Association of Digital Verification Professionals
Cabinet Office Consultation • CP 1498
The Government Consultation
The government has consulted 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
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
The Government needs to overcome embedded resistance, skepticism and lack of understanding across much of the UK by adopting a proven solution already demonstrated by its partnership with the private sector.
A significant risk is that direct government provision of identity services, particularly where subsidised or preferentially integrated, may distort a functioning market.
The UK already has an established Digital Verification Services ecosystem, and policy interventions should be carefully scoped to avoid duplicating existing capabilities or undermining private sector investment and innovation.
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 extent to which the system improves ease of use will depend upon the detailed context. Some people have difficulty in some contexts for specific reasons. Many people do not have difficulty. In the vast majority of cases ‘ease of use’ requires more than identity data and re-engineering of downstream systems and processes. The cost benefit case to the economy needs to be carefully assessed.
In principle, allowing individuals to select from a range of certified identity providers and wallets will improve adoption and usability, as it enables services to better reflect diverse user needs and existing behaviours.
Reframed correctly, ADVP’s position is that ease of use improves where identity can be reused across multiple contexts, supported by a choice of certified providers and complemented by reform of downstream service processes.
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 presupposes that the government’s design for a digital ID system will enable more modern, efficient and personalised public services at a cost that represents value to the economy. The government should present the instances of where it thinks this is the case.
Priority should be given to enabling consistent acceptance of voluntary, reusable, inclusive digital identity approaches, accredited to the trust framework, already set up by government. This should be across key sectors where identity is repeatedly required, such as financial services, health, and telecommunications. The parity of acceptance of DVS accredited digital identity across these sectors would maximise user benefit by enabling reuse of verified credentials and reducing friction across everyday interactions.
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
It is most important that government operates to the standards and functional capabilities defined within its own, recently legislated DVS Trust Framework. This will clarify how the overall market will function openly, fairly and with citizen choice.
A clear separation of roles should be established, where government acts as the issuer of authoritative credentials, while storage and presentation of those credentials can be handled by certified wallets of the user’s choice. This separation supports interoperability, reduces systemic risk, and avoids unnecessary duplication of existing capabilities.
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
Public services aren’t one-size-fits all. Local challenges need local solutions, and a national digital ID risks distracting from that reality. Centralised top-down approaches can slow innovation, while bottom-up ecosystems let communities respond within shared national standards.
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.
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
Yes. Deletion isn’t the real issue, it’s what data is kept, why it is needed, and how long it’s held under GDPR. Deleting a digital ID doesn’t mean everything linked to it can disappear.
It’s a balance between personal control and system stability, letting people move their verified credentials between Holder Service Providers without breaking the trust or compliance that each credential brings. A single, fixed digital ID doesn’t offer that flexibility and, consequently, raises real ethical questions around deletion.
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
Yes. Rather than revoking it, the focus should be on managing risk through proportionate controls, ensuring people retain access while the system stays secure.
This approach shifts the focus from removing identity to managing risk, requiring consistent standards, shared safeguards, and strong oversight across the ecosystem.
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, enabling individuals to store their digital identity in certified wallets beyond a government-operated solution supports user autonomy, competition, and resilience. A multi-provider model reduces single points of failure and ensures that services can evolve over time to meet different user and business requirements.
The UK already has an established ecosystem of certified providers delivering identity services at scale. Allowing these providers to participate alongside government will help maintain innovation, support economic growth, and provide better outcomes for users through competition and choice.
A model in which government focuses on issuing trusted credentials, while enabling their use through a range of certified providers, is more consistent with a competitive and resilient ecosystem than one in which government directly provides end-to-end services.
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
Introducing a government-operated checker service in a market where equivalent capabilities already exist risks duplicating provision and distorting competition. Any such intervention should be clearly justified by evidence of market failure and designed to complement, rather than compete with, existing services.
The creation of a government checker service would be a major threat to the private DVS sector and even consideration of such a service by government is already impacting investor confidence.
