Who Authorised the Sale? Alcohol-Sales Authorisation Explained
A new employee is standing behind the till. A customer places alcohol on the counter. The manager is busy, the Designated Premises Supervisor is away from the premises—and nobody has formally discussed alcohol-sales authorisation.
Can the employee legally complete the sale?
Alcohol-sales authorisation is frequently misunderstood. Some businesses assume that employing someone automatically allows them to sell alcohol. Others believe the DPS must personally supervise every transaction.
Neither assumption provides a reliable compliance system.
In this guide, we explain the legal requirement and the practical steps licensed premises should take to train, authorise and monitor employees who sell alcohol.
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What is the legal requirement?
Where alcohol is sold under a premises licence, every supply of alcohol must be made or authorised by somebody who holds a personal licence.
The person completing the transaction does not necessarily need to hold a personal licence. However, if they do not, they must have been authorised by a personal licence holder.
A premises licensed to sell alcohol must also normally have a nominated DPS who holds a valid personal licence. Limited exceptions apply, including certain community premises where the standard DPS requirement has been formally disapplied.
Does the DPS have to be present for every sale?
No.
The Licensing Act does not require the DPS or another personal licence holder to be physically present for every alcohol sale.
A personal licence holder can authorise employees to complete multiple transactions and may be away from the premises when an individual sale takes place.
However, being away from the premises does not remove responsibility.
The current statutory guidance states that sensible arrangements should exist for the responsible personal licence holder to monitor authorised activity on a reasonably regular basis. The premises licence holder and DPS also remain responsible for ensuring the law and premises-licence conditions are followed.
MYTH
The DPS must stand beside the till whenever alcohol is sold.
FACT
Properly authorised