England and Wales the law makes every pub have an age verification policy covering anyone who looks under 18, and lets you set the age higher, which is where 25 comes from. The ID has to show a photo, a date of birth and a hologram or ultraviolet mark. Since 15 September 2026 you can also accept a digital proof of age from a certified provider, as long as it's checked by a scanner or reader, never by looking at a phone screen.

Challenge 25 is the cheapest bit of compliance in the building and the one that costs the most when it fails. One sale to a test purchaser and the server gets a £90 penalty notice. Two in three months and the licence holder is looking at a fine of up to £20,000 and the pub shut for up to two weeks. Here's what the law actually asks for, what ID counts, what changed in September, and a policy you can lift.

What the law says

The age verification rule is a mandatory condition on every premises licence that allows alcohol. It splits the job in two:

• The premises licence holder must make sure an age verification policy is adopted for the premises.
• The designated premises supervisor must make sure alcohol is sold in line with it.

The policy has to require anyone who appears to be under 18, "or such older age as may be specified in the policy", to show ID before they're served. The ID must carry their photograph, their date of birth, and either a holographic mark or an ultraviolet feature. That's the whole legal test. "Challenge 25" isn't in the condition. It's the older age most pubs choose, because a 25-year-old line gives your staff seven years of margin for a bad guess.

What ID you can accept

ID against the legal test of photo, date of birth and hologram or UV feature. Sources at the bottom.

ID	Accept?	Why
Passport	Yes	Photo, date of birth, security features
Photocard driving licence	Yes	Photo, date of birth, hologram
Proof of age card with the PASS hologram	Yes	Built to meet exactly this test
Digital proof of age from a certified provider, checked by scanner or reader	Yes, from 15 September 2026, if you choose to	The 2026 amendment order
A photo or screenshot of a driving licence on a phone	No	No hologram or UV feature, and trading standards guidance says a photo of a licence isn't acceptable digital ID
A digital ID app you just look at	No	Visual checks of a digital proof aren't allowed. It has to be checked by technology
Bank card, student card without a hologram, a mate vouching	No	Doesn't meet the test

Your policy can be stricter than the law. Name exactly which documents you take, so a new member of staff isn't trying to judge a foreign ID card at 11pm on a Saturday.

Digital ID: what changed on 15 September 2026

The Licensing Act 2003 (Mandatory Licensing Conditions) (Amendment) Order 2026 came into force on 15 September. It lets you accept a digital proof of age, but only one that comes from a digital verification service on the government's statutory register, checked with technology such as a QR code or a tap reader. The government's own guidance says a visual check of a digital proof isn't allowed, age estimation tech can't be used instead, and you should only process the data you need to check age.

Three things worth knowing before anyone sells you a scanner:

• It's optional. Councils are clear that you don't have to adopt it, and passports and driving licences stay valid.
• Being on the register isn't the same as being compliant. The register means the provider passed the trust framework audit. You still have to check the way you use it meets the licensing condition.
• If you adopt it, rewrite your policy. North Northamptonshire Council's guidance tells businesses to update their Challenge 25 policy documents if they start taking digital checks.

My view: for most locals it's not worth spending money on yet. The people who'll turn up with a digital ID are the same people who carry a licence. Where it might earn its keep is a busy student or late-night bar where queues and lost IDs are a real problem. Wait until your EPOS or card machine supplier offers it in a box you already pay for.

What happens when it goes wrong

Penalties for selling alcohol to under-18s in England and Wales. Sources at the bottom.

What	Who	Penalty
Selling alcohol to a child	The person who served, and staff who knowingly allowed it	A penalty notice for disorder, currently £90, or prosecution and a fine
Persistently selling: two or more sales to children within three consecutive months	The premises licence holder	A fine of up to £20,000
Closure notice for persistent selling	The premises	No alcohol sales for 48 to 336 hours (up to 14 days)
Court order	The licence	Suspension for up to three months, and a licence review

Run the closure line through a normal pub. A pub taking £5,000 a week loses up to £10,000 of takings on a 14-day closure, and two weeks is long enough for regulars to find somewhere else to drink. My arithmetic, illustrative.