Several DVS providers are already offering free Right to Work (RtW) and Digital ID checking services to the third sector as part of wider offerings. These market developments need to be encouraged. Announcing a free government service undermines these developing initiatives before they have begun.
Where government assurance is required, this could be delivered through certification, audit, and revocation signaling to accredited providers, rather than direct transaction-level checking. This would preserve trust while avoiding unnecessary market duplication
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
Government’s role should focus on setting standards, certifying providers, and ensuring trust across the ecosystem. Direct provision of services should be limited to clearly defined public interest use cases where market solutions are insufficient.
If a government checker is introduced, strict safeguards should apply, including clear limitations on scope, transparency on cost and operation, and ongoing independent review to assess market impact. This would help ensure that any intervention remains proportionate and does not displace existing providers.
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
The system should adhere to the principle of data minimisation. Rather than embedding additional attributes within a single identity record, government should issue separate, verifiable credentials that can be selectively disclosed as required. This approach reduces risk and enhances privacy.
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
A static address field on a digital ID is sub-optimal, it lacks wider utility and is, as a consequence, unlikely to remain accurate. It also does not meet requirements where multiple concurrent and historical addresses are required.
Maintaining an address on a digital ID will add significant costs and complexity.
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
There are already laws regarding the deliberate provision of misinformation. It is when a digital ID is used that responsibility for the veracity of the information matters. If a person uses a digital ID that he or she knows is inaccurate then the liability should fall on that individual.
A legal obligation on individuals to update their data risks placing an unrealistic burden on users and may undermine adoption, particularly for those who are already digitally or socially excluded. It implies a change that is being done to people rather than for them. It raises practical questions of enforcement particularly for low-income workers or those on benefits.
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 are not technical. They stem from complex government policies and fragmented systems which have been incrementally changed by successive governments. There are also cultural issues and usability design issues.
Digital ID will not address this legacy. It requires a more holistic approach across the whole society, not just government — unlocking opportunity, protecting privacy, supporting local economic regeneration, and enabling more joined-up interventions.
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
Government’s policy decisions on matching citizen identity information across public services should not be conflated with government’s policy on issuing digital IDs to citizens. They are distinct processes and require distinct policies; like how government raises money (tax) is different to how government spends money.
The narrative of the consultation “Making public services work for you with your digital identity” implies that policy makers believe them to be one and the same thing.
Centralised matching systems risk causing unintended harm at scale when local conditions and sub-group variations are not understood. A better approach prioritises local accountability, user control, interoperability, and independent oversight.
This would be very difficult to achieve without seamless interoperability across government departments and across public and private sector wallets.
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
How government identifies and matches its citizens across the different branches of government determines the kind of society we want to create.
There is a danger of function creep leading to unintended profiling, or exclusion of individuals with non-standard identity records. Strong governance, civil society involvement and clear purpose limitation would be essential to deliver public trust in such a system.
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
In a person-centric data economy, supporting people to live well means shifting to user-led demand where individuals can find and access services seamlessly, regardless of whether they come from the public, private, or third sector.
Matching mechanisms should be planned transparently. They should prioritise accuracy and proportionality. Reliance on simple deterministic matching of personal data is likely to result in errors and exclusion.
Instead, systems should use assurance levels, credential-based verification, and appropriate safeguards, including human oversight where that is required.
Technical design should prioritise interoperability, inclusion, accessibility, privacy, and resilience. This includes avoiding centralised data stores, enabling reuse of verified credentials, and adopting privacy-enhancing technologies such as tokenisation and selective disclosure.
Leveraging existing DVS trust framework standards will reduce risk and accelerate delivery.
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
If the government’s goal is participation and inclusion, then people should be able to use all appropriate means.
A market of certified DVS providers is the most effective means of ensuring participation and inclusion. The government should identify underserved segments of the population and work with the market to meet their needs.
Choice is essential. Restricting different digital ID solutions limits reuse, entrenches fragmentation, and reinforces siloed systems, replicating the inefficiencies’ digital identity is intended to resolve.
