The United Kingdom is moving towards a future where identity verification is increasingly digital. The concept of a Digital ID promises to streamline how we prove who we are, whether accessing government services, opening a bank account, or verifying our age. This shift aims to enhance security, improve convenience, and modernise interactions in both the public and private sectors.
However, for a globally mobile population, particularly individuals with dual residency, this transition raises important questions. What happens when your physical presence in the UK is infrequent? Could a system designed for convenience create new hurdles for those living and working abroad? The introduction of Digital IDs is not just a technological upgrade; it carries significant legal and practical implications that warrant careful consideration.
This article will explore the rollout of Digital IDs in the UK from a legal perspective. This article analyses many scenarios including the potential challenges for dual residents, comparisons with systems in other countries and whether these new digital identities will be mandatory.
Key highlights
- A new way to prove identity: Digital IDs are a secure, electronic way for individuals to verify their identity online and in person. Replacing the need for physical documents like passports or driving licences.
- Challenges for dual residents: those who do not visit the UK often may face issues with ID expiration, re-verification processes, and potential difficulties accessing services from abroad.
- Government costs and user fees: the implementation of a nationwide digital identity framework is a costly endeavour. It remains to be seen if the government will pass on some of these costs to users.
- Lessons from abroad: countries like Portugal and Malta have Digital ID systems that offer insights into both the significant benefits and the potential pitfalls.
- The question of ‘opt-out’: current UK government policy suggests that Digital IDs will not be compulsory. However they may become the default and most convenient method, creating a two-tier system of access.
What are Digital IDs and why are they being introduced?
A Digital ID is a verified electronic credential that represents an individual’s identity. Instead of carrying a physical passport or utility bill, you would use a secure application on your smartphone or another device to prove who you are. The UK government’s plan, is not to create a single, centralised national identity card, but to establish a market of providers that can manage digital identities.
The primary goals behind this initiative are to:
- Enhance security: reduce identity fraud by creating a more robust and verifiable system. Since physical documents can be easily lost, stolen, or forged.
- Increase convenience: streamline processes like applying for a mortgage, starting a new job, or accessing government services like HMRC or the NHS.
- Promote economic growth: a trusted digital identity market is expected to foster innovation and make the UK economy more efficient.
For the user, this could mean a future where complex administrative tasks are completed in minutes. With just a few taps on a screen, eliminating the need for paperwork and in-person appointments.
The impact on dual residents: a looming challenge?
While the convenience of Digital IDs is clear for UK-based residents. Perhaps the picture is more complex for the millions of British citizens and residents who spend significant time abroad. Dual residents, expatriates, and non-domiciled individuals could face a unique set of obstacles.
The risk of Digital ID expiration and re-verification
Digital identity systems must be periodically updated to remain secure and accurate. This often requires a re-verification process. If this process requires a physical presence in the UK – for example, a biometric scan at a designated location or an in-person check – it could become a major hurdle for those who only visit the country infrequently.
Imagine your Digital ID expiring while you are managing a property sale or dealing with a UK tax matter from your home in Portugal or the UAE. If you cannot easily re-verify your identity from abroad, you could be locked out of essential services. Perhaps this will force an unplanned and costly trip back to the UK simply to complete an administrative task.
Government-imposed costs and accessibility
Creating and maintaining a secure digital identity framework is a massive undertaking for the government and certified providers. It is plausible that some of these costs could be passed on to the user. This could take the form of an initial setup fee, an annual subscription, or a per-use charge for verification services.
For a dual resident who may only need to use their UK Digital ID a few times a year, these costs could feel disproportionate. Furthermore, if accessing the system requires specific UK-registered mobile numbers or banking details, it could create another barrier for those whose financial and personal lives are primarily based overseas.
Exclusion from essential services
If Digital IDs become the standard method for interacting with government agencies like HMRC, those unable to obtain one could find themselves at a significant disadvantage. While alternatives will likely exist, they may be slower and more cumbersome, effectively creating a two-tier system of access. A dual resident needing urgent access to their UK tax records or state pension forecast could face delays and complications. Should their only option be to then rely on traditional, paper-based methods.
Lessons from other EU countries: Portugal and Malta
As the UK looks to implement its own Digital ID system, it is useful to consider how other EU nations have approached digital identity. And perhaps what lessons can be drawn from their experiences.
