Harnessing the potential of new digital forms of identification

The Prime Minister’s initial announcement of mandatory digital ID was rushed, poorly thought through and failed to make a convincing case for the introduction of mandatory digital ID. While digital ID was being discussed by Westminster think tanks and politicians, for the general public the proposal came out of the blue. The announcement and subsequent communications were completely inadequate given the impact that mandatory digital ID would have had on our society. As a result, the announcement undermined what existing public support there was for digital ID. Subsequent developments, including the innovative use of deliberative methods as part of the public consultation and improved engagement with key stakeholders, are positive but should have been announced at the outset not as an afterthought. The government’s decision to abandon the mandatory element of the programme and limit its ambition is welcome; but it has also served to reveal the incoherence of its policy- making process and damage the confidence of key stakeholders and the public. (Conclusion, Paragraph 13)

The track record of digital transformation in government is poor, and we are sceptical that digital ID will be any different. The rushed nature of the government’s initial announcement of digital ID, subsequent changes of policy, and the complacency about government capacity for implementation, suggest that the government has not learnt the lessons from previous failures, particularly the risk of optimism bias and poorly defined objectives. The government’s more limited plans for digital ID in this Parliament now look more realistic, but it has not yet demonstrated a credible roadmap for implementation. (Conclusion, Paragraph 19)

When the government publishes the response to its consultation it should set out a much clearer estimate of the expected cost and forecast benefits of its final policy, with a detailed roadmap for implementation. (Recommendation, Paragraph 20) 27

The digital verification services sector in the UK has developed over 17 years, contains considerable expertise, and contributes an estimated £2 billion to the UK economy. The government’s initial announcement threatened to undermine this sector and was in direct conflict with the government’s own policy to support a trusted digital identity sector. The government has since improved its engagement with this industry, but still risks missing out on the value of this expertise if it is not open to the different roles the private sector can play in helping to implement digital ID. (Conclusion, Paragraph 24)

Digital ID will not achieve widespread adoption unless the majority of people can trust that their data is secure, so it is vital that the programme is subject to the highest standards of privacy and cyber and data security. Given the government’s poor track record in handling data securely, building this trust will require a significant effort to reassure the public. We therefore welcome the government’s commitment to the principle of data minimisation and in particular that it will not seek to create a centralised database for digital ID. (Conclusion, Paragraph 29) Right to work checks

Digital right to work checks offer some benefits to employers, but mandating digital right to work checks would mean a very significant shift in the way that employers are required to carry out right to work checks. It is vital that this change is not just treated as an afterthought to digital ID, but as a significant policy change in its own right. In particular, the implication that it may become mandatory for UK citizens who wish to work in the UK to hold a passport or a digital ID has not been highlighted by the government and is not asked about specifically in its consultation. (Conclusion, Paragraph 36)

The government should ensure that its plans for the transition to digital right to work checks reflect the significance of this policy change for both businesses and individuals. In particular, we recommend that the government takes steps to engage the general public on the specific question of what identity documents will in future be required to work in the UK, and whether government support is needed to increase the accessibility of those documents. The government should also work with businesses to ensure that effective guidance is available about how digital right to work checks should be carried out and what responsibilities employers will have. (Recommendation, Paragraph 37)

Digital right to work checks are not foolproof, and while the intelligence that these checks generate can help to target enforcement, intelligence alone will not reduce illegal working. There is no replacement for frontline enforcement to follow up on intelligence with investigations, arrests and penalties. (Conclusion, Paragraph 42) 28

In response to this report, the Home Office should set out whether and how resources were reallocated to support an increase in illegal working enforcement visits in 2025, and how this level of resource for frontline enforcement will be maintained in the future, in order to make effective use of new intelligence gathered through mandatory digital right to work checks. (Recommendation, Paragraph 43)

Intelligence that is currently being gathered by digital identity providers should clearly be informing Home Office enforcement and we share the Chief Secretary to the Prime Minister’s incredulity that this intelligence cannot already be shared and acted on effectively. We do not see any good reason that improving this intelligence sharing needs to wait for the introduction of digital ID or the wider roll-out of digital right to work checks. (Conclusion, Paragraph 45)

We recommend that the Home Office works with digital identity providers to ensure that there is an effective mechanism for them to share the intelligence they currently gather through digital right to work checks, so that this can support enforcement activity. This work should take place immediately. (Recommendation, Paragraph 46)

The government should learn from the errors that have affected the eVisa system in developing digital ID, as well as ensuring that opportunities to improve eVisas through the development of digital ID are not missed. In particular, the government should consider whether eVisas should be transferred into the digital ID system, so that in the future all UK residents can access a stable, tokenised digital form of proof of right to work. (Recommendation, Paragraph 52) The future of digital ID

There are theoretical benefits of digital ID in terms of ease of access to public services, but the government has not yet decided which public services will be accessed in this way. The government should be clear about the evidence base for proposing future uses of digital ID and provide a clear explanation of the intended benefits. Any planned use of digital ID to combat crime should follow extensive engagement with both the public and law enforcement agencies. Other committees of the House will no doubt wish to scrutinise government plans to integrate public services they are responsible for scrutinising with the new digital ID. (Recommendation, Paragraph 58)

The government is right to identify the need for safeguards to ensure that any proposed future expansions of digital ID cannot be made without proper scrutiny: not a slippery slope, rather a staircase, with progress—and direction—governed by Parliament. The government should set out these 29 safeguards in its forthcoming legislation on digital ID and ensure that any subsequent significant changes to the scheme are subject to debate in the House and the affirmative statutory instrument procedure at a minimum. The government should consider repeating its People’s Panel for any proposed future expansion of digital ID. (Recommendation, Paragraph 62) Conclusion

The government’s initial announcement of digital ID was rushed, poorly thought through, and failed to articulate convincingly any of the potential benefits. This undermined existing public support for the introduction of digital ID. The government has since taken positive steps to improve its policy including abandoning the commitment to make digital ID mandatory, improving engagement with the digital verification services sector, and publishing a detailed consultation with a People’s Panel. However, the fact that these steps were all taken after the initial announcement of mandatory digital ID shows how back-to-front the development of this policy has been. The government has already learnt some lessons from the handling of this programme so far, including the need for greater sensitivity to the views of the public. However, there is still a long way to go to undo the damage of the initial announcement, and the government is yet to demonstrate that it has the capacity to implement a complicated programme of this nature. To ensure the credibility of the programme it is essential that it is subject to much more robust cross-government consultation across the UK, as well as more detailed policy development and public engagement. (Conclusion, Paragraph 63) 30