The national system is one of the most significant, and controversial, digital projects ever embarked upon by government. Amid the conjecture and criticism, PublicTechnology examines what we know so far.
Since being unveiled in September, the government’s plan for a new national digital identity regime has not been short of detractors.
Anyone wishing to engage with criticism of the proposals could turn to any of the Labour government’s rivals, with all other major UK parties – across the breadth of the political spectrum – disparaging the plans. Others seeking critiques could simply search for ‘digital identity’ on any social media platform and see what people – so many people – have to say on the matter.
But, then again, according to Matthew Feeney, advocacy manager at Big Brother Watch: “It’s not very easy for me to criticise the digital ID policy – because there isn’t one yet. The government announced this in September and, since then, we’ve been waiting for a consultation, and we’ve been waiting for legislation – and we [recently] learned that this consultation, which we were expecting in a few weeks, is going to be kicked down the road until 2026.”
Speaking at a recent panel discussion organised by think tank the Institute for Government, Feeney told attendees that – speaking theoretically, at least – he believes that “not only will this likely not work, but I think there’s significant privacy and security concerns”.
“One of those is that this kind of scheme would turn us into the kind of society that the UK has traditionally rejected – which is a permission-seeking, ‘papers, please’ kind of society,” he said. “We don’t exist at the permission of the state – we go about our lives, getting public services by using identification methods that range, and that we can pick from.”
Feeney added: “It also seems to me that, for this to be effective, to do what the government wants it to do, the government will need a bird’s-eye view of the data, [including] when it’s being used, how it’s being verified, and, if not direct data gathering, at least metadata gathering, and I think that may be a rather attractive target for criminals and foreign adversaries.”
Others have different theories, not least Morgan Wild, the chief policy adviser for Labour together and co-author of the report Britcard: a progressive digital identity for Britain – a policy paper widely credited as informing prime minister Keir Starmer’s subsequent proposals.
Wild told the IfG event that a digital identity programme will “help us do three things better – if we do it right”.
“Firstly, I think we have to accept the pragmatic reality where we have lots of different ID systems in the UK already – the government has your data in all kinds of different nooks and crannies of the stat, of varying levels of security,” he said. “And the fact that we don’t treat that data well, at the moment, contributes to injustices that ordinary citizens face as a consequence: most famously in recent years, the Windrush scandal [can be laid] at the door, partially, of poor data-management processes.”
Wild added: “Secondly, this makes everyone’s lives a little bit easier – if you’ve got digital ID, it’s gonna be an easy way of accessing public services, and it’s gonna be an easier way of proving who you are to various businesses… Thirdly, I think it’ll help with illegal migration. It won’t be a silver bullet, but it will make Right to Work and Right to Rent checks more effective. The way it will do that is by providing an audit trail to the state of when those checks have been conducted. The Home Office [currently] has no idea… if any of your employers have done their checks. At the moment it is, to a large extent, enforcement theatre.”
While, to Feeney’s point, neither proponents nor opponents of digital ID can say exactly how the technology will work in practice, details of government’s thinking concerning the operation of the new regime have begun to emerge.
So, what do we know so far?
Do we already have digital ID?
Since 2022, citizens and companies have been allowed to use digital identity to complete the Home Office’s Right to Work and Right to Rent checks. These processes can be completed using one of a current total of 57 ID third-party ID services that have been accredited via a government certification administered by the Department for Science, Innovation and Technology.
Under the PM’s proposals, pre-employment checks – based on a state-issued ID – will be mandatorily digital by the end of this parliament in 2029.
These digital credentials will contain the holder’s name, date of birth, nationality and residence information, and a photograph – which will be used for biometric checks.
The ID and supporting services are being developed by DSIT’s Government Digital Service, while the Cabinet Office recently took assumed control of policymaking requirements and any necessary amendments to the UK’s legal framework, as well as broad oversight of implementation.
The new identity will form part of a growing suite of electronic documents formally issued by government – beginning with a new digital version of the Veteran Card, which was launched in October. This will be followed by digital driving licences, National Insurance cards, marriage and birth certificates, and status evidence of the completion of a Disclosure and Barring Service check. Also digitised will be documents confirming lasting power of attorney, and proof of receipt of state benefits such as Universal Credit, Disability Living Allowance, and Personal Independence Payment.
Government has also indicated that it intends, at some point, to offer a digital version of the passport – although this is not likely to be useable for international travel in the near-term.
Users will be able to store all these documents, as well as the mandatory digital ID for employment checks, on their smartphone – with the plan being to offer a ‘GOV.UK Wallet’ where all forms of state identity can be kept. Officials are also actively exploring the possibility of enabling storage via the wallet platforms offered by Apple and Android.
At the launch of the new virtual Veteran Card, digital government minister Ian Murray told PublicTechnology: “Using a closed group like the 300,000 veterans is a really good case study to show that [digital ID] does work, and it will be very beneficial. It shows the technology works, and it shows that we can prove [that], and dispense with some of those – legitimate – concerns around privacy and security.”
How will this apply across the UK – and beyond?
Government’s plan is for the new identity system to be introduced throughout the four countries of the UK.
Answering one of a vast number of recent parliamentary questions on issues related to digital ID, Murray said that “the government has engaged with the devolved governments… and will continue to work closely with [them] throughout all stages of the programme’s development”.
There have been particular concerns about the potential impact of the scheme across the island of Ireland. Since the Good Friday agreement of 1998, Northern Ireland’s inhabitants have the right to hold either British or Irish citizenship – or both. Citizens of the Republic, meanwhile, retain the right to live, work and travel freely in the UK – irrespective of Brexit.
Since the digital ID plans were announced, ministers have repeatedly stressed that the technology will be introduced without jeopardising “the commitments in the Good Friday Agreement, the Windsor Framework and the Common Travel Area”.
There are, as yet, no specific details of how these commitments will be protected.
Further afield, it is understood that British Overseas Territories (BOTs) and Crown Dependencies will be offered opportunities and support to adopt the UK’s new digital identity system – but it will up to local legislators to decide the extent to which to do so.
This includes the three dependencies of Jersey, Guernsey and the Isle Man, as well as 14 overseas territories, including: the Cayman Islands; Bermuda; Gibraltar; the British Virgin Islands; the Turks and Caicos Islands; Akrotiri and Dhekelia; Anguilla; the British Antarctic Territory; the British Indian Ocean Territory; the Falkland Islands; Montserrat; the Pitcairn Islands; Saint Helena, Ascension and Tristan da Cunha; and South Georgia and the South Sandwich Islands.
While all of these are largely self-governing, Westminster has far greater power to unilaterally legislate in the overseas territories. However, while it is understood that the 270,000 people that live across the 14 areas may be able to obtain a digital ID, it will down to local governments to decide whether to fully adopt a similar regime as in the UK.
The same choice will also face legislators in the Channel Islands and the Isle of Man. Any regions that do wish to fully adopt digital ID will be supported by central government to do so.
Will ID be offered to children?
Because digital identity will be mandatory in employment checks, electronic IDs are expected to be issued to all citizens as they pass their 16th birthday – as is the case with National Insurance numbers.
Those aged over 16 at the time the regime is introduced will need to apply for an ID if and when they are required to complete a Right to Work check.
Government has also previously indicated that the rollout may be extended to children as young as 13 – who, in a number of local-council areas, can be legally employed for part-time roles. In regions where this is not the case, the minimum age for paid employment is 14.
The potential expansion of the new identity programme to cover children of legal working age will be subject to an upcoming public consultation, which will seek feedback on numerous policy and operational aspects of the plans.
Ahead of this process, Cabinet Office minister Josh Simons espoused the potential benefits of providing children with a digital ID document.
“Extending the national digital credential scheme to include 13–16-year-olds could streamline administrative processes involved in employing young people,” he said. “Inclusion of this age group could also support children’s online safety by supporting age verification for online services in line with the Online Safety Act 2023.”
“We are currently exploring best practice from other countries with digital identity schemes and other private sector companies who have digitised their services in order to develop the set of proposals to take to public consultation.”
Cabinet Office minister Josh Simons
Will there be physical ID cards?
The 30 or so Labour MPs who have been in parliament long enough to remember the party’s last spell in government are likely to have unhappy memories of previous attempts to introduce a national identity card scheme.
But, despite Tony Blair’s much-maligned attempt to introduce such a programme, his party’s current leaders have resurrected the possibility of the dreaded ID card.
Asked about whether government’s new identity plan might include alternative options to the electronic document and support for the digitally excluded offered over-the-counter via Post Offices, Simons said: “We are considering options like a digitally enabled physical alternative for those without access to technology, as well as in-person onboarding support for those who struggle to engage digitally. This may include Post Offices but that decision has not yet been made and will depend on several different factors.”
What about digital exclusion?
Questions regarding in-person support mechanisms and alternative ID options form part of a wider disquiet from some critics regarding the implications of the new regime for those lacking access to technology, or the confidence to use it.
The latest statistics from Ofcom show that 6% of UK adults do not have internet access at home – a figure that rises to 15% for those in the D or E social grades and 21% for over-65s. A total of two million people aged over 16 do not currently go online at all, according to the communications regulator.
Some 4% of households do not possess a smartphone, including 11% of homes with a total annual income of less than £26,000, and 18% of those inhabited by over-65s.
To help support these people, the government earlier this year published a Digital Inclusion Action Plan – the first nationwide strategy dedicated to tackling tech exclusion in over a decade.
The introduction of digital ID will augment, rather than impede this plan, according to ministers, who have pledged that the rollout will be accompanied by the “largest ever digital inclusion programme ever delivered in this country”.
Digital government minister Murray said: “The government will deliver a comprehensive inclusion programme to help ensure everyone eligible is able to access the new digital ID. This will include targeted support for both people and businesses who may struggle to access or engage with digital services or devices.”
He added: “The inclusion programme could also have wider benefits for people who are currently digitally excluded, such as enabling them to access wider benefits of being online such as getting support with the cost of living and the public services they are entitled to.”
2022
Year in which Home Office rent and employment checks began allowing the use of digital ID
57
Number of third-party ID services currently accredited via government’s standards framework
One in nine
Proportion of households with less than £26,000 annual income that do not possess a smartphone
13
Minimum age at which digital ID could be made available
Where will data be hosted?
Amid concerns about the data sovereignty and cybersecurity implications of the new ID regime, government has pledged that all data gathered and processed by the initiative will be hosted in IT storage facilities based in the UK.
Many government agencies now rely heavily on public cloud services delivered by US-based vendors – chiefly Amazon Web Services, whose clients include the Cabinet Office and DSIT, which are jointly working on delivery of the new national digital ID.
While data related to the new virtual identity will be kept in a cloud environment, the physical datacentre facilities used for this storage will be situated in the UK, according to junior Cabinet Office minister Simons.
“Data associated with the digital ID system will be held and kept safe in secure cloud environments hosted in the United Kingdom,” he said recently. “The government will work closely with expert stakeholders to make the programme effective, secure and inclusive, including taking insights from previous IT projects where appropriate.”
The technical details of the identity system will be one of many policy and operational aspects of the programme that will be covered by the upcoming public consultation, which is expected to launch in the new year. The results of this process will help shape the design and delivery of the scheme over the coming years, according to Simons.
“The government will conduct a full public consultation on the new digital ID to inform our approach,” he said. “We are currently exploring best practice from other countries with digital identity schemes and other private sector companies who have digitised their services in order to develop the set of proposals to take to public consultation.”
How much will it cost?
The TL; DR answer to this one is easy: we do not know.
However, government’s independent fiscal watchdog, the Office for Budget Responsibility, has not only cited a precise figure – £1.8bn of public money over the next three years – but claimed that the required funding does not currently exist anywhere on Whitehall’s current budgets and balance sheets.
But the plot thickens, as ministers have said that government “does not recognise” the numbers provided by the OBR – which is comprised of £1.3bn in upfront capital funding and £500m in day-to-day operational costs of programme delivery. Representatives have also repeatedly insisted that, whatever amount is required, it will be met from existing departmental budgets set at the spending review earlier this year.
This mystery and mixed messaging has already led to some uncomfortable exchanges. There may be many more ahead.
