Member

The legal clarity offered by the legislation is, of course, welcome, but there are significant implementation considerations for retailers, and there will be a cost to contracting providers or building in-house DPoA systems at scale. Retailers will be required to ensure that they comply with the wider licensing obligations in operating digital proof of age—for example, ensuring that sales are not made to intoxicated persons, which is already a crime, and that proxy sales are not taking place. This means that human interaction could still be required in a significant number of transactions in addition to general consumer familiarisation with the digital proof of age process at the point of sale.