Association of Digital Verification Professionals
Cabinet Office Consultation • CP 1498
The Government Consultation
The government is consulting on plans for a national digital ID system. Below you can explore every consultation question, organised by theme.
Open: 10 March 2026
Closes: 5 May 2026
46 questions across 6 parts
How is the consultation structured?
The consultation is divided into six parts. Click on any section to read the questions and the ADVP response.
1
The government's ambition
Part 1 introduces the current landscape and sets out the government’s goals for the new national digital ID system, including the benefits it aims to bring to people across the UK.
1.0.Q1
What do you think the main benefits will be, if any, for the government’s new national digital ID system?
Everyone
ADVP Response
For those people who do not have a passport (~15% of the UK population) a UK national digital ID may be valuable when it is necessary for them to prove identity. However, it should be noted some 3% of adults do not have access to the internet and c30% of over 75 have no or limited access. The scheme should not exclude these people by default.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
1.0.Q2
What do you think the main drawbacks will be, if any, for the government’s new national digital ID system?
Everyone
ADVP Response
A national digital ID has been poorly communicated and therefore will be opposed by large sections of society. ADVPs discussions with various civil society groups have raised significant concerns about privacy & surveillance. The proposal in its current form will also have significant impact on the private sector companies operating under the DVS Trust framework with the potential for significant job losses, lower growth and reduced tax revenues from one of the UK’s fastest growing fintech sectors. Our estimates suggest that by 2035 the revenue from the sector could be £2bn per annum lower than based on current projections, 12,000 fewer jobs & a fiscal impact of £1bn lower taxation revenue for government.
ADVP also believes that the current proposal is not compliant with several aspects of the UK’s Competition & Markets Authority (CMA) Legislation.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
1.0.Q3
One of the government’s aims for the new national digital ID system is to make it easier for people to prove who they are. To what extent do you agree or disagree that the proposed system could help achieve this aim, and why?
Everyone
ADVP Response
c) Neither agree nor disagree. The National Digital ID is being presented as a ‘political’ solution with which people are asked to ‘agree’ or ‘oppose’. Providing a mechanism for people to be trusted digitally is important – but achieving ‘trust’ end-to-end is complex and cannot be delivered by a government ‘Digital ID’ solution.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
1.0.Q4
The government proposes to use the digital ID system to enable more modern, efficient and personalised public services. Which public services would you want the government to prioritise making faster or more efficient using the system?
Everyone
ADVP Response
This question represents how the government is misrepresenting what Digital ID is. It will not “enable more modern, efficient and personalised public services.” To achieve this, public services would need to be completely redesigned. By presenting it to the public as such, the government sets false expectations.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
2
The government's approach
Part 2 describes how the government intends to build the digital ID system, harnessing existing investments in GOV.UK One Login and the GOV.UK Wallet. It covers how the digital ID will be issued, stored and checked.
Chapter 2.1: Creating the digital ID
2.1.Q1
Do you have any concerns about the impact of the national digital ID that are specific to your part of the UK?
Experts & Orgs
ADVP Response
The government should be designing a national Digital Verification Services infrastructure in collaboration with industry. The decisions on standards are complex and involve trade offs.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
2.1.Q2
Are there any ethical factors government should consider that relate to an individual deleting their digital ID?
Everyone
ADVP Response
Fraud and misinformation are growing at alarming rates and affecting all parts of the country. They should be addressed through a national Digital Verification Services infrastructure developed in collaboration between government and industry.
The proposal in its current form will also have significant impact on the private sector companies operating under the DVS Trust framework with the potential for significant job losses, lower growth and reduced tax revenues from one of the UK’s fastest growing fintech sectors. Our estimates suggest that by 2035 the revenue from the sector could be £2bn per annum lower than based on current projections, 12,000 fewer jobs & a fiscal impact of £1bn lower taxation revenue for government.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
Chapter 2.2: Storing, Managing and Using the digital ID
2.2.Q1
Are there any ethical factors government should consider that relate to an individual deleting their digital ID?