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
Employers will be faced with trying to prove RtW for those employees who do not have a passport, share code or digital identity (assuming it is not compulsory to have one) or do not want to do a RtW check via digital (remote) means.
There are still many employers who conduct RtW checks in person (checking physical documents) as that fits their onboarding process. Making all RtW checks digital will require many employers to change their onboarding process. Given the current choice of RtW checks available to employers and employees allows both parties to select the best route to fit their process/circumstances and that the vast majority of illegal workers are detected when the employer uses a DVS provider to support all checks (including in person checks) then a less disruptive approach for employers would be to compel all employers to use a DVS to support all RtW checks – the vast majority of which would be digital anyway.
The good news is that the DVS sector already conducts over 5 million Right to Work checks each year and could complement and accelerate delivery by regenerating reusable Right to Work credentials within 12 months, bringing key immigration policy outcomes forward by up to two years. This approach offers a pragmatic, lower-cost pathway that minimises taxpayer burden. With appropriate regulatory support, DVS providers are ready to step up and accelerate delivery of these outcomes.
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.
If the government mandates every employer to use a DVS provider to support all checks (digital and physical) then the DVS market will be better placed to grow adoption than a direct government solution.
DVS Providers should be mandated to provide quarterly data to Home Office as to how many employers they have using their solution, how many checks are carried out and where possible how many attempts at illegal working they have prevented. This approach will speed up the number of digital RtW checks carried out, reduce illegal working and give political leaders the evidence that illegal working is being detected and prevented.
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 can obtain a statutory excuse from a fine by using a DVS Provider.
Clearer rules are needed around responsibilities and liability for identifying and reporting fraudulent documents. At present, this burden largely sits with the employer. If the employer is not a member of CIFAS, they are unable to use its services, creating a gap in fraud reporting. To resolve this better alignment is required around rules concerning GDPR, Right to Work and accountability for reporting attempted fraud.
To join CIFAS, DVS providers need to operate as a data controller. This does not align with some Relying Party models that require Right to Work providers to act as data processors. UK GDPR guidance is silent on Independent Data Controllers, although this in better defined within EU guidance. This causes confusion and better guidance is required to both employers and the DVS sector. The result is that there is confusion in the market as to who is responsible to reporting fraud to whom and when. Resolving this requires alignment between GDPR, Right to Work and fraud reporting.
Currently, when an employer conducts a RtW check via a DVS (digital or non-digital), the employer is provided with a report confirming RtW by the DVS provider. The Home Office could strengthen this further by compelling DVSs to provide the intelligence/data flow as set out in 3.4Q2. It could also consider replicating the DBS Supplementary Code and require a DVS to provide a unique identifier for every RtW check conducted so auditing by Immigration Enforcement would be easier and less costly.
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’. Any citizen should be able to establish a digital identity. The entitlement of the person represented by a digital identity is a matter of policy, which varies.
A truly inclusive system must allow people to participate on their own terms, not just the state’s.
Crucially, those who choose not to adopt a government issued digital ID, whether out of principle or practical grounds, should not be excluded from digital participation.
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.
Access should be guided by purpose, not a single age threshold. Sometimes a digital ID might be used to support participation in which early access is both appropriate and beneficial for example health and education.
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
Many people are fearful of the power that a national digital identity places in the hands of a future government that chooses to mandate it.
Barriers to adoption are often cultural and extend beyond technology, including access to documents, devices, connectivity, difficulties due to a wide range of disabilities, and or the requisite digital skills and literacy. These factors are often interconnected and require a holistic approach to ensure that systems are accessible in real-world conditions.
The core issue is not identity technology itself, but how services are organised around people’s lives.
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
Trusted, in-person support delivered through existing infrastructure, such as high street services, local authorities, libraries, and professional advisory services, will be critical.
Assisted digital pathways should be available throughout the user journey, not only at onboarding. For the majority of people, this means commercial organisations.
While the consultation centres on a new national ID and the broader transformation of public services, there is a lack of clarity around how that transformation will be achieved.