Portugal
Portugal has made significant progress in digital identity infrastructure with the “Cartão de Cidadão” (Citizen Card). This chip-enabled card serves as the official ID for Portuguese citizens and residents, and offers robust digital functionalities. Through the “Chave Móvel Digital” (Digital Mobile Key), individuals can authenticate themselves online and sign documents electronically for many sector services.
Benefits: the digital ID has greatly improved access to online public services, reduced bureaucracy, and simplified administrative procedures. This is for both residents and Portuguese citizens living abroad. It has also enhanced security for accessing sensitive data.
Challenges: for non-residents and expats, obtaining and renewing the card often requires physical presence in Portugal or a Portuguese consulate. This can introduce practical barriers similar to those expected with the UK’s system. System integration can be inconsistent, with some private sector services lagging behind in accepting digital authentication.
Malta
Malta offers a national e-ID system that grants access to a wide array of public digital services, from tax filings to healthcare information. The Maltese e-ID is available to both citizens and certain categories of residents, and is a key part of the nation’s “digital-by-default” government strategy.
Benefits: residents and eligible non-residents enjoy quick, secure, and centralised access to government portals and digital services. Improving overall administrative efficiency.
Challenges: access for long-term non-residents can be limited, and physical presence in Malta may be required to activate some identity features. While widely used for government services, private sector adoption is not universal, and issues around cross-border recognition remain.
Key takeaways
The experiences of Portugal and Malta show that while digital identity systems can significantly enhance convenience, access, and security, they also come with real practical challenges – especially for dual residents and those living overseas. Issues like the need for physical presence during setup or renewal and incomplete sector-wide adoption are recurrent themes. For UK dual residents, learning from these European models highlights both the potential of Digital IDs and the importance of flexible, accessible implementation.
The UK government’s approach appears to be a hybrid model, learning from both the successes and failures abroad. The stated policy is that using a Digital ID will not be mandatory unless applying for a Right to Work. Citizens will still be able to use physical documents to prove their identity.
However, a key concern is “optional in name only.” As more services, both public and private, become optimised for Digital IDs, using physical documents may become increasingly impractical. This could pressure individuals into adopting the new system, even if they have reservations.
The financial aspect is also significant. The government will bear the cost of developing the trust framework and regulatory oversight. Private sector providers will invest in building the technology to offer certified identity services. While this may create a competitive market, it is almost certain that costs will be involved for the end-user, whether directly or indirectly. For the government, the long-term goal is that the efficiency savings from reduced fraud and streamlined administration will outweigh the initial investment.
How to prepare
For dual residents, the introduction of Digital IDs adds another layer of complexity to managing your UK affairs. However, since this is a new update, as of September 2025, the discussions are that the rollout will only occur after the end of the current Government.
In the meantime, our team understand the challenges of navigating cross-border administration and compliance. We can help with:
- Staying informed: we will keep you updated on the latest developments in the UK’s Digital ID framework and what they mean for you.
- Managing UK compliance: we can act as your trusted agent in the UK. Helping you navigate the Digital ID introduction as a dual resident.
- Structuring for simplicity: our team at RHJ Accountants can review your tax affairs to ensure your UK presence is managed as efficiently as possible.
Perhaps you’re facing a lot of uncertainty about continuing to live in the UK, so you can always review visa options for a new life abroad!
Frequently asked questions
What is a Digital ID?
It allows you to prove who you are online or in person without needing physical documents like a passport or driving licence. It is verified and issued by a government-approved provider.
How will a Digital ID work in practice?
You would typically use a secure app on your smartphone. When a service needs to verify your identity, the app would share the necessary information (e.g., your name and that you are over 18) with your explicit consent. The process uses encryption and other security features to protect your data.
What are the main benefits of having a Digital ID?
The key benefits are convenience and security. It will make processes like opening a bank account, applying for a job, or accessing government services faster and easier. It also aims to reduce the risk of identity theft and fraud associated with physical documents.
Will I have to pay for a Digital ID?
The government has not finalised the cost structure. It is possible that certified private providers will charge a fee for issuing or maintaining a Digital ID. The goal is to create a competitive market, but some form of user cost is likely.
Is the UK Digital ID going to be mandatory?
No, the UK government has stated that the Digital ID will be optional. You will still be able to use physical documents to prove your identity. However, for individuals that require a Right to Work the Digital ID will be mandatory.