Everyone
ADVP Response
If the digital ID becomes a mandatory means of proving a citizens ID, the impact of revoking that ID would effectively bar the citizen from access to public and potentially private services under the current proposal. Alternative methods of identification such as passports must continue to be allowed under the DVS framework
The proposal in its current form will also have significant impact on the private sector companies operating under the DVS Trust framework with the potential for significant job losses, lower growth and reduced tax revenues from one of the UK’s fastest growing fintech sectors. Our estimates suggest that by 2035 the revenue from the sector could be £2bn per annum lower than based on current projections, 12,000 fewer jobs & a fiscal impact of £1bn lower taxation revenue for government.
ADVP also believes that the current proposal is not compliant with several aspects of the UK’s Competition & Markets Authority (CMA) Legislation.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
2.2.Q2
Are there any ethical factors government should consider that relate to revoking (i.e. cancelling) an individual’s digital ID?
Everyone
ADVP Response
If the digital ID becomes a mandatory means of proving a citizens ID, the impact of revoking that ID would effectively bar the citizen from access to public and potentially private services under the current proposal. Alternative methods of identification such as passports must continue to be allowed under the DVS framework
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
2.2.Q3
Do you think people should be able to choose to store their national digital ID in digital wallets other than the GOV.UK Wallet, that are certified to meet government standards?
Everyone
ADVP Response
Yes, otherwise the government can be accused of creating a surveillance state.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
2.2.Q4
We are considering creating a ‘government checker’ service to verify that a digital ID has not been faked, tampered with or revoked. To what extent do you agree or disagree with this service being made available in the private and third sectors, at low or no cost?
Experts & Orgs
ADVP Response
The design of the government checker will significantly influence the competitive landscape. The government has a dual role – as policy maker and as a potential service provider – which requires caution to avoid conflicts of interest. Competition law effectively asks the government to self-regulate its market behaviour or face external regulation.
ADVP also believes that the current proposal is not compliant with several aspects of the UK’s Competition & Markets Authority (CMA) Legislation.
Government should not create monopolistic services but should work with industry to create the best outcomes for increasing trust in digital services.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
2.2.Q5
We are considering several limitations to the government checker service, by design. Are there any specific limitations you think we should set for the government checker?
Experts & Orgs
ADVP Response
The design of the government checker will significantly influence the competitive landscape. The government has a dual role – as policy maker and as a potential service provider – which requires caution to avoid conflicts of interest. Competition law effectively asks the government to self-regulate its market behaviour or face external regulation.
ADVP also believes that the current proposal is not compliant with several aspects of the UK’s Competition & Markets Authority (CMA) Legislation.
Government should not create monopolistic services but should work with industry to create the best outcomes for increasing trust in digital services.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
3
Uses for government digital ID
Part 3 discusses how the digital ID system could reduce bureaucracy and build more responsive public services. It covers what information the ID should contain, how it could be used across the wider economy, and how it will help tackle illegal working.
Chapter 3.1: Information contained in the digital ID
3.1.Q1
The national digital ID will include a person’s full name, date of birth, nationality, and a photo. What further information, if any, should the digital ID also include?
Everyone
ADVP Response
None on a digital ID – but government departments should issue separate Verifiable Credentials to people where it is needed.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
3.1.Q2
The government is not planning to initially include address information on the national digital ID. If your organisation were to rely on this information, what would help you trust an address on the digital ID?
Organisations
ADVP Response
Address is a complicated policy area. Policy on address should not be conflated with policy on national digital ID. Given the rate at which the validity of address information decays over time, connecting it to the digital identity may provide a false level of assurance to the validity of that address. This could be exploited by fraudsters for example.
Furthermore, maintaining addresses connected to digital identity would add significant costs to operating the scheme.
This question also demonstrates why government should understand its own Digital Verification Services legislation
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
3.1.Q3
We are exploring whether people with a digital ID should be legally required to inform the government of certain changes or errors to their personal information. To what extent do you agree or disagree with such a legal requirement?
Everyone
ADVP Response
Again, this question is unrelated to a national Digital ID. The government needs to be specific. Which data are they referring to and why is the proposed change in policy required.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
Chapter 3.2: Transforming public services
3.2.Q1
Are there examples of any barriers or inefficiencies that prevent you (or people you support) from interacting with public services, that you think the digital ID system could help with?
