FOI/202600512950 · FOI · partially withheld
Digital identity scheme consultation queries: FOI release
Information requested
1. Has the Scottish Government been formally consulted by the UK Government on the proposed national digital identity scheme, including the proposal to assign digital identities to children at birth? 2. What is the Scottish Government’s position on whether the scheme would apply to Scotland? 3. Whether any Scottish Government officials have attended meetings with UK Government officials about the digital identity programme, and if so when and what was discussed? 4. Whether there are any plans to connect ScotAccount — the identity layer underpinning MyCare.scot — with the proposed UK national digital identity infrastructure?
Response
1. While Scottish Government officials engaged in routine intergovernmental discussions with UK Government officials following the announcement of proposals for a UK national digital identity scheme on 26 September 2025, these discussions did not constitute a formal consultation process, and the Scottish Government was not consulted on the content, scope, or framing of the UK Government’s public consultation.
The Scottish Government’s formal consideration of the proposals will be through a response to the UK Government’s public consultation, which launched on 10 March 2026.
The following link to a previous FOI request received, explains the correspondence received by UK Government directly following the announcement and the request to engage with devolved administrations. UK Government's plans to introduce a digital ID: FOI release - gov.scot
2. The Scottish Government has been clear in its opposition to any mandatory digital identity scheme, particularly where concerns arise in relation to inclusion, proportionality, privacy, and non‑discrimination.
The Scottish Government will consider the proposals set out in the public consultation to assess which elements, if any, may be relevant to devolved services or matters within the competence of the Scottish Parliament.
3. I have interpreted your request as referring to meetings held directly between Scottish Government and UK Government officials concerning the proposed UK national digital identity scheme following the announcement on 26 September 2025.
On that basis, Scottish Government officials attended nineteen meetings with UK Government officials between 1 October 2025 and 26 March 2026.
I have included a list of the meeting dates below: 1 October 2025 7 October 2025 15 October 2025 22 October 2025 29 October 2025 5 November 2025 12 November 2025 18 November 2025 19 November 2025 26 November 2025 3 December 2025 5 December 2025 12 December 2025 17 December 2025 9 January 2026 19 January 2026 16 February 2026 26 February 2026 17 March 2026
These meetings formed part of regular engagement with devolved administrations and broadly followed a standing agenda covering:
General updates Consultation‑related topics Any Other Business (AOB)
While we can confirm the number, dates, and broad nature of these meetings, we are unable to disclose the detailed content of discussions held. Although multiple meetings took place and followed a standing agenda, a significant proportion related to discussions on the timing and management of the delayed consultation process rather than engagement on the substantive content of policy design, constitutional competence, delivery risks, and public trust implications in relation to an active UK policy process.
The following exemptions under the Freedom of Information (Scotland) Act 2002 apply to the information requested:
Section 28(1) – relations within the United Kingdom Section 30(b)(ii) – free and frank exchange of views for the purposes of deliberation
The information withheld comprises confidential intergovernmental discussions, including provisional information, advice and emerging assessments exchanged between UK Government and Scottish Government officials in relation to the proposed UK national digital identity scheme.
The information is exempt under section 28(1) of FOISA, as disclosure would, or would be likely to, prejudice substantially, relations between the Scottish Government and the UK Government.
The discussions relate to sensitive and developing policy considerations, where internal information and early views were shared on a confidential basis. Disclosure would be likely to undermine trust between administrations by revealing such material publicly, thereby prejudicing effective intergovernmental working and future cooperation.
The information is also exempt under section 30(b)(ii) of FOISA. Disclosure would be likely to inhibit substantially the free and frank exchange of views for the purposes of deliberation.
Although some positions have evolved, consideration of the UK Government’s proposals remains ongoing, including in the context of the current public consultation. Releasing deliberative content at this stage would reduce officials’ willingness to express candid views, test policy options, and explore risks openly, undermining effective policy development.
Both exemptions are subject to the public interest test, and we have carefully considered whether the public interest in disclosure outweighs the public interest in withholding the information.
We recognise the public interest in transparency and accountability, particularly in relation to engagement between administrations on matters that may have implications for devolved responsibilities, public services, and individuals in Scotland. Disclosure could help inform public understanding of how such matters are being considered.
However, we have concluded that this is outweighed by the public interest in maintaining intergovernmental relations and preserving a safe space for officials to engage in open and frank discussions, particularly while policy development remains ongoing following the UK Government’s decision on 14 January 2026 to reconsider elements of the proposed scheme, including its mandatory nature.
We considered whether partial disclosure could meet the public interest test but concluded that even limited disclosure of records would risk revealing provisional views, negotiating positions, and internal assessments, undermining both effective intergovernmental relations and the integrity of ongoing policy deliberation.
On balance, the public interest favours withholding the information in order to protect effective governance and informed decision‑making.
4. There are currently no plans to connect ScotAccount with the proposed UK national digital identity infrastructure.
We continue to work with the UK Government on a commitment to interoperability and federation of credentials with their existing GOV.UK One Login programme, where this will benefit users of both Scottish and UK public services.
About FOI
The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.
Contact Please quote the FOI reference Central Correspondence Unit Email: contactus@gov.scot Phone: 0300 244 4000 The Scottish Government St Andrew's House Regent Road Edinburgh EH1 3DG
Detected exemption language
The following exemptions under the Freedom of Information (Scotland) Act 2002 apply to the information requested: Section 28(1) – relations within the United Kingdom Section 30(b)(ii) – free and frank exchange of views for the purposes of deliberation The information withheld comprises confidential intergovernmental discussions, including provisional information, advice and emerging assessments exchanged between UK Government and Scottish Government officials in relation to the proposed UK national digital identity scheme. The information is exempt under section 28(1) of FOISA, as disclosure would, or would be likely to, prejudice substantially, relations between the Scottish Government and the UK Government. The information is also exempt under section 30(b)(ii) of FOISA. Both exemptions are subject to the public interest test, and we have carefully considered whether the public interest in disclosure outweighs the public interest in withholding the information.
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