Where to start?
Whether you’re developing an age verification policy from scratch or need to carry out due diligence on your current policy, the Chartered Trading Standards Institute’s Business Companion website () is a great first port of call and adopting this 8-point underage sales compliance checklist will ensure best practice:
1. Put effective age verification systems in place: assess, monitor and update systems regularly to identify and rectify problems or weaknesses.
2. Age ID checks: ask to see nationally-recognised age identification for all young-looking customers. Ensure that the photo matches the person presenting the card and check the date of birth. Guidance on fake ID is available on the Home Office website: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/183495/False_ID_guidance.pdf.
3. Challenge 21/25: participate in a scheme to carry out age verification checks for anyone that looks younger than 21 or 25. In Scotland, Challenge 25 is a legal requirement for any retailer selling alcohol.
4. Staff training: ensure staff receive adequate, up-to-date and regular training on underage sales. By law, retailers must be able to prove that staff have understood what is required of them. Keep a record of training and ask staff members to sign that they have understood their training. Records should be monitored regularly by store management. People under 18 cannot sell alcohol without adult authorisation. Supervise any staff under 18 as they may find it difficult to refuse customers in their own age group.
5. Till prompts: use your EPoS system to make till prompts to remind staff to carry out age checks.
6. Store layout, storage, signage and CCTV: display signage that confirms the minimum age of purchase and your refusal statement. This, along with CCTV, can serve both as a deterrent to underage buyers and as a reminder to staff.
7. Refusals register: to demonstrate active refusal of underage sales, keep a record of incidents. The register should include details of date, time, incident and a description of the potential buyer, and should be checked by store management regularly. An example refusals log is available on the CTSI Business Companions website.
8. Proxy purchasing*: be aware of young people loitering outside your premises. They may ask adult customers to buy alcohol for them and these sales should be refused too.
For full CTSI guidance, visit
In its 12 years of auditing pub compliance, Serve Legal has identified 3 key factors that affect staff performance around age checks:
· Early eye contact and conversation: making early eye contact and conversation is not only part of good customer service, it provides an opportunity to make an early assessment of age when young customers approach the bar or are waiting to be served. Underage people may be keen to avoid eye contact and conversation to detract attention, so this early test serves as a trigger for staff to prepare to request identification. Serve Legal’s audit data shows that pass rates (when a staff member asks a young mystery customer for age identification) are higher when eye contact is made before the transaction than when made during a transaction.
· Number of staff and queue length: when establishments are busy, short-staffed and/or where customer queues are long, staff may be tempted to overlook requests for age identification in order to save time and process sales. Having enough staff to cope with busier trading times is vital to ensure compliance around age checks.
· Request customer ID, not just their age: asking a young person their age is not proof of age. Young people must be asked to show picture identification that proves beyond doubt that they are 18 or older.
By combining the CTSI and Serve Legal checklists with independent auditing of staff performance, operators will be putting in place an effective age verification policy which cements their commitment to responsible retailing.
Serve Legal http://www.servelegal.co.uk/
Chartered Trading Standards Institute’s Business Companion website
Full CTSI guidance on underage alcohol sales