Everyone
ADVP Response
The complexities of accessing public services stem from complex government policies which have been incrementally changed by successive governments. Digital ID will not address this legacy.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
3.2.Q2
Have you ever faced issues with knowing which public services are available to you based on your circumstances?
Everyone
ADVP Response
Again, this question does not relate to Digital ID but implies a much bigger and more complex government policy ambition.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
3.2.Q3
Have you ever been unable to or had difficulty accessing a public service because you were unable to prove your identity?
Everyone
ADVP Response
The more common and complex problem is for public service providers to be able to identify whether a person meets the criteria for a public service. Establishing identity is normally only a small part of this problem.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
3.2.Q4
Government would develop a method to securely identify and match people across different public services to simplify everyday interactions. To what extent do you agree or disagree with the adoption of such an approach?
Everyone
ADVP Response
ADVPs discussions with various civil society groups have raised significant concerns about privacy & surveillance related to this type of functionality.
The adoption of a cross government identity matching approach as described, raises issues, due to significant concerns around privacy, proportionality, governance, and long term trust — concerns which outweigh the potential convenience benefits unless the proposal is materially narrowed and re scoped.
While simplifying interactions with public services is a legitimate policy objective, developing a mechanism to securely identify and match individuals across different services risks normalising widespread data linkage across government. This represents a fundamental shift in the relationship between citizens and the state and requires an exceptionally high justification threshold, which has not yet been demonstrated.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
3.2.Q5
What ethical issues, if any, can you think of when designing a way to identify and match people across services?
Everyone
ADVP Response
ADVPs discussions with various civil society groups have raised significant concerns about privacy & surveillance related to this type of functionality.
The government should not identify and match people across services. The UK has long opposed ‘Big Brother’ government. Instead, the government should enable citizens to control and share their personal data as they choose.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
3.2.Q6
What technical issues do we need to think about when designing a way to correctly identify and match people across public services?
Experts & Orgs
ADVP Response
It is the ethical – not technical – issues that government should be considering.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
Chapter 3.3: Utility in the wider economy
3.3.Q1
To what extent do you agree or disagree that the private sector and third parties should be able to use the digital ID alongside other options like physical documents?
Everyone
ADVP Response
ADVP believes that people should have the choice between the digital ID and identity documents such as passport, driving licence, mDL, consistent with the DVS framework.
People should be able to use their personal data where they choose, under their own control with confidence in how the data will be used and processed
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
Chapter 3.4: Tackling illegal working
3.4.Q1
Are there any additional challenges not captured in the consultation that businesses would face in carrying out fully digital right to work checks for all new workers?
Everyone
ADVP Response
Digital right-to-work checks can be conducted today for the 85% of British citizens with a passport. Of the other 15% many do not need to prove the right-to-work but issuing a government credential to this set of people would be valuable. As articulated to the Home Affairs Select Committee, the greatest challenge is not around digital identity: it is within the Home Office systems which establish a non UK person’s right-to-work. That is where government should apply its resources.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
3.4.Q2
Would any additional support not captured in the consultation be required for businesses to comply with fully digital right to work checks?
Everyone
ADVP Response
The government has not explained which of the many problems with right-to-work it wishes to address. It should engage with industry on the specific problem before it proposes a solution.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
3.4.Q3
What information would your organisation require to have confidence that a digital right to work check has been completed?
Organisations
ADVP Response
This question demonstrates that the government should engage with employers before designing a new solution. Today the employer is able to obtain a statutory excuse from a fine by using a DVS Provider.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
4
Inclusion
Part 4 covers the government’s plans for an ID and digital inclusion drive, to make the digital ID available and accessible to all. It discusses eligibility, the minimum age, what groups may need extra support, and what alternative access routes could look like.
Chapter 4.1: Eligibility for the digital ID
4.1.Q1
All British and Irish citizens, and foreign nationals with permission to be in the UK, who are above an agreed minimum age will be eligible. Are there any other groups that should be included?
Everyone
ADVP Response
The government is conflating ‘digital identity’ with ‘right to be in the UK’. Anyone should be able to establish a digital identity.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
4.1.Q2
Which of the following ages do you think is most suitable to access the digital ID system from?