Regional pilots would help inform policy while engaging the public through practical delivery. If successful, it would generate lessons that can be replicated elsewhere.
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
Digital exclusion is a complex matter. Exclusion is best addressed by diversity and enable people choice and control.
One group that warrants explicit consideration are victims of identity theft or identity misuse. Such individuals may face additional barriers when enrolling in or using a digital ID, particularly where existing records have been compromised or disputed. Targeted support pathways, clear recovery processes, and access to specialist assistance will be essential to ensure that digital ID systems do not inadvertently exacerbate harm for these individuals.
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
Alternative access routes should provide equivalent outcomes to digital channels. Individuals should be able to establish and use their identity through supported, in-person processes without being disadvantaged.
It is also important to recognise that digital exclusion may be a matter of choice rather than capability. Alternative identity routes must therefore remain available on an ongoing basis and not be treated solely as transitional measures.
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
Eligibility should be designed to maximise inclusion, particularly for individuals without standard identity documents, those with complex circumstances, and those interacting across multiple services. Multiple pathways to establish identity will be essential to avoid exclusion.
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
Digital exclusion is rarely just about technology, it is about confidence, trust, and connection. Embedding support into high street and community spaces helps make digital identity feel relevant and useful.
Locally delivered, trusted support is essential, but it needs to go further by being embedded into everyday life, not treated as a separate service.
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
If we apply the concept of forward guidance to digital identity, it is about setting out a clear, credible direction of travel for the market over the next 10 years based on an honest assessment of technology, regulation, and societal needs. Creating this clear ‘to-be’ market vision requires input from the Competition and Markets Authority to safeguard choice, prevent concentration, and ensure the market works for the whole of society.
The current debate is framed largely around eligibility for services, for example, RtW and the technical transformation of public services. This risks overlooking a more fundamental reality: this is a cultural shift towards participation and access across the whole economy.
If key key government departments and parts of the economy, particularly relying parties, choose not to participate, the success of the entire system is put at risk. For organisations to invest in the future, they need certainty that extends beyond the lifetime of one Parliament.
With this in mind, the Competition and Markets Authority can play a key role to ensure the DVS market remains competitive, avoids concentration of power, and is not distorted by major relying parties not to participating.
This also supports wider national resilience, ensuring that critical digital identity infrastructure does not become overly dependent on a small number of providers, particularly those outside UK control.
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
Trusted, in-person support delivered through existing community infrastructure, such as high street services, local authorities, libraries, post offices, and advisory services, could be critical. Assisted digital pathways should be available throughout the user journey, not only at onboarding.
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.
Additional safeguards should include the use of privacy-enhancing technologies, clear separation between issuance, storage and verification functions, and strong user controls over how data is shared. These measures will reduce risk and strengthen trust.
The national ID task force needs to recognise the concept of multiplicity of identity – where a single individual can hold multiple accounts or personas, each underpinned by their verified legal identity but not exposing it by default.
This shifts the model to reflect lived experience – one person, many context-specific identities. This has the additional advantage of protecting someone’s data and privacy. This can only be delivered by the private sector and requires the new National ID to fit within this broader structure rather than supplant it.
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
The principles of data minimisation and user empowerment are not delivered by a single system or national ID. They emerge from a connected ecosystem, one that gives individuals real control over how their data is used, shared, and reused.
In this model, data is not copied and stored repeatedly across organisations. Instead, it is held once, shared with consent, and accessed only when needed. This reduces duplication, lowers risk, and improves accuracy.
Transparency is not something that sits behind the scenes, it is designed into every interaction. Individuals can see who is requesting their data, why it is needed, and what will happen next. Trust is no longer based on central control, but on clear rules, interoperability, and accountability across providers.
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 overlooks the need for the DVS Trust Framework. This is a major oversight.
Fraud will only be addressed if it is addressed systemically through services that have been certified against well-defined and governed standards.
Fraud conducted through digital channels is growing rapidly. The government should prioritise working with providers under the DVS Trust Framework to develop systemic fraud mitigations.
