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Preventing Underage Sales

Understanding how to manage underage sales is probably the main compliance challenge a convenience store retailer faces. This guide explains what you are legally obligated to do; what you should consider doing as best practice; and how you put in place the policies and procedures that will help you to manage this difficult area successfully.

Download the Preventing Underage Sales Guide

ACS recommends the use of Challenge 25 policies for all underage sales.

Challenge 25 is a store policy based on two simple principles:

1. All staff serving customers should be trained to ‘think 25’. This means if a customer is seeking to buy an age restricted product (of any kind), the staff member should ask themselves the question – ‘does the person in front of me look like they might be under the age of 25 years?’ If the answer is yes, then they should ask the person for a valid proof of age. If the identification confirms they are over the legal age of purchase for that product, then it can be sold to them.

2. The store policy is clearly communicated to customers, usually through the use of visible in-store signage.

Additional advice on preventing underage sales is also available on the Business Companion website here


As part of our Assured Advice on age restricted sales, we have produced guidance ffor delivery drivers on how to approach the delivery and refusal of age restricted products like alcohol, tobacco, e-cigarettes and lottery products.

The guidance, which has been designed as a quick reference guide for drivers to view on their mobile devices, details the steps that delivery drivers should go through to ensure that they are only delivering to customers that are 18 and over. This includes:

  • Establishing whether the products in a delivery include anything that is age restricted
  • The importance of utilising the Challenge25 policy for deliveries and the kinds of identification that are accepted at the point of delivery
  • When a delivery should be refused, and how to report that back to the business

Download the Home Delivery Guide



It is illegal to sell National Lottery products (including scratchcards) to anyone under the age of 18. There are strict rules for the authorisation of 16 and 17 year old sellers. It is also a breach of your National Lottery Retailer Agreement for prizes to be paid out to someone under 18. Underage sales can lead to a termination of your retailer agreement with the lottery operator, and to the removal of your lottery terminal.


For age restricted products excluding alcohol, there are additional ways that customers can provide proof of their ID digitally. You can accept digital forms of ID under the following circumstances:

  • The purchase does not include alcohol
  • The method of digital identification that is used is one that you understand how to use and is part of an age verification system that has been implemented in your business
  • The operator of the digital verification scheme can demonstrate compliance with BSI PAS 1296 – Online Age Checking: Provision and Use of Online Age Check Services


The Psychoactive Substances Act (2016) came into force on the 26 May 2016, replacing previous legislation on intoxicating substances. The primary purpose of the legislation is to stop the sale of items that are commonly known as ‘legal highs’. However, the Act will also have implications for legitimate retailers, which in many cases will sell psychoactive substances such as butane and solvents entirely legitimately.

The ACS guidance document on Psychoactive Substances can be downloaded here.

Supporting materials for this advice guide are available for ACS members. For more information about these materials, please email Chloe Hunsley at

Preventing Underage Sales - Extra Materials