Everyone
ADVP Response
Different age groups require different Digital Identity propositions. The government should work with the market to develop specific certified solutions for specific demographic needs.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
Chapter 4.2: Unlocking access across society
4.2.Q1
Some people may face barriers to creating or using the national digital ID. Are you aware of any other barriers not captured in the consultation?
Everyone
ADVP Response
ADVPs discussions with various civil society groups have raised significant concerns about privacy & surveillance related to a Digital ID and its proposed use. It is evident by the 3 million signatures opposing the government’s proposal to introduce a mandatory National ID for Right to Work that many people are fearful of the power that a national digital identity places in the hands of a future government.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
4.2.Q2
Is there any particular support not captured in the consultation or the Digital Inclusion Action Plan that would help you or other people to use the national digital ID?
Everyone
ADVP Response
ADVP believes that people should have the choice between the digital ID and identity documents such as passport, driving licence, mDL, consistent with the DVS framework.
People should be able to use their personal data where they choose, under their own control with confidence in how the data will be used and processed. This in turn would help to maximize inclusion in a future digital economy.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
4.2.Q3
Are there any groups not included in the list that you believe could also be at risk of ID or digital exclusion?
Everyone
ADVP Response
The ADVP is engaging with other stakeholder groups to answer this question.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
Chapter 4.3: Commitment to supporting inclusion
4.3.Q1
What kind of support should be made available to people who do not have a digital device to enable them to create and access the digital ID?
Public
ADVP Response
The ADVP is engaging with other stakeholder groups to answer this question.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
4.3.Q2
We are considering dedicated accessible support for those who are digitally excluded, delivered locally by trusted organisations. Are there any other ways government should consider supporting those who are digitally excluded?
Experts & Orgs
ADVP Response
The ADVP is engaging with other stakeholder groups to answer this question.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
Chapter 4.4: Accessibility
4.4.Q1
The government intends to engage with organisations outside government to help ensure the digital ID system is accessible. Can you suggest any specific organisations which the government should engage with?
Everyone
ADVP Response
The ADVP is engaging with other stakeholder groups to answer this question.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
Chapter 4.5: Alternative access routes
4.5.Q1
We are exploring alternative ways to access the national digital ID for those who cannot use a device. What do you think are the most important barriers for government to address?
Everyone
ADVP Response
The ADVP is engaging with other stakeholder groups to answer this question.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
4.5.Q2
If you are someone who does not use a digital device, what would you want from an alternative access route?
Public
ADVP Response
The ADVP is engaging with other stakeholder groups to answer this question.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
5
Trust in the government's digital ID
Part 5 covers how the system will be designed to protect people’s data. It discusses technical security measures, data protection standards, how people can exercise consent and control, and how the system will be governed and overseen.
Chapter 5.1: Data protection and privacy
5.1.Q1
Are there any additional measures, beyond the principles and standards set out in the consultation, that we should consider to further protect user data?
Public
ADVP Response
As with all service providers under the DVS Trust Framework, there should be independent audit of all identity and data services provided by government. People should have genuine choice on whether to use government identity services or those of an equivalent provider.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
5.1.Q2
Principles of data minimisation and user control will be central to the digital ID system. How should the government ensure transparency around how national digital ID data is used?
Experts & Orgs
ADVP Response
OfDIA should be independent of government in the way that the Bank of England is independent of HM Treasury.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
Chapter 5.2: Securing the national digital ID system
5.2.Q1
Are there any additional security safeguards that should be considered in relation to the national digital ID system?
Everyone
ADVP Response
Yes, the government’s recently published National Fraud Strategy largely overlooks the importance of the DVS Trust Framework in the fight against fraud – and does not even use the correct name for it.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
Chapter 5.3: Fraud as a national challenge
5.3.Q1
We want to ensure alternative access routes are secure. What do you think are the most important factors we need to consider to achieve this?
Everyone
ADVP Response
This question implies that a national digital ID will ‘solve’ fraud. This is naive. Fraud must be addressed systemically – not through a point solution.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
5.3.Q2
What do you think are the most important factors to consider when ensuring alternative access routes are not misused by fraudulent actors?
Everyone
ADVP Response
Digital ID systems must continuously evolve security measures. Aggregating identity data in one system increases the risk that a single data breach or design flaw can expose millions.
