Two sales to under 18s on the same premises within three months is persistent selling, an offence for the premises licence holder. The defence is evidence: a written policy, dated staff training and a refusals register. This pack gives pubs, bars, clubs, off-licences and shops all three.
Refusals register Staff training records One-minute check Everything for pubs and licensed premises
What the Licensing Act 2003 says for England and Wales. Where this page gives PHW's own advice, it says so.
Section 146 makes it an offence to sell alcohol to a person under 18. The penalty is a level 5 fine, which has no upper limit for offences committed on or after 12 March 2015. Section 147 makes it an offence for a person who works at the premises in a capacity that lets them prevent a sale to knowingly allow one.
Section 147A, persistent selling, is an offence for the premises licence holder where alcohol is unlawfully sold to an under 18 on the same premises on two or more different occasions within three consecutive months. The fine has no upper limit.
A court that convicts the licence holder may suspend the alcohol part of the premises licence for up to three months (section 147B). Police or trading standards can instead serve a closure notice (section 169A), which offers a ban on alcohol sales of 48 hours to 14 days in place of prosecution.
Where a premises licence allows the sale of alcohol, a mandatory condition requires the premises licence holder to adopt an age verification policy, and the designated premises supervisor to make sure alcohol is supplied in line with it. The policy must require anyone who appears to be under 18, or an older age the policy sets, to produce on request, before being served, ID showing their photograph, their date of birth and either a holographic mark or an ultraviolet feature. Since 15 September 2026 the policy may also accept digital ID checked through a registered digital verification service.
Section 19 also requires the designated premises supervisor to hold a personal licence, and every sale of alcohol to be made or authorised by a personal licence holder.
Challenge 25, asking anyone who appears under 25 for photographic ID before completing a sale of alcohol, is industry best practice and the accepted standard. The age of 25 is the venue's own policy, never a statutory duty. PHW's training tells staff it is the venue's policy and that departing from it is a disciplinary matter, never that it is the law.
Section 146(4) gives a person charged by reason of their own conduct a defence where they believed the individual was 18 or over and either took all reasonable steps to establish age or nobody could reasonably have suspected from appearance that the individual was under 18. Asking for evidence of age that would have convinced a reasonable person counts as taking all reasonable steps (section 146(5)). Section 146(6) gives a separate defence where a person is charged by reason of the act or default of some other person and exercised all due diligence to avoid committing the offence.
This is PHW's advice rather than the Act's: a court looks at what was actually done, so keep the evidence. A written policy, dated training records, staff sign-off on what they were taught and a completed refusals register support a defence and do not guarantee one. A manager saying staff know the rules is not evidence. Dated records, kept up and followed, are.
Ten documents for alcohol sales to under 18s: the policy, the training, the test and the records a defence rests on.
Refusals register (UAS-04). Kept at the till and completed before the end of every shift: date, time, who refused, why, a description of the customer, whether ID was offered and whether a manager was told. The pack says to keep it for at least two years.
Staff training records. For each member of staff: the dated training record (UAS-02), the signed knowledge test paper (UAS-03), the signed authorisation and declaration (UAS-06) and the signed briefing sheets (UAS-08). Together they show who was trained, on what, when, and that they passed.
The implementation guide sets the order: adopt the policy, train everyone who sells alcohol, test them, authorise them in writing, start the refusals register the same day, set the till prompts and signage, audit yourself, then brief the team and repeat for every new starter.
A due diligence defence needs a record that outlasts the shift the training happened on.
The pack keeps its own dated training records: who was trained, on what, the knowledge test result and the sign-off.
For each person PHW certificates, the training includes knowledge questions put and recorded as it goes. They then answer a written test in their own handwriting and are signed off against the authorisation (UAS-06). The certificate is issued only when all three are complete and signed, and PHW keeps the evidence file, the test paper, the questioning record and the signed assessment records, for at least two years.
Each certificate carries a QR code. Scanning it, or looking the reference up directly, opens a live record showing who was trained, on what, and when: the same record a licensing officer, trading standards or your own management can check without asking you to find a filing cabinet.
Tell us your venue and how many of your people sell alcohol, and we will come back with a quote.