How close does my old passport photo have to be to my new passport photo to not require a countersignature?

Question

I'm looking to renew an expired adult passport issued when I was 16 (now 27), and under the rules for submitting new passport photos it says one photo may need to be certified (and I assume section 10 of the application countersigned) if:

• you cannot be recognised from the photograph in your current passport.

I presume they're checking the old photo to the submitted photos.

Is there any guidance on how close you have to look? I've shown my old passport photo and my to-be-submitted photo to multiple people who are in agreement that it's obviously me, but I'd prefer something more concrete than that.

The problem is that otherwise I'd need a non-family professional who's known me for at least two years to countersign, and having moved across the country, that won't be easy for me to do (without travelling back across country for this one purpose).

Answer 1

While Origimbo's answer is also correct, I posted the same question to HMPO not expecting a response for awhile. As they've already got back to me, I think their answer would count as more official and so I should use that.

Their response

Thank you for your enquiry regarding countersignature requirements

If you feel that you are recognizable from your previous passport photographs to the photographs you will be sending us, you will not require a countersignature.

The following changes will not require a photograph to be countersigned:

• Changing of hair colour/style

• Aging of skin

• Facial Hair

Thank you,

Customer Service E-mail Team.

Answer 2

This appears to be an area where the guidance (possibly deliberately) has got more vague over the years. I'm sure I remember previous versions explicitly stating something like "the effect of ordinary ageing may be disregarded" or something along those lines, but now it looks like the line in your question is all you get. There does appear to be an upload of advice to examiners, which may be relevant, particularly the paragraph

The photograph to be used for the passport must show the same person and, appear to show the person at the same age, as in the certified photo. If the original photograph received is acceptable, but the countersignature is not then, to, cover all eventualities, request 2 further photographs, one countersigned. However, if you are satisfied that the photograph already scanned onto the system shows the same person, and appears to show the person at the same age, as in the new certified photograph then the photograph already scanned onto the system can be used in the passport provided it passes all manual and automatic photograph policy standards.

Not that this provides many more details from the applicants point of view.

Personally, I'd say that if relatively casual acquaintances say they can recognise you from both the old photo and the new ones, you are probably all right to proceed, but if you're particularlly worried, then one possibility, depending on whether you had any friends with the correct professional background in your old location, would be to post the photos back and forth to them, rather than travelling yourself.