Similar schemes (e.g. Singapore, EU’s upcoming wallet) are incorporating advanced biometrics, encryption, and strict data-minimization to guard against emerging threats.
As direct impersonation gets harder, fraudsters pivot to new methods: social engineering (phishing users’ logins, as seen with hundreds of SingPass thefts), malware (stealing saved credentials), deepfakes (to fool facial checks), and even recruiting insiders or victims to share their digital IDs for cash.
ADVP believes the government needs to consult with industry and to leverage the DVS Trust Framework to design a broad industry approach to the issue of fraud.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
Chapter 5.4: Ensuring strong oversight and governance
5.4.Q1
What additional oversight mechanisms, if any, should be put in place for the national digital ID system?
Experts & Orgs
ADVP Response
As stated above, OfDIA should be made independent from government and should provide governance over the DVS Trust Framework within which the government’s solution should sit.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
5.4.Q2
What measures can you suggest that could be put in place to make sure people can resolve issues with their national digital ID?
Experts & Orgs
ADVP Response
The ADVP will provide a response on this question in due course.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
5.4.Q3
What additional oversight mechanisms, if any, would help you to have trust in the national digital ID system?
Public
ADVP Response
Independence for OfDIA for setting detailed identity policies in a similar manner to the Bank of England with regard to monetary policies.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
5.4.Q4
What measures do you think should be in place to help you feel confident in resolving any issues with your national digital ID?
Public
ADVP Response
The ADVP will provide a response on this question in due course.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
6
Wider considerations
Part 6 outlines the government’s early assessment of the potential impacts of the system, from building more efficient public services to reducing friction in the wider economy.Part 5 covers how the system will be designed to protect people’s data. It discusses technical security measures, data protection standards, how people can exercise consent and control, and how the system will be governed and overseen.
6.1.Q1
Do you think there are any other benefits for businesses from introducing the national digital ID system that have not been considered?
Everyone
ADVP Response
The proposal in its current form will have significant impact on the private sector companies operating under the DVS Trust framework with the potential for significant job losses, lower growth and reduced tax revenues from one of the UK’s fastest growing fintech sectors. Our estimates suggest that by 2035 the revenue from the sector could be £2bn per annum lower than based on current projections, 12,000 fewer jobs & a fiscal impact of £1bn lower taxation revenue for government.
ADVP also believes that the current proposal is not compliant with several aspects of the UK’s Competition & Markets Authority (CMA) Legislation.
The market of Digital Verification Services is a rare example of rapid growth, high productivity job creation and innovation.
The government’s consultation recognises that its current policies will damage this market. Its national digital ID should be designed to complement – not compete with – the DVS market
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
6.1.Q2
Do you think there are any other costs to businesses from introducing the national digital ID system that have not been considered?
Everyone
ADVP Response
Yes, many. The ADVP will set them out below in due course.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
6.1.Q3
Do you think there are any other benefits for households from introducing the national digital ID system that have not been considered?
Everyone
ADVP Response
Most of the benefits described in this consultation do not relate to a national digital ID but to reform of public services – which will be much more complicated and expensive to deliver than the government has understood.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
6.1.Q4
Do you think there are any other costs to households from introducing the national digital ID system that have not been considered?
Everyone
ADVP Response
The benefits, although the cost benefit analysis has not yet been carried out by the OBR, ascribed to the digital ID in ADVP’s view can largely be achieved and delivered at lower cost by government working with certified DVS providers to design a trust framework fit for a digital economy.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
6.1.Q5
Do you believe there are any other wider impacts from introducing the national digital ID system that have not been considered in this consultation?
Everyone
ADVP Response
The government has opened up an old and contentious subject: national digital identity. It has once again divided society on a subject where a high degree of consensus had been achieved through the DVS Trust Framework. The ADVP proposes that we should work constructively with government to address the pernicious blight of fraud and misinformation.
Further information
The ADVP will provide a further, more detailed explanation of our position in the next few days.
Have your say
The consultation is open until 5 May 2026. Your views will help shape the design of the UK’s national digital ID system.
The Association of Digital Verification Professionals represents the UK’s trusted digital verification industry. We champion privacy, security and consumer choice.
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