Age Verification and Refusals

Challenge 25: How the Policy Works and How to Run It Properly

What Challenge 25 is, whether it is law, the ID you can accept, how to train staff and how to record refusals so the policy protects the licence

Challenge 25 is the policy of asking anyone who looks under 25 to prove they are over 18 before selling them alcohol. It is not written into the Licensing Act, but every premises licence carries a mandatory condition requiring an age verification policy, and Challenge 25 is the one the police, trading standards and the guidance all expect. It exists because judging whether someone is 17 or 19 is impossible, whereas judging whether someone might be under 25 gives a margin that catches nearly every underage attempt. This article covers what the policy requires, the ID you can accept, how to train and brief staff, why the refusals log is the evidence that matters, and what a failed test purchase means for the licence.

Put the age verification policy in every induction See licence features

Key takeaways

Challenge 25 is the industry-standard age verification policy; an age verification policy is a mandatory licence condition, and Challenge 25 is often an express one.

Acceptable ID carries a photograph, date of birth and a holographic or UV feature: passport, photocard driving licence, PASS card, military ID, biometric residence permit.

Two underage sales in three months is the persistent selling offence that can suspend the licence; test purchasing is how it is caught.

The refusals log is the evidence the policy is applied; an empty log at a busy venue is the worst possible answer.

Is Challenge 25 a Legal Requirement?

Not by name. The Licensing Act 2003 mandatory conditions require the premises licence holder to ensure an age verification policy is in place requiring anyone who appears to be under 18 to produce identification bearing their photograph, date of birth and a holographic mark or ultraviolet feature. The policy must be applied; the age threshold is the operator's choice, and Challenge 25 is the industry standard because 18 gives no margin and 21 gives very little. Many licences carry Challenge 25 as an express condition because the applicant offered it in the operating schedule or the police asked for it at a hearing, and where that is the case, running Challenge 21 is a breach of condition. Check your licence.

Acceptable Forms of ID

The mandatory condition names the features: photograph, date of birth and a holographic mark or UV feature. The forms of ID that meet it are a passport, a UK or EU photocard driving licence, a PASS-accredited proof of age card such as CitizenCard or the Young Scot card, a military ID card and a biometric residence permit. Student cards, bus passes, birth certificates and photos of a passport on a phone do not meet it, and the last is the one staff are most often shown. Digital ID is changing: PASS now accredits digital proof of age in an app, and the government's digital verification framework is bringing more schemes through, so a policy written in 2020 may be behind the guidance. Whatever you accept, staff should check the photograph matches, the date of birth passes, and the document is intact.

Training, Briefing and the Two-Sale Rule

The person who serves is the one who commits the offence, so every member of staff who might sell alcohol needs to know the policy before their first shift, and to be able to say what it is if an officer asks. Training should cover the threshold, the ID list, how to ask without confrontation, how to refuse and how to record it, and the fact that a manager can be called. Refresh it every six to twelve months and record it. The reason the law bites is the persistent selling offence: two sales to under-18s at the same premises within three months can suspend the licence for up to three months and fine the holder, and a single failed test purchase brings the second visit. Trading standards and the police run test purchases with volunteers aged 15 to 17, and they visit the premises that have failed before.

Age Verification and Refusals

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The Refusals Log Is the Proof

A policy that is not written down and a refusal that is not recorded look, to an officer, like a policy that does not exist. The refusals log records every occasion a sale was refused for age or intoxication: date, time, what was asked for, why it was refused, a brief description and the initials of the staff member. A log with entries every week shows a venue that is checking; an empty log at a busy bar shows a venue that is not. Inspecting officers ask for it, licensing hearings read it, and a due diligence defence to an underage sale charge depends on it. Keep it behind the bar, review it weekly with the team, and keep old logs for at least a year.

What to do next

Check whether Challenge 25 is a condition on your licence

If it is, the threshold is not negotiable. Either way, put the policy on the wall by the till and in the induction.

Audit the refusals log weekly

Count the entries, praise the refusals and ask why a busy Friday produced none. Sign and date the review.

Common mistakes to avoid

Mistake

Accepting a photo of a passport on a phone

Instead

A photograph of a document cannot be checked for holograms or tampering and is not acceptable ID under the mandatory condition. Ask for the original or refuse.

Frequently asked questions

Is Challenge 25 the law?

The law requires an age verification policy for anyone who appears under 18; Challenge 25 is the policy almost every venue adopts to meet it, and many licences make it an express condition. Where it is a condition, it is legally binding on that premises.

What ID is acceptable for Challenge 25?

A passport, a photocard driving licence, a PASS-accredited proof of age card, a military ID card or a biometric residence permit. The document must carry a photograph, date of birth and a holographic or UV security feature.

What happens if a member of staff sells alcohol to someone under 18?

The individual can receive a fixed penalty of £90 or a fine, and the premises licence holder can be prosecuted. Two such sales within three months is the persistent selling offence, with a fine of up to £20,000 and suspension of the licence for up to three months.

Age Verification and Refusals