Trust is the core of trade and transactions. The UK should recognise the advantage that the DVS Trust Framework represents to the digital economy. The Trust Framework will be more effective at countering fraud than a single government built digital ID solution.
Individuals should be able to see when their identity data has been used, which organisations have accessed it, and for what purpose. Clear communication of roles across the ecosystem will also be important to support understanding and trust.
As with financial services, resilience comes from choice and plurality. Allowing individuals to use multiple certified DVS providers reduces systemic risk, avoids concentration of power, and strengthens accountability through competition.
A national digital ID system must ensure that individuals retain continuous, sovereign access to their identity and personal data, regardless of geopolitical pressures. This includes maintaining access during disputes, sanctions challenges, or legal appeals, where access to that data may be essential for them to seek legal recourse.
The policy challenge is clear: how to balance security and compliance with the fundamental right of individuals to have access and control their own data as a human right.
In a world of interconnected systems, safeguarding identity is no longer just about privacy, it is about national resilience and individual freedom.
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
Digital Verification Service (DVS) providers exist for a single purpose: to safeguard identity data, protect it rigorously, and share it only with explicit user consent. In that sense, they operate much like banks — built on trust, custody, and duty of care.
By contrast, most other organisations in the ecosystem, specifically Reliant Parties – including public authorities and central government, have broader objectives. They may handle personal data, but protecting it is not their sole mission; it sits alongside commercial and operational priorities.
That distinction matters. It places the DVS Providers, and specifically Holder Service Providers, in the realm of critical national infrastructure.
As with financial services, resilience comes from choice and plurality. Allowing individuals to use multiple certified DVS providers reduces systemic risk, avoids concentration of power, and strengthens accountability through competition.
Similarly, within the DVS Trust Framework, a plurality of certified providers provides options for the victims of fraud. If one provider is compromised or access is restricted, individuals must be able to recover through another. This allows for clear, user-led recovery pathways, enabling individuals to quickly re-establish trust and regain access without being excluded from essential services.
In combination, a system built on specialist DVS providers, interoperability, and choice will be far more secure, resilient, and responsive to the needs of fraud victims than one reliant on single National ID Provider alone.
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
Ensuring alternative access routes are not misused by fraudulent actors is less about restricting access, and more about strengthening the trust fabric that sits behind it.
First, shared fraud signals are critical. Today, digital identity providers detect valuable intelligence—fake document types, impersonation attempts, sector targeting—but there is no consistent mechanism to share this across the ecosystem. Without shared signals, fraudsters exploit the gaps between providers. A coordinated, near real-time approach allows patterns to emerge quickly and creates a collective defence.
Building on this, there is a clear need for operational intelligence sharing data gathered centrally and distributed for local enforcement. This means intelligence is not just collected, but actively used: informing frontline decisions by employers, landlords, and financial institutions, while also supporting targeted action by enforcement agencies. A central hub can aggregate signals across providers, enrich them, and push actionable insights back out to those who need them most.
Closely linked is threat intelligence, the structured analysis of fraud patterns, behaviours, and tactics. This goes beyond raw data. It answers questions such as how attacks are being carried out, why certain sectors are targeted, and where vulnerabilities exist. Threat intelligence transforms individual incidents into foresight, enabling both providers and government to anticipate and disrupt emerging risks rather than simply reacting to them.
Second, live, dynamic intelligence must replace static datasets. Fraud evolves quickly, and legacy databases that are not updated in real time lose effectiveness. Intelligence should flow continuously between providers, enabling rapid identification of repeat offenders, emerging document vulnerabilities, and organised crime linkages.
Third, consistent assurance standards are vital across all access routes. Alternative methods such as vouching or assisted digital journeys are essential for inclusion, but they must operate within structured, auditable frameworks aligned to standards like GPG 45. Trust should be derived from defined processes, not individual judgement.
Fourth, public and private sector collaboration is essential. Industry often detects fraud at onboarding, while government holds broader enforcement insight. Integrating these perspectives improves detection, response, and policy outcomes.
