Protection of children from harm

What "harm" actually means here

The protection of children from harm does not only mean alcohol. It covers anything that could harm a child who comes into contact with your venue or its activities: alcohol, illegal drugs, adult-only entertainment, violence, and any adult content or environment that is inappropriate for someone under 18.

For most bars and clubs, the practical focus is on preventing underage people from gaining access to the premises and from being served alcohol. But if your venue has other licensable activities — live music late at night, adult entertainment, or anything with explicit content — the scope is wider.

The licensing authority will want to see that you have thought about every route through which a child could be harmed by your operation, not just the obvious one of "don't give them alcohol."

Challenge 25

Challenge 25 is a standard industry policy: if someone appears to be under 25, ask for proof of age before serving them alcohol. Because the legal age is 18, this gives you a buffer — it means someone who is 20 and looks young is asked for ID as a matter of routine, rather than the bar staff having to make a judgment call on whether they look "old enough."

It is widely accepted by licensing authorities and the police as a credible, recognised scheme. Committing to it in your operating schedule signals that you have a real system, not just a vague intention.

Challenge 25 should be:

• Clearly stated as your policy in the operating schedule
• Communicated to all staff through induction and training
• Displayed on Challenge 25 signage at the bar and entry points
• Applied consistently — no exceptions for regular customers who "everyone knows," no discretion based on how well they're dressed or how confident they seem

Acceptable ID

Not all ID is equal. Trading Standards conduct test purchase operations where young-looking individuals attempt to buy alcohol with no ID or with invalid ID. Your staff need to know what they can and cannot accept.

The standard acceptable forms of ID for proving age in licensed premises are:

• A valid UK or EU passport (or equivalent from another country)
• A valid UK photocard driving licence (full or provisional)
• A card bearing the PASS hologram (the Proof of Age Standards Scheme — this includes many branded proof-of-age cards and some student union cards)
• An HM Forces identity card

That is it. A student union card without a PASS hologram, a bank card, a bus pass, or anything else does not count. Your staff need to know this clearly, not approximately.

Include your list of acceptable ID in the operating schedule. Then include it in your staff training and post it behind the bar.

Fakes and how to handle them

Your staff will occasionally encounter fake ID. They are not required to be document experts, but they should know the basics: is the photo a reasonable match, does the date of birth make the person 18 or over, does the document look obviously tampered with? When in doubt, refuse. The consequence of refusing a legitimate customer is that they don't get a drink. The consequence of serving an underage person is a criminal offence, a fine, or potentially the loss of the premises licence.

If a member of staff is presented with ID they believe is false, they should confiscate it and hand it to the police if practicable, record it in the incident log, and refuse service. Commit to this process in the operating schedule.

The refusal log

Every time you refuse service to someone because they cannot prove their age, it should go in the refusal log. Date, time, description of the person (without identifying details), what ID they provided if any, and who made the refusal decision.

This log serves two purposes. First, it is evidence that your Challenge 25 policy is actually being applied, not just written down and forgotten. Second, if you are ever prosecuted for underage sales or your licence is reviewed, a robust refusal log showing consistent application of your policy is the strongest mitigation you have.

The refusal log should be separate from or clearly identified within your incident log. It should be kept at the premises and available to authorised officers on request.

Staff training

Training records for age verification are critical. If a member of staff serves an underage person, the question that follows is: did you train them properly? If you can produce a training record showing that this specific person completed age verification training before they worked their first bar shift, that is evidence of due diligence. If you cannot, the absence of training records is its own problem.

Training should cover: why Challenge 25 exists, what ID is acceptable, how to handle someone who doesn't have ID (politely but firmly), how to handle suspected fake ID, and how to record a refusal. Keep the record — who was trained, by whom, on what date, and what was covered. A short sign-off sheet works fine.

Include agency staff and temporary staff. They do not get an exemption because they are only working one night.

Children's access to your venue

This is where many operators do not think carefully enough. The fact that you are primarily an adult venue does not automatically mean children cannot be on the premises. In fact, unless your licence contains a specific condition restricting access, the law does not automatically prohibit under-18s from being in licensed premises at all times. The restriction on selling alcohol to them does not mean the premises is off-limits to them.

You need to decide what your policy on under-18s is, and state it in the operating schedule. The options:

• No under-18s at any time (the simplest, most common approach for nightclubs)
• Under-18s permitted during specified hours (e.g. a bar that does food during the day may allow children in until 9pm, with later hours adults-only)
• Under-18s permitted only when accompanied by an adult and only in certain areas

Whatever your policy, write it clearly. If you have a mixed-use premises (restaurant and bar, café by day and club by night), map out exactly when each part applies and how you transition between modes. Ambiguity here is what causes problems.

Adult entertainment

If your venue runs or intends to run adult entertainment — burlesque, exotic dancing, strip nights, or anything with explicit content — this objective has additional teeth. Under the Licensing Act, "the protection of children from harm" explicitly includes protecting children from exposure to adult entertainment, and conditions restricting access during these events are standard.

Typically this means: robust age verification on entry during any event with adult entertainment, a clear policy that under-18s are not admitted under any circumstances during those events, and a mechanism for ensuring those customers who arrived earlier (e.g. for dinner) are either over 18 or have left before the entertainment begins.

If you apply for a Sexual Entertainment Venue licence (a separate process under the Local Government (Miscellaneous Provisions) Act 1982, not the Licensing Act), the requirements are more stringent still and involve a separate application to the council. This is its own topic and beyond the scope of this page — if you are heading in that direction, take legal advice specific to your local authority.

Putting it in your operating schedule

Protection of children from harm is one of the more straightforward objectives to write if your venue is a straightforward adults-only late-night bar or club. The core commitments are Challenge 25, acceptable ID, a refusal log, and a clear under-18s exclusion policy. Write them specifically, not vaguely, and evidence that they are real by linking them to training and records.

Our operating schedule template walks through this objective in full, including prompts for age verification, staff training records, and access policy. It is free, and built from a real UK venue application.