Selling alcohol to a person under 18 is a criminal offence under section 146 of the Licensing Act 2003, punishable by an unlimited fine on summary conviction. Challenge 25 is an industry best practice scheme designed to prevent underage sales by requiring anyone who looks under 25 to produce acceptable proof of age before being served. While Challenge 25 is not a legal requirement in itself, it is widely adopted as the standard approach and is frequently included as a licence condition.
Disclaimer: This article covers age verification for alcohol sales in England and Wales. Scotland has a mandatory Challenge 25 policy for all premises that sell alcohol under the Licensing (Scotland) Act 2005. Northern Ireland has separate requirements. Always seek professional legal advice and consult your local authority licensing team.
What is Challenge 25?
Challenge 25 is straightforward in principle: if a customer appears to be under 25 years of age, they must be asked for acceptable proof of age before being served alcohol. The age threshold of 25 (rather than 18) provides a safety margin, because judging someone's age from their appearance is inherently unreliable. The legal drinking age remains 18; Challenge 25 is simply the verification mechanism.
The scheme was developed by the Retail of Alcohol Standards Group and is endorsed by licensing authorities, the Home Office, and the police. Most premises licences issued in recent years include a condition requiring the implementation of Challenge 25 or a similar age verification policy.
Acceptable forms of identification
The following forms of ID are generally accepted under Challenge 25:
- Passport -- UK or foreign passports are universally accepted.
- UK driving licence -- full or provisional, including the photocard.
- PASS card -- any card bearing the PASS (Proof of Age Standards Scheme) hologram. This includes cards from schemes like CitizenCard and Young Scot.
- Military ID -- Ministry of Defence identity cards with a date of birth and photograph.
Student ID cards, bank cards, and birth certificates are not acceptable proof of age, even though they may show a date of birth. They lack the security features needed to verify authenticity.
Implementing Challenge 25 at events
Events present unique challenges for age verification. Unlike a pub where the same staff work regularly, events often rely on temporary bar staff, volunteers, or agency workers who may not be familiar with age verification procedures. Here is how to implement it effectively:
Staff training
Every person serving alcohol at your event must understand the Challenge 25 policy before they start work. Training should cover: what Challenge 25 means, which forms of ID are acceptable, how to check ID (looking for security features, checking the date of birth, comparing the photo to the person), how to refuse a sale politely but firmly, and how to record refusals.
Training does not need to be lengthy, but it must be documented. Keep a record of who was trained, when, and what was covered. This is evidence of due diligence if a test purchase operation detects an underage sale.
Signage
Display Challenge 25 notices prominently at every point of sale. Signs should be visible from the customer's side of the bar and should clearly state that anyone who appears under 25 will be asked for ID. This manages customer expectations and supports your staff in requesting identification.
Refusal logs
Maintain a refusal log at every bar or point of sale. When a sale is refused because the customer cannot provide acceptable ID, record the date, time, description of the person, the reason for refusal, and the name of the staff member who refused the sale. Refusal logs demonstrate that your policy is being actively enforced, not just displayed on a sign.
Wristband systems
For events where attendees will visit the bar multiple times, consider using a wristband system. Check ID at a designated point (such as the entrance or a dedicated ID check station) and issue a wristband to confirm the person is over 18. Bar staff then only need to check for the wristband. This speeds up service and reduces the burden on bar staff while maintaining compliance.
If you use wristbands, ensure they are tamper-evident and difficult to transfer. Paper wristbands that tear if removed are effective and inexpensive. Brief your door and capacity management team on the wristband system so it operates smoothly.
The law on underage sales
Under section 146 of the Licensing Act 2003, it is an offence to sell alcohol to a person under 18. The offence applies to the person who makes the sale, not just the licence holder. Under section 147, it is also an offence to allow such a sale if you are in a position of responsibility. Both offences carry an unlimited fine on summary conviction.
There is a statutory defence: it is a defence to show that the person selling the alcohol believed the buyer was 18 or over, had taken all reasonable steps to establish the buyer's age, and that nobody could reasonably have suspected from the buyer's appearance that they were under 18. A properly implemented Challenge 25 policy with documented training and refusal logs provides strong evidence of this defence.
Test purchase operations
Local authority trading standards departments regularly conduct test purchase operations at events, sending volunteers aged 16 or 17 to attempt to buy alcohol. The volunteers are instructed not to lie about their age if asked directly but may not volunteer the information. If a sale is made, the person who served the alcohol can be prosecuted, the premises licence can be reviewed, and the event organiser faces reputational damage.
Prepare your staff for this possibility. Reinforce that every person who looks under 25 must be challenged, without exception, regardless of how busy the bar is or how confident the staff member feels about judging ages.
Beyond alcohol: other age-restricted products and activities
Age verification is not limited to alcohol. If your event includes the sale of tobacco, e-cigarettes, or fireworks, or if you are screening films with age ratings, separate age verification requirements apply. For events with mixed-age audiences, consider how your ticketing approach can support age verification, for example by requiring date of birth at the point of purchase for events with age-restricted elements.
A well-run age verification system protects your attendees, your staff, your licence, and your reputation. It is one of the most scrutinised areas of licensing compliance, and getting it right is straightforward with proper preparation. For further guidance, the Home Office guidance under section 182 of the Licensing Act 2003 includes detailed advice on age verification, and the event management tools you use should support compliance record-keeping.