Finally, controls must address the full spectrum of fraud and be supported by incentivised intelligence sharing.
Ultimately, inclusion and security are not opposing forces, when connected through shared intelligence, they reinforce each other.
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.
OfDIA should have statutory independence in setting identity policy and standards, with clear separation from delivery functions, analogous in principle, though not form, to other independent UK economic regulators, in the way that the Bank of England is independent of HM Treasury.
Independent oversight, transparent reporting, and accessible redress mechanisms will be critical to maintaining confidence in the system. Users should have clear routes to challenge decisions and resolve issues, supported by timely and consistent processes.
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
Government departments should issue Verifiable Credentials in exactly the same way as private sector organisations. If there are issues with a Verifiable Credential, then the person to whom it was issued should ask the issuing body to resolve it.
If necessary, the independent OfDIA should be the point of escalation.
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
Government departments should issue Verifiable Credentials in exactly the same way as private sector organisations. If there are issues with a Verifiable Credential, then the person to whom it was issued should ask the issuing body to resolve it.
If necessary, the independent OfDIA should be the point of escalation.
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 market of Digital Verification Services is a rare example of rapid growth, high productivity with high overseas demand. 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.
Digital identity has the potential to act as enabling infrastructure across the economy, supporting secure data sharing, reducing duplication, and improving compliance processes. These benefits are maximised where systems are interoperable and reusable across sectors.
There are additional, high-value benefits for businesses that are not fully explored, particularly around new business models, risk management, data management, and how demand is created.
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, there are additional costs to businesses that are not fully considered, particularly those associated with transitioning to a fundamentally new data infrastructure.
Potential costs include integration with existing systems, ongoing compliance requirements, and adaptation to evolving standards. These should be minimised through alignment with existing DVS trust frameworks and reuse of established infrastructure, such as provided by the current marketplace of digital verification organisations.
In addition to integration and compliance costs, businesses face transitional duplication, uncertainty over liability, and stranded investment risk where government provision displaces existing certified digital verification services. These costs are magnified where policy direction is unclear, forcing organisations to maintain parallel identity processes during transition.
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 legacy services, which will be much more complicated and expensive to deliver than the government has understood.
While digital ID is an important starting point, the broader opportunity lies in personal data wallets and reusable credentials. Together, they can reduce exclusion and stigma, enable more personalised and joined-up support, and empower individuals with control over their data and their participation in society.
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 cost of delay. There are many benefits that can be delivered at lower cost to the taxpayer and more rapidly.
One area is the burden of digital participation. While digital ID is intended to simplify access, it also assumes a level of digital capability, device access, and confidence.
There is also a shift in responsibility. As data moves from organisations to individuals, households take on a greater role in managing their own data.
Another consideration is the risk of exclusion during the transition period. As businesses and public services adopt digital ID at different speeds, households may face inconsistent experiences, where some services require digital credentials while others do not. This fragmentation can lead to confusion, duplication of effort, and temporary barriers to access.
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.
The introduction of a national digital ID system has broader implications for market structure, competition, and the UK’s position in global digital identity standards and the financial and payments sector. A long term, coordinated, cross-government approach will be essential to ensure alignment with wider digital and economic strategies and to achieve GDP growth via harnessing digital identity and digital verification across the UK economy and allied smart data sectors. This requires the government considering the linkages across its industrial strategy, fraud strategy, growth strategy and smart data strategy. Digital identity is an underpinning fundamental layer for our economic growth as a nation for the coming decades, not just for public sector innovation.
There are wider impacts that extend beyond those considered in the consultation. The introduction of digital ID should be seen in the broader context of personal data wallets and reusable credentials, of which digital ID is only one component.
This represents a profound cultural and structural shift in how data is owned and used. Today, data largely sits with organisations, fragmented across systems. In a personal data wallet model, individuals hold their own verified credentials (identity, right to work, qualifications, financial signals) and share them with consent. This enables the reuse of trusted data across multiple interactions, rather than repeated collection.
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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