Where next for UK government digital ID?

As the UK government digests the 90k responses to the consultation on whether or not it should create a national digital ID system, here are some questions that need answering as we get into more details on what is being proposed.

1) What capabilities do we already have today?

With any change programme, a good understanding of the current capabilities is critical; things we already have:

• One Login - what is the existing scope of One Login? Undefined at present, so Digital Verification Services (DVS) are unclear on where the interface boundary is, which weakens interoperability; public and private sectors are currently not connected - we have a siloed approach (e.g. Companies House director verification can't be reused in private sector).
• Data Act 2025 - introduced Digital Verification Services and Smart Data scheme powers
• DVS Trust Framework
• Information gateway (legal powers for public to private sector data sharing)
• Digital credentials - mobile driving licence in development, planned digital passport
• Certified digital wallets (DVS, gov wallet planned HSP certification)
• DVS sector - 50 providers solving problems today
• Corporate ID wallet already being worked on by CFIT

2) Where do we want to get to?

• Define the desired goals, purpose, problems, scope for any new things, that are not being solved by the things we already have.
• What are the limitations or gaps that need new things to be delivered?
• What is the purpose and scope for the proposed ID system, what problems is it intended to solve?
• Recognised progress already made by One Login for access to public sector, Digital Verification Services (DVS) for access to private sector services - define and maintain clear boundaries.
• Government doesn't need to solve private sector ID journeys (alcohol, bank onboarding) - DVS are already doing this. There are fewer privacy issues & taxpayer costs if DVS solve private sector use cases.

"My Ministers will also proceed with the introduction of Digital ID that will modernise how citizens interact with public services [Digital Access to Services Bill]."

How is the new ID and 'access to services' bill different to One Login?

• If the ID system scope is access to government services, does the citizen have a choice of using One Login OR the digital ID method?
• Why have two methods when the point of One Login was to have one login method?

If the decision is made to introduce a new ID, start small and prove the model - which services are being joined up, and why? Where does the data reside?

• E.g. if HMPO and DVLA data is joined up, does HMPO store DL no? DVLA store passport no?
• For joined up childcare and benefits - does NHS store DWP data? DWP store NHS data?

The Cabinet Office are already expanding the scope into talking about digital ID for businesses - this increases cost, complexity and risk for the digital ID programme.

How will the new system prevent illegal working? Illegal working prevention needs enforcement; digital right to work checks will have limited value, as bad employers won't comply.

• RTW informs ’who has checked’, government needs to enforce existing rules and fines on ‘who hasn’t checked’.

3) What are the grounds for introduction of a National ID?

A national ID is a fundamental change for the UK, that wasn't in the manifesto; UK citizens want to have a say in how they are governed.

What was in the manifesto?

• "Labour will safeguard taxpayers’ money."
• "We will end the link between access to ministers and an inside track for public contracts."
• "We will ensure taxes on working people are kept as low as possible. Labour will not increase taxes on working people"
• "We will ensure a pro-business environment, with a competition and regulatory framework, that supports innovation, investment, and high-quality jobs"
• "Business has for too long been hampered by a government that does not work with it. As a result, investment in the UK is too low. To address this long-standing problem Labour will use every available lever. Public investment, where it supports and de-risks additional private investment, is one important tool being used successfully across the world"

Saving taxpayers money, not increasing taxes and creating a pro-business environment that encourages investment were in the manifesto. A government digital ID could negatively impact all of these pledges.

• Some proponents of government digital ID have claimed that a vote for 'change' means a vote for digital ID - this is obviously a spurious connection.
• A survey carried out by a pro-ID think tank, or a small peoples panel, isn't enough justification to build a national system.

In Switzerland, citizens were given two referendums, and ultimately narrowly voted for it.

UK citizens should have the same choice for a fundamental reset of the state/citizen relationship in a common law country.

There should be an explicit mandate from the UK public for a national ID, rather than being grounded weakly in party ideas.

If there is sufficient public backing for a new ID system, clarification on what will be delivered:

3) What new things does the new 'ID system' comprise of?

Digital ID platform - what is the new technology? It needs a credential issuing platform, to enable issuing, status and revocation of digital credentials (e.g Estonia uses x-road https://x-road.global/ - is this what is being proposed? Or MOSIP? https://www.mosip.io/ SSI tech? E.g. Dock.io, Walt.id, Lissi.id). Or perhaps OneID® ?

• Where will the data be stored? How will it be protected to allay security concerns?
• Biometrics, hi-res photos - what controls are there over powers for use by police?

New identifier - what is being proposed?

Government can’t just join up services for those opting in to digital ID, as this would amount to discrimination, so government can’t just use the new identifier as a key to joining services, but needs to enable other keys; driving licence no, passport, NI no, NHS no. Government could supply an alias service - citizen can choose which identifier to link their services to.

National identity register - the list of who has been issued an ID credential (which will be a partial register of citizens - only for those who have opted-in)

The last ID cards programme had a National identity register, which was scrapped in 2010 https://www.gov.uk/government/news/identity-cards-are-to-be-scrapped

"Cancelling the scheme and abolishing the National Identity Register is a major step in dismantling the surveillance state"

What has changed since 2010 to make a citizen identity register more acceptable now?

Digital credentials - How is the new ID credential different to the passport credential, which has the same data (and 85% can get one)? Why have two credentials the same?

How does someone get an ID credential? What ID evidence do they already need to have (and why not just get the digital version of that evidence)? E.g. if someone has a passport, they can get a digital passport - what does the digital ID enable that the digital passport can't do?

Can immigrants get an ID? If so, when? Illegal immigrants don’t get one, but then how does government differentiate between an opted out citizen (who may have no DL or passport) & an illegal person?

What is the scope of the GOV.UK Wallet service? Can citizens choose an equivalent certified DVS wallets to store government-issued credentials?

Is the scope just access to public services? If the ID system scope includes access to private sector services, then the government wallet is competing with DVS wallets; this needs fair competition, not subsidised by the taxpayer, and equal rules for equivalent services. And why does government want to compete?

Checker service - what is the need for this service? DVS already do this today for private sector. For public sector, citizens can use One Login. What does the checker service add?

And finally, a net positive benefit that is sufficiently clear and large enough to warrant the opportunity cost of doing something else with the time and money:

Cost Benefit Analysis, by component

How much will the new ID system cost over its expected life cycle? Digital ID could cost billions, more than any other manifesto commitment.

What are the quantified benefits?

What are the quantified risks of negative impacts to economic growth, inbound UK investment and job creation?

And finally, key to success and delivery will be cross-sector collaboration to leverage the DVS services and experience; again from the manifesto, the government promised:

"an enduring partnership with business to deliver the economic growth we need".

This is mission one.