UK Digital Identity & Data Reform — What Founders Need to Know (2025/2026)
Estimated read time: 5 minutes
“Digital identity” isn’t a buzzword anymore—it’s the next compliance frontier. The UK is moving from pilots to production: the Data (Use and Access) Act 2025 (DUAA) is now law and explicitly enables digital verification services, while the UK Digital Identity & Attributes Trust Framework (DIATF) has advanced, with a public register for certified providers. And from 18 November 2025, Companies House starts mandatory identity verification for directors and PSCs—using GOV.UK One Login or an authorised provider.
Why this matters now
Board-level accountability: Identity proofing decisions (how you verify, who you trust, what you retain) will be judged on evidence. DUAA phases-in changes through 2026, so regulators and partners will expect proportionate, documented controls—not just policies. ico.org.uk
Mandatory checks arriving in your stack: As Companies House verification goes live, founders must coordinate legal, HR, finance and product so that onboarding, role access, and director/PSC flows cohere. gov.uk+1
Customers notice dignity: People share only what they understand. Clear language, minimal data, and the ability to reverse a choice build trust (and reduce complaints).
What’s changed in the ecosystem
Digital identity services can be certified against the DIATF; there’s now a public register (searchable by role type: identity, attribute, orchestration, etc.). This makes vendor assurance more concrete: you can check certifications and renewal dates. digital-identity-services-register.service.gov.uk+1
Trust framework rules matured: The current DIATF (gamma 0.4) took effect 1 July 2025, clarifying “must” vs “could” requirements and how they apply by role. That means your provider’s controls aren’t generic—they’re testable. gov.uk+1
Government identity journeys standardising: GOV.UK One Login continues rolling out (with features like open-banking-assisted verification on the roadmap), signalling where UX patterns are heading. sign-in.service.gov.uk
Three implications for founders
Verification will be formalised—internally and externally. Expect more assurance labels in contracts (eg, certified to DIATF role X, re-cert due <date>). Your due-diligence files should include the provider’s certification, scope, and incident posture. digital-identity-services-register.service.gov.uk
Layered accountability is inescapable. Your risk ≈ your provider’s risk. If your vendor’s redaction or device-binding fails, you own the outcome. Bake “evidence you can produce in a week” into service schedules (logs, decisions, and DPIA references). ico.org.uk
Trust becomes a product feature. People will opt-in faster when they can see: what’s collected, why it’s necessary, how long it’s kept, and how to change their mind.
Design principles to ship this quarter
Proportionality by default: Collect only what’s essential for the asserted claim (eg, “is over 18” vs full DOB).
Choice symmetry: Make “no” as easy as “yes” (no dark patterns).
Explainability in plain language: One screen that answers “why, how, how long, who sees it.”
Reversibility: Allow users to revoke a credential or switch verification route (document the exceptions).
Auditability: Keep a short, human-readable log of verification decisions and controls used.
Vendor diligence (fast + defensible)
When assessing or switching digital ID partners:
Check the register: Confirm the provider’s role, scope, and certification status/expiry. Screenshot and file the record. digital-identity-services-register.service.gov.uk
Map the data path: What raw attributes leave the user’s device? What’s stored at rest? For how long?
Failure modes: How do they handle false negatives/positives? What’s the fallback route and how is it evidenced?
Incident posture: Ask for the last two post-incident reviews (sanitised) and the first-hour RACI.
Contract hygiene: Tie service fees to recertification; require notice for role/scope changes under DIATF. Include minimum logging and evidence packs in the schedule.
Security & privacy posture to verify
Authentication: MFA that supports backup methods (don’t strand users). One Login’s roadmap suggests where the bar is moving. sign-in.service.gov.uk
Data minimisation + retention: Store the assertion you need, not the full document image, where possible.
DPIA & LIAs: If you rely on legitimate interests, maintain a current balancing test; link it to your DPIA and RoPA entry for the relevant journey. gov.uk
Redress: Publish a simple route for users who can’t pass verification (accessibility, alternative channels).
Founders’ 30/60/90-day plan
Next 30 days
Name an owner (Product + Privacy) for your identity flows.
Inventory verification touchpoints: onboarding, password resets, high-risk actions, staff access.
Pick metrics: time-to-verify, drop-off rate, % manual reviews, % verified via alternative route.
Next 60 days
Run a DPIA-lite on your highest-risk flow; file the decision log.
Vendor evidence pack: certification proof, retention policy, incident response summary, sub-processor list—drop into your audit folder. digital-identity-services-register.service.gov.uk
Directors/PSC route ready: rehearse the Companies House verification path (user comms + support FAQs). gov.uk
Next 90 days
Ship one improvement that reduces data collected or shortens retention (and announce it publicly).
Tabletop an incident: 30-minute drill on a failed verification or credential theft scenario; fix one bottleneck.
Publish transparency notes: “What we changed and why” (one paragraph in your changelog or help centre).
Risk radar for 2026
Certification churn: Providers will recertify against evolving DIATF versions; track expiries and role changes. gov.uk
Ecosystem dependencies: As One Login spreads across government services, user expectations for clear flows and recovery options will rise. sign-in.service.gov.uk
Board scrutiny: With DUAA bedding in, regulators emphasise evidence and proportionality over paperwork theatre. ico.org.uk
A quiet invitation
If it helps, I’ve got a one-page “Digital Identity Readiness Checklist” you can use to map owners, artefacts and deadlines. Reply with “ID Readiness” and I’ll share it—no sales pitch, just a tool.
Mediajem Compliance — Governance. Integrity. Trust.
Helping you turn values into verifiable systems.
hello@mediajemcompliance.com | www.mediajemcompliance.com
