GOV.UK Wallet rollout sparks competition row over mobile driving licences

The UK government’s flagship GOV.UK Wallet faces mounting scrutiny ahead of the rollout of mobile driving licences, with claims that the programme risks distorting the digital identity market.

Richard Oliphant, a specialist in digital identity law, has warned the approach could breach competition rules and provoke regulatory action. Oliphant questioned whether restricting government-issued credentials to a single, state-run wallet is lawful – raising the prospect of a complaint to the Competition and Markets Authority (CMA).

Set to be introduced in phases, with additional credentials added over time, the GOV.UK Wallet is expected to allow citizens to store and present official digital credentials on their smartphones, starting with a mobile driving licence (mDL).

But in a LinkedIn post, Oliphant warned that limiting access to the mobile driving licence could have serious legal and market consequences.

“The mobile driving licence (#mDL) is coming to the UK; but if this credential is restricted to the GOV.UK Wallet, expect to see a complaint to the Competition and Markets Authority,” he wrote.

Oliphant argued that issuing high-value government credentials exclusively through the GOV.UK Wallet would amount to preferential treatment by the state, placing private sector digital wallet providers at a structural disadvantage.

‘This is not a level playing field’

More than 50 digital verification service (DVS) providers are currently certified under the UK’s Digital Identity and Attributes Trust Framework (DIATF). These providers operate their own digital wallets and identity services, many of which are designed to hold and present verifiable credentials across public and private sector use cases.

However, Oliphant warned that if original, government-signed credentials are only made available through the GOV.UK Wallet, other certified wallets would be forced to rely on weaker, derived credentials.

“This is not a level playing field,” he said. “A credential which has been derived by a DVS provider from an mDL is not signed by the DVLA’s cryptographic key and it is NOT proof of driving entitlement.”

He added that this distinction matters for high-assurance use cases such as car hire, insurance or employer checks, where reliance on derived credentials could limit trust and usability.

Oliphant also pointed to recent legislative changes, arguing that they strengthen the case for allowing private sector wallets to store government-issued credentials.

Referring to the Data (Use and Access) Act 2025, he wrote that the legislation “would appear to entitle DVS providers to host the mDL and VCs in their certified digital wallets”.

He also raised questions about how the GOV.UK Wallet itself will be treated under the trust framework.

“If the GOV.UK Wallet is certified against the UK DIATF, it cannot be treated more favorably than any other certified digital wallet,” he said, warning that preferential treatment could distort the market.

Oliphant also argued that restricting access to core credentials undermines the purpose of the trust framework itself.

“It undermines the core aims of the now-statutory UK DIATF – encouraging innovation and a fair, contestable DVS market, interoperability, and consumer choice,” he wrote.