Last updated: 24 April 2026
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Most new licensees think Challenge 25 is optional guidance. It isn’t. If you’ve just taken on a pub or you’re about to, this policy is a legal requirement that sits at the centre of your trading licence and your personal liability. Get it wrong and you’re not just risking a fine—you’re risking closure. Challenge 25 is the age verification policy that requires staff to ask for ID from anyone who appears to be under 25 when purchasing alcohol, regardless of how old they actually look. It’s enforced by trading standards and the police, and it’s a condition of your premises licence as a pub licensee. This article explains exactly what Challenge 25 requires, how to implement it in your pub, what your staff need to know, and what happens if you get it wrong. I’ve seen pubs lose their licence over a single failed test purchase. This isn’t theoretical—it’s what happens when Challenge 25 isn’t taken seriously.
Key Takeaways
- Challenge 25 is a legal age verification policy that requires UK pub staff to request ID from anyone who appears under 25 when buying alcohol.
- Non-compliance can result in fines up to £20,000, closure notices, and personal liability for the licensee and staff members involved.
- Implementation requires clear signage, staff training, ID acceptance procedures, and refusal protocols documented in your premises licence.
- Test purchases by trading standards are used to audit Challenge 25 compliance and are a standard enforcement tool in 2026.
What Is Challenge 25?
Challenge 25 requires staff to ask for ID from anyone who appears under 25 when purchasing alcohol, regardless of their actual age. This isn’t a suggestion. It’s a legal age verification policy that has been adopted across the UK hospitality sector since around 2007, and it’s now woven into licensing law and premises licences.
The policy is simple in theory: if someone looks like they could be under 25, you ask for ID. If they can’t produce valid ID, you refuse the sale. There are no exceptions and no discretion. You don’t sell to friends of friends. You don’t make assumptions based on how confident they seem. You ask for ID, or you don’t sell alcohol.
It applies to all alcohol sales: beers, spirits, wine, cider, shots, anything with alcohol in it. It applies at the bar, in the restaurant, through table service, at the till. Every transaction, every time.
The policy protects two groups: young people (by preventing underage access to alcohol) and you (by creating a documented, defensible system that shows you’ve taken reasonable steps to prevent illegal sales). When a trading standards officer or police officer asks you how you prevent underage sales, Challenge 25 is your answer.
Is Challenge 25 a Legal Requirement?
Challenge 25 is a legal requirement under the Licensing Act 2003 and must be part of your premises licence conditions. It’s not guidance. It’s not best practice. It’s a licensing condition.
The legal basis comes from the Licensing Act 2003, which places a duty on premises licence holders to prevent underage sales of alcohol. The Licensing Act 2003 and its regulations are the statutory framework. Your premises licence (the document issued by your local council when you take on a pub) will specifically reference Challenge 25 or age verification requirements.
What this means practically: if your pub doesn’t have Challenge 25 in place, you’re in breach of your premises licence. Trading standards can take action. Your licence can be reviewed or suspended. You personally, as the licensee, face fines and potential prosecution.
I took on Teal Farm Pub three years ago under a Marston’s CRP agreement, and Challenge 25 was explicitly called out in the licence conditions. The local authority made it clear: you have a documented age verification policy, or you don’t have a licence. This isn’t interpretation. It’s the law.
How to Implement Challenge 25 in Your Pub
1. Document Your Policy
First, you need it in writing. Most pub chains (Marston’s, Greene King, Wetherspoon, Punch, Admiral Taverns) provide Challenge 25 templates as part of their licensing support. If you’re independent, you’ll need to draft one or adapt a template. Your local authority may provide one too—contact them and ask.
Your Challenge 25 policy must cover:
- The trigger age (25)
- What counts as valid ID (photocard, passport, driving licence)
- What to do if someone refuses to provide ID (refuse the sale)
- Staff training and responsibility
- Records of sales and refusals
- How the policy is monitored
File it. Keep it accessible. Show it to your staff. Have a copy available if a trading standards officer asks to see it.
2. Display Clear Signage
You must have visible signage at points of sale stating Challenge 25. This typically goes near the till, at the bar, and at any service point where alcohol is sold. The sign should clearly state that ID will be requested from anyone who appears under 25.