The defence, and why the policy is your evidence

If a sale to a child does happen, the server has a defence if they believed the customer was 18 or over and either took all reasonable steps to check, or nobody could reasonably have suspected from the way they looked that they were under 18. Trading standards' guidance spells out that "reasonable steps" means asking for evidence of age, and the evidence has to be good enough to convince a reasonable person. For the licence holder, the defence is having taken all due diligence.

That's why the paperwork matters. A written policy, training records that show each person was taken through it, and a refusals log that shows the policy being used are what due diligence looks like on paper. Trading standards says it's best practice to record every refusal, with the date, the time, what happened and a description of the person, and for a manager to check the log. My incident log guide covers how to keep one that stands up.

A Challenge 25 policy you can copy

Write it on one page and keep it behind the bar. Mine would say:

1. We operate Challenge 25. Anyone who looks under 25 will be asked for ID before being served alcohol.
2. We accept a passport, a photocard driving licence, or a proof of age card with the PASS hologram. [Add digital proof of age, and the provider and reader you use, only if you've adopted it.]
3. We don't accept photos or screenshots of ID, or any digital ID shown on a screen without being scanned.
4. If a customer can't show acceptable ID, we refuse the sale and record it in the refusals log.
5. We refuse any sale we believe is being bought for someone under 18.
6. Every member of staff is trained on this policy before their first shift, signs to say so, and is refreshed every six months.
7. The DPS checks the refusals log every week.

Display Challenge 25 posters at the bar and the door. They do half the work for you, because people who know they'll be asked often don't try.

Two things I'd add that nobody talks about

Put the date on the till. Every morning, write "Born on or before [today's date, 18 years ago]" on a card by each till. At 11pm nobody should be doing date-of-birth sums in their head with a queue three deep. The card does it.

Decide who checks at the table. If you take orders at the table, by app or by QR code, the person who pours never sees the customer. Your policy has to say who checks ID when the drinks land, because it won't be the bar. Write that line in now, before the first table service Christmas party.

And remember the proxy sale. Buying alcohol on behalf of someone under 18 is an offence too, which is why the policy tells staff to refuse when they think that's what's going on. The children in pubs guide covers the 16 and 17-year-old with a meal rule, which is the one exception in pubs.

My take

Challenge 25 isn't about catching kids. It's about your staff never having to make a judgment call alone. A clear one-page policy, the right ID list, a log, and a date card on the till take the guesswork out, and they're exactly what you want to hand a licensing officer. Digital ID is a nice option to have in your back pocket. It isn't a reason to change anything this Christmas.

Common questions

Is Challenge 25 a legal requirement?

The law requires every premises licence that allows alcohol to have an age verification policy covering anyone who appears under 18, and lets the policy set an older age. Challenge 25 is the older age most pubs choose. Some licences have it written in as a specific condition, so check yours.

What ID is acceptable for Challenge 25?

ID with the customer's photo, date of birth and a holographic mark or ultraviolet feature: typically a passport, a photocard driving licence or a PASS-hologram proof of age card. From 15 September 2026 a digital proof of age from a registered provider, checked by scanner or reader, is also allowed if the pub chooses to accept it.

Can pubs accept digital ID?

Yes, in England and Wales since 15 September 2026, but only from a certified digital verification service on the government register, checked with technology. Looking at a screen isn't allowed, and pubs don't have to accept digital ID at all.

What is the fine for selling alcohol to under 18s?

The server can get a £90 penalty notice or be prosecuted. If a premises sells to children twice within three months, the licence holder faces a fine of up to £20,000, a closure notice of 48 to 336 hours, and the licence can be suspended for up to three months.

Do I need to keep a refusals log?

It's best practice and many licences make it a condition. Record the date, time, what happened and a description of the person, and have the DPS check it regularly. It's your evidence of due diligence if a sale is ever challenged.