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Challenge 25

  /    /  Challenge 25

How do you achieve Challenge 25?

Actually, the law does not specify in any detail what you must or must not do.  That’s where The Licensing Guys step in.

There is some flexibility as to how you may achieve these levels of compliance.  The systems used by a nightclub can be expensive and complex (e.g. the use of a software solution like IDScan).  This will way more than expected for a small Convenience Store with Off-Licence.

☝️ Always remember that the ultimate goal is to prevent anyone under 18 from being supplied with alcohol unlawfully. This includes home delivery!

✅ You can download a templated Age Verification Policy for free from the TLG Vault.

Failing to Plan is Planning to Fail.  Have a Plan!:

  • Ensure that all your staff that sell alcohol are trained and retrained in Challenge 25, know where your Policy is and know what it says – exactly. Train them in who to ask, how to ask and what forms of ID to accept, how to check that ID for fake items, and then how to politely but firmly refuse the sale.  The best way to do this is to give them formalised training.

☝️ The Licensing Guys provide Responsible Alcohol Retailing training that includes Challenge 25.  Call us for details on 01432 373603 – we will even come to your Premises to train your staff in their workplace.

  • The only acceptable forms of Valid ID should be a photo driving licence, a passport or a PASS (Proof of Age) card (see page 38). Some Council policies allow the presentation of a Military Pass, but here at TLG we do not encourage the presence of Military Passes in the Night Time Economy, in case they should they become lost or stolen.
  • Keep a Training Record of who has been trained in Challenge 25, when and by whom. Get you staff to sign to the fact that they have been trained, so as to prevent any ‘blow-back’ upon you should they later commit an offence by selling to an under-age customer.

✅ You can download a templated Staff Training Record for free from the TLG Vault.


  • Display Challenge 25 posters in your shop:
  1. At the entrance of the shop
  2. On the alcohol shelves
  3. At the counter.

✅ You can download Challenge 25 posters for free from the TLG Vault.


  • If a person challenged cannot provide proof of being 18 when being challenged, then ALWAYS refuse the sale.
  • Whenever a sale is refused, EITHER by you OR you staff, the following information should be recorded:
  1. Time
  2. Date
  3. Type of alcohol attempted to be purchased
  4. Description of the person refused
  5. Type of ID presented to you (if any is offered)
  6. Reason for refusal or non-acceptance of ID produced.
  7. Your Name (this is really important to protect you!)

As explained earlier, it is the responsibility of the DPS to check that the Policy is being implemented.  That means that YOU will have to check the Refusals Register

✅ You can download a templated Refusals Register and a Deliveries Log for free from the TLG Vault.

When you are presented with fake ID, inform the holder that you will retain it and call the Police and give it directly to them.  This usually results in the Young Person leaving the shop immediately.  Call the Police and give them the suspected piece of fake ID when they arrive.  Some Police forces will provide outlets with “Bailment Forms” which you complete and give part of to the customer as a receipt for the ID.

If the Young Person is adamant and demands the return of the article of suspected fake ID back, enter the Young Person’s details AND the details of the suspected fake ID in your Refusals Register and then hand it back to them – but STILL REFUSE the sale.

☝️ Do not end up in a fight with them over the suspected fake ID.  You do not have to justify your decision not to make the sale to them.  Be firm and polite.  They will soon go to attempt to make their purchase elsewhere.

Support your Staff:

Challenge 25 will only work if your staff have complete confidence that the decisions they make, often in potentially stressful circumstances, will not be undermined by you with the benefit of hindsight.  Yes, they will occasionally make mistakes – that’s only human.  But if they are brave enough to refuse a sale, they are doing to in order to protect YOUR business.  So, whatever you do or don’t do, ALWAYS support your staff.  Remember…

☝️ Your business is only as good as your staff.

☝️ Your staff are only as good as your leadership, and the training and support that you give them.

PASS Cards:

The Proof of Age Standards Scheme (PASS) – is the UK’s national proof of age accreditation scheme.  It is endorsed by the Home Office, National Police Chief’s Council, the SIA and the Trading Standards Institute.  For further details, please visit

Test Purchase Operations:

The only person under 18 who can lawfully buy alcohol in the UK – is a ‘spy’ (aka Test Purchaser), sent into your premises by Trading Standards and/or the Police, with the training and authority to attempt to buy alcohol from you for the purposes of a test purchase operation.  This activity is lawful.  What a test purchaser cannot do is consume the alcohol (or other age-restricted goods) that they have purchased.

Trading Standards and/or the Police mount Test Purchase Operations when they have general or specific intelligence relating to under-age purchases in a vicinity of or from a premises.

☝️ If you implement Challenge 25 properly, you and your staff will never be caught out!

The Table Meal EXCEPTION:

You will know that a person under 18 can NEVER purchase alcohol.  However, there is a strange quirk in the Licensing Law regarding Young People aged 16 and 17 and their consumption of alcohol.

Some people have heard of this ‘loophole’ and some people even claim to understand it.  Few rarely do.  So here it is set down as simply as possible so that you can comprehend it in all its full glory…

A Young Person aged 16-17 can CONSUME beer, cider or wine in licensed premises if accompanied by someone over 18 (who must do the purchasing) and only if that drink accompanies a substantial table meal. So…

  1. There’s got to be a substantial table meal on the table
  2. It’s got to be beer, cider or wine in the glass
  3. The over-18 year old is the only one allowed to purchase the drink.

Moreover: Watch that Young Person like a hawk!  There should be absolutely NO WAY that young person is going to get drunk or be allowed to consume more than a couple of drinks in your premises – as the consequences for your business of it going very wrong could be appalling.

Thought she looked old enough?  Better Call Paul!

Our advice is always free.