Signage serves two purposes: it informs customers what to expect, and it demonstrates to an enforcement officer that you have a documented system in place.
3. Establish Valid ID Criteria
You need a clear rule about what ID you will accept. Standard acceptable forms are:
- UK driving licence (photocard)
- UK passport
- PASS accredited card (Proof of Age Standards Scheme)
- EU/EEA national ID card
You can accept others, but these are the main ones. The key is that ID must be photographic, current (not expired), and clearly show age and identity. Expired ID is not acceptable, even if the photo is obviously the same person.
Many licensees accept one or more of these, but not all. That’s fine—decide what you’ll accept, make it clear to staff, and be consistent. The issue arises when you’re inconsistent (accepting expired ID one day and refusing it the next), as this suggests you don’t have a proper system.
4. Train Your Staff Thoroughly
Your staff are the point of enforcement. If they don’t understand or follow Challenge 25, the policy fails and you’re liable. Training must cover:
- Why Challenge 25 exists (legal requirement, not suggestion)
- Who to ask (anyone who appears under 25)
- What ID to accept (criteria you’ve set)
- How to refuse a sale professionally (important for managing difficult situations)
- Consequences of breaches (for them and the pub)
Document training. Have staff sign a record confirming they’ve been trained. Refresh training at least annually, or when staff turnover is high. In my experience running Teal Farm, this is where most pubs fall short. Staff get trained once on their first day, then the policy fades into the background. When a test purchase happens, they fail because they’ve never been reminded. Training is ongoing, not one-time.
Staff Training and Compliance
Documented staff training is your primary defence against trading standards enforcement and the most common reason pubs fail age verification test purchases.
In 2026, test purchases are routine. A young-looking person (under 25 in appearance, but legally aged) walks into your pub and tries to buy alcohol. If your staff don’t ask for ID, it’s logged as a failure. If they ask for ID but accept an expired passport, it’s logged as a failure. If they follow your Challenge 25 policy perfectly, it’s logged as a pass. Your pub’s compliance record is built on these test results, and it becomes part of your licensing profile.
What this means: training isn’t a one-off box-ticking exercise. It’s an ongoing system. Here’s what I do at Teal Farm:
- Induction training: All new staff receive full Challenge 25 training on their first shift, with a sign-off sheet kept on file
- Monthly refreshers: A 5-minute reminder at team briefings, covering real scenarios or recent news about underage drinking
- Post-failure training: If a test purchase is failed, additional training happens immediately, with documentation showing what went wrong and how it was corrected
- Annual attestation: All staff sign a statement confirming they understand and will follow Challenge 25
The documentation matters because it shows intent. If you’re audited and you have training records, you’ve done your job. If you have no records and staff can’t explain the policy, you’re in breach.
Penalties for Breaking Challenge 25
The penalties for Challenge 25 breaches are serious and escalate depending on the breach and your history.
Financial Penalties
A single breach (one failed test purchase) can result in a fine up to £20,000 for the premises. If the breach is proven to be deliberate or reckless, the fine can be higher. Staff members who make the sale can also be fined individually up to £1,000.
Licensing Action
If you accumulate multiple breaches or a serious single breach, your premises licence can be reviewed. A review can result in:
- Suspension of your licence for a defined period
- Modification of your licence conditions
- Revocation of your licence (closure)
Revocation is rare but it happens. Once your licence is revoked, getting a new one is extremely difficult. Potential tenants won’t touch the property because the licensing history is tainted.
Criminal Liability
If a breach is deemed reckless or deliberate (e.g., you’re knowingly selling to underage customers), you can face criminal prosecution under the Licensing Act 2003. This can include imprisonment in serious cases, though this is rare.
Reputational and Business Impact
A failed test purchase is logged in your licensing record. It becomes publicly available information. Local media often report on licensing breaches. Your reputation takes a hit. Other local venues and pubcos hear about it. It affects your ability to get support from your pubco and your credibility with suppliers and staff.
I’ve never failed a test purchase at Teal Farm because Challenge 25 is embedded in how we operate. But I’ve spoken to other licensees who have, and the stress and disruption is significant. Prevention is far easier than remediation.
