HM Passport Office

3. Mr X complains in January 2023 HMPO rejected him as a referee for his friend’s urgent passport application without explaining why.

4. He says it refused to disclose or discuss the reason for this decision on security grounds. He considers this is not something that should prevent transparency. He says it labelled him as ‘unfit’ to act as a referee without justification.

5. Mr X says HMPO’s actions have caused him inconvenience, worry and diminished confidence. He is anxious that something may be wrong with his own passport or with his suitability to act as a referee in future.

6. In bringing his complaint to us, Mr X would like HMPO to apologise for what went wrong and the impact this had. He would also like it to change its procedures so it can tell people why they have been rejected as a referee in future cases.

7. On 27 January Mr X attempted to provide an online reference for his friend’s passport application. HMPO’s online system notified Mr X he could not proceed and told his friend that Mr X did not meet the criteria to confirm his identity.

8. On 31 May Mr X made an online complaint to HMPO. The following day HMPO acknowledged his complaint.

9. On 20 July HMPO issued its first-stage complaint response. It said it was unable to disclose specific reasons why a counter-signatory/referee was rejected for security reasons. Mr X escalated his complaint the same day.

10. On 19 August HMPO issued its final complaint response. It said it could not provide further details, but Mr X could contact the Disclosure of Information Team for further information.

11. On 20 August Mr X complained to the Independent Examiner of Complaints (IEC). It accepted the complaint for examination four days later.

12. On 4 July 2024 the IEC shared its decision with Mr X. It explained HMPO followed its own guidance in not disclosing why it rejected Mr X as a referee.

15. Before we decide if we should conduct a detailed investigation of a complaint, we look at whether there are signs the organisation has got something wrong. We do this by comparing what should have happened with what did happen.

16. A passport applicant must nominate someone they know to confirm their identity. The person nominated is known as a ‘referee’ or ‘counter-signatory’. For online passport applications, the applicant can nominate either a digital (online) referee or a paper referee. HMPO’s website explains the criteria to be a referee.

17. Once the customer nominates their referee online, HMPO’s Digital Customer Services (DCS) sends an email asking the referee to verify the applicant’s identity. To do this, the referee must provide the application reference number and the intended passport holder’s date of birth.

18. DCS conducts automatic checks as the referee completes the application and verifies the customer’s identity. If any of the automatic checks are unsuccessful then DCS will reject the digital referee.

19. There are two main reasons why DCS would automatically reject a referee. Either the referee:

• fails the initial security checks because the details entered do not match the details held by HMPO, or • gives unacceptable answers to the qualifying questions.

20. HMPO guidance was updated in July 2025. However, the relevant parts remained the same as those used at the time of the events Mr X has complained about. For this reason, we have relied on them as appropriate standards.

21. The guidance says if any of the automatic checks are unsuccessful then DCS will reject the digital referee. HMPO will tell the customer and digital referee they have been rejected but it will not tell them why.

22. In this case, HMPO rejected Mr X as a digital referee and notified him and his friend. This suggests Mr X did not pass one or more of the automatic checks. We have not been able to establish which checks were unsuccessful, as HMPO does not store this information.

23. Our role is to consider whether an organisation has followed the relevant guidance. We can see HMPO acted in line with its own guidance when it did not to give Mr X further detail about the rejection.

24. We understand why Mr X wanted to know the specific reason for the rejection. Unfortunately, this is not possible, but we understand why the lack of explanation caused him worry and uncertainty about his suitability to act as a referee.

25. We have seen no indication of failing in this complaint and will not be continuing our consideration. We thank him for bringing his concerns to us.

1. We have carefully considered Mr X’s complaint about HM Passport Office (HMPO). We are sorry to hear how much distress this situation has caused him.

2. Having looked carefully at the evidence, we have not identified any failings in HMPO’s decision not to disclose the reason it rejected Mr X as a digital referee. For that reason, we have decided to take no further action on this complaint. We have explained the reasons below in more detail.