In our response, we support the ambition to create a digital identity that is useful, inclusive and trusted. We recognise the potential for a well-designed system to reduce friction for consumers and firms, improve access to public services, support stronger digital verification and help tackle some forms of identity fraud.

At the same time, we make clear that the success of the programme will depend on a number of important design choices being addressed early. These include assurance levels, reliance and liability, the role and scope of the proposed Government Checker, the treatment of address and wider attributes, and how the new system will interact with existing private-sector digital verification services.

Our response also highlights the importance of practical usability in regulated sectors such as financial services. That includes machine-readable and interoperable verification, clear audit-quality outputs, and a model that supports firms’ risk-based obligations rather than displacing them.

We also emphasise that inclusion, fraud prevention, revocation, recovery and operational resilience must be designed into the system from the outset. Secure assisted routes, strong consumer protections and clear public communication will all be important if the scheme is to build trust and work effectively in practice.

UK Finance would welcome continued engagement with Government and other stakeholders as the programme develops.