Best Practice Beyond the Minimum
Compliance is the minimum. Best practice goes further and actually reduces the likelihood of breaches.
Use Technology Where Possible
Some EPOS systems (electronic point of sale tills) have age verification flags built in. When alcohol is scanned, the system prompts the staff member to confirm they’ve checked ID. When evaluating best pub EPOS systems for a pub handling wet sales, dry sales, quiz nights, and match day events, age verification functionality should be part of your assessment. It removes the risk of human error and creates an automated record of compliance.
Scenario Training
Don’t just tell staff the rule. Run through realistic scenarios:
- “A regular comes in with their teenage child who orders a soft drink. What do you do?” (Correct answer: nothing—soft drinks don’t require ID.)
- “Someone produces a driving licence from Spain. Do you accept it?” (Yes, if it’s current and photographic.)
- “A customer gets aggressive when you ask for ID. How do you handle it?” (Calmly, professionally, offering alternatives: “I’m asking everyone who appears under 25. It’s not personal. If you’d prefer to come back with ID, that’s fine.”)
Scenario training embeds the policy in a way generic training doesn’t.
Mystery Shopper Testing
Before trading standards shows up with a test purchase, run your own internal test. Hire a young-looking adult (or ask a trusted customer) to come in and try to buy alcohol without ID. See if staff ask. If they do, they pass. If they don’t, you’ve identified a training gap before the official test.
Record Refusals
When you refuse a sale, record it. This shows a pattern of compliance. Keep a refusal log (date, time, reason, staff member, outcome). If you’re audited, this log demonstrates that Challenge 25 is actively working in your pub, not just a poster on the wall.
Communicate With Your Pubco
If you’re on a tenancy (Marston’s, Greene King, Punch, Admiral, etc.), your pubco has a vested interest in your compliance. They don’t want licensing breaches on their portfolio. Most pubcos run their own compliance audits. Share your Challenge 25 documentation with them. If they provide templates or guidance, use it. Marston’s, for example, provides detailed Challenge 25 support as part of their BDM relationship. Use it.
Frequently Asked Questions
What happens if I refuse a sale under Challenge 25?
You tell the customer politely that you can’t complete the sale without valid ID. Most customers accept this and either provide ID or leave. Some get defensive or aggressive. Stay calm, don’t argue, and never make assumptions about why they can’t produce ID. Once you’ve asked and they’ve refused or can’t produce ID, the conversation is over. You don’t sell. Document the refusal in your refusal log.
Can I accept a photograph as ID for Challenge 25?
No. A photograph on a phone screen is not valid ID under Challenge 25. You need physical, photographic ID: driving licence, passport, or PASS card. Digital versions don’t work because they’re too easily faked and they’re not the official format the law recognises. If someone tries to show you a digital ID, explain this and offer them the option to come back with physical ID.
Do I have to ask for ID from someone who is clearly over 25?
The policy is “appears under 25,” not “is under 25.” If someone genuinely looks over 25 (grey hair, obvious age), you don’t need to ask. But people age differently, and it’s better to err on the side of caution. If someone could plausibly be under 25, ask. This is subjective, which is why training and consistency matter. Your staff’s judgment will vary, but they should all default to asking rather than guessing.
What if a customer refuses to provide ID?
You refuse the sale. You don’t negotiate. You don’t offer alternatives like “just this once” or “I’ll ask the manager.” If they can’t or won’t provide valid ID, they don’t buy alcohol. This is the non-negotiable point of Challenge 25. Be polite, but be firm. Most customers will understand. Some will complain or get angry. That’s normal. Your job is to follow the policy, not to manage everyone’s feelings.
Can I be prosecuted personally if my pub fails a Challenge 25 test purchase?
Yes. As the premises licence holder, you’re responsible for Challenge 25 compliance. If your pub fails a test purchase, you can be fined up to £20,000. The staff member who made the sale can also be prosecuted. This is why training and documentation are essential—they show you took reasonable steps to prevent the breach. If you can demonstrate that you trained staff, you have a policy in place, and you monitor compliance, you have a defence. If you have nothing, you’re fully liable.
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Running a pub with an outdated or non-existent Challenge 25 system puts your licence at risk and your income under threat from compliance action.
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