Challenge 25 is not itself the law. In England and Wales the Licensing Act 2003 mandatory conditions require the premises licence holder to adopt an age verification policy, and they set the floor: anyone who appears under 18 produces identification with a photograph, date of birth and a holographic mark or ultraviolet feature before alcohol is served. Challenge 25 is the policy most premises adopt on top, raising the age at which staff ask to 25. A festival bar follows the same rules under a premises licence and a lighter route under a temporary event notice.
The mandatory condition sets the floor and Challenge 25 raises it
The condition sits in paragraph 3 of the Schedule to the Licensing Act 2003 (Mandatory Licensing Conditions) Order 2010, substituted from 1 October 2014 and amended on 15 September 2026. It has three parts. The premises licence holder or club premises certificate holder must ensure that an age verification policy is adopted for the premises. The designated premises supervisor must ensure that alcohol is supplied in accordance with it. And the policy must, at a minimum, require anyone who appears to the responsible person to be under 18, or under a higher age the policy names, to produce on request, before being served, identification bearing their photograph, date of birth and either a holographic mark or an ultraviolet feature. Since 15 September 2026 the policy may also permit digital identification checked through a registered digital verification service; the guide on digital proof of age for alcohol sales covers that route.
Nothing in the Order says 25. The statutory guidance under section 182 notes at paragraph 10.63 that a policy may set a higher trigger age such as 21, and at paragraph 11.30 describes premises running a Challenge 21 or Challenge 25 scheme as carrying out due diligence at the point of sale. The offence underneath is section 146 of the Act: selling alcohol to an individual under 18. The defence in section 146(4) and (5) is that the seller believed the person was 18 or over and took all reasonable steps, which the Act defines as asking for evidence of age that would have convinced a reasonable person. Asking at 25 rather than 18 makes that defence easier to rely on.
Three documents meet the condition in practice: a passport, a photo driving licence and a card carrying the PASS hologram. Paragraph 10.46 of the guidance says the Home Office encourages premises to accept PASS cards, while noting that many other forms of identification satisfy the condition. The 2014 Code of Practice on age restricted products asks enforcing authorities to promote PASS cards as the preferred proof of age for face-to-face sales and asks licensing authorities not to impose conditions that exclude them. A student card does not fit: it is not issued against an audited standard and does not usually carry a holographic mark or ultraviolet feature, so it falls short of the minimum.
How festival bars are licensed
A festival bar is authorised in one of two ways. The first is a premises licence; the mandatory conditions attach to it and a designated premises supervisor is named on it. The second is a temporary event notice, or TEN, a light-touch route for small events: fewer than 500 people at any one time including staff, no more than 168 hours, at least ten working days’ notice to the licensing authority with copies to the police and environmental health, and a £21 fee. A personal licence holder may give 50 TENs a year and anyone else five; a single premises may carry 15 TENs and 21 days of events in a calendar year, with 24 hours between events.
A TEN carries no conditions of its own. The section 182 guidance at paragraphs 7.28 and 7.38 explains that the licensing authority may impose conditions from an existing premises licence on a TEN only where the police or environmental health have objected and part of the premises is already licensed. The mandatory conditions do not attach to a TEN. The offences do: paragraph 7.29 reminds premises users that they remain liable for offences committed during the event, including persistently selling alcohol to children. A bar team under a TEN therefore checks age because of section 146 rather than a licence condition.
A pre-arrival check on the phone sits before the bar, not instead of it
VenueGo, a verification platform designed for venues, runs when the attendee signs up or buys a ticket. On their own phone they capture their face, then their document, then a photo of themselves holding it. UK, Irish and US passports and driving licences are accepted. The result is approved, declined or needs review, and an under-age decline is never retried into a pass. Images are deleted after 30 days unless a review is open, processing runs in London and data is stored in the UK.
That check happens days before the gate, on the attendee’s device, against a document in the camera. The mandatory condition is written around the point of sale: the responsible person sees the identification before serving. The digital route added in September 2026 is also tied to the point of sale and to a registered digital verification service. A pre-arrival check is neither. It gives the organiser a record of who has shown a document and who was declined before anyone reaches the gate. The challenge at the bar still happens for anyone who looks under the policy age.
What door and bar staff still do, and what to record
Paragraph 10.61 of the guidance says licence holders must ensure staff involved in supplying alcohol know the age verification policy, and paragraph 10.62 places personal responsibility on the designated premises supervisor for sales following it. Bar staff ask anyone who appears under the policy age for an accepted document and refuse the sale when none is produced. Under the digital route a phone screen is not inspected by eye: paragraph 10.47 says holders must not rely solely on visual inspection.
The mandatory condition does not require a refusals register. Conditions on an individual premises licence can, and paragraph 11.30 explains why records matter either way: where premises operate a responsible policy and can show due diligence, a licensing authority may take a proportionate view of an isolated failure; where they cannot, a review of the licence should be the norm, especially after a prosecution for persistent sales or a closure notice. The 2014 Code of Practice notes that enforcing authorities check training records and till prompts when they visit. A refusals log, a training record and a written policy show the policy exists outside the staff briefing.
Scotland puts the trigger age in the statute
Scotland differs. Paragraph 9A of Schedule 3 to the Licensing (Scotland) Act 2005, inserted by the Alcohol etc. (Scotland) Act 2010, makes an age verification policy a mandatory condition and defines it as a policy that steps are taken to establish the age of anyone who appears to the seller to be under 25, or an older age the policy specifies. Challenge 25 is therefore the legal minimum in Scotland, not a voluntary uplift. Scottish Government guidance confirms the condition applies to premises and occasional licences, does not prescribe the detail of the policy, and leaves the purchase age at 18. The 2026 digital identification amendment extends to England and Wales only.
What VenueOra does here
VenueGo is age verification on the guest’s phone: the attendee checks before arrival, the organiser sees approved, declined or needs review, and images are deleted after 30 days unless a review is open. It is one part of the festival stack; the guide to cashless festivals and arenas in 2026 covers the payments side, and the guide on who the data controller is when a nightclub scans ID covers door scanning. The licensing facts above are current as of October 2026.
VenueGo reads the document in the camera. It does not look up DVLA, the passport office, or any other government database, and it does not read a passport chip. A clear result is not proof a document is genuine. It does not replace a premises licence, a challenge at the bar, or legal advice.
This page describes how VenueOra’s products handle card data, personal data and age checks. It is not legal advice. Your premises licence conditions and your own data protection assessment take precedence.
Sources
- Licensing Act 2003 (Mandatory Licensing Conditions) Order 2010, Schedule
- Licensing Act 2003 (Mandatory Licensing Conditions) (Amendment) Order 2014
- Licensing Act 2003 (Mandatory Licensing Conditions) (Amendment) Order 2026
- Licensing Act 2003, section 146
- Section 182 guidance, September 2026 (GOV.UK)
- Temporary Events Notice (GOV.UK)
- Digital verification services for alcohol purchases, 17 August 2026 (GOV.UK blog)
- Age Restricted Products and Services Code of Practice, April 2014 (GOV.UK)
- Licensing (Scotland) Act 2005, Schedule 3, paragraph 9A
- Alcohol etc. (Scotland) Act 2010 guidance for licensing boards, section 4 (gov.scot)
