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).

  • 2
    Purely one man's opinion, you should be fine. Just as origimbo explains, they deliberately have no specific guidelines, so that they can make an arbitrary call.
    – Fattie
    Commented Jan 5, 2018 at 12:02
  • 1
    I renewed my passport recently and had a similar concern having grown a beard since my last passport photo. Everything was fine. I wouldn't worry unless your appearance has changed drastically beyond hairstyles, facial hair and general ageing. Commented Jan 5, 2018 at 12:57
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    UK law has the idea of the "man on the Clapham omnibus" (en.wikipedia.org/wiki/The_man_on_the_Clapham_omnibus) who is taken to be a reasonably educated and intelligent but nondescript. I think that even in the case of a legal case if this reasonable stranger would agree that both photos are of the same person you'd be more than fine.
    – MD-Tech
    Commented Jan 5, 2018 at 15:22
  • I mean, if you were really worried about it, can't you scan and email a signature? No need to travel, it's 2018. Commented Jan 5, 2018 at 17:47
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    @Azor-Ahai If you have to get someone to sign to verify your photograph, they have to sign on the back of the actual physical photograph that they’re verifying, so it can’t be emailed.
    – Mike Scott
    Commented Jan 6, 2018 at 10:40

2 Answers 2


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.


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.

  • I'll leave this up for awhile to allow for other answers just in case, but this seems to answer my question. Just a note that where you've hyperlinked to the document, I think you may have made a slight error as it says "enter link description here" as the hyperlink.
    – Philbo
    Commented Jan 5, 2018 at 12:54
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    The references to "appear to show the person at the same age" would seem to link this quote to re-use of already-submitted photos, for example, a driving licence photo in the new passport. Commented Jan 6, 2018 at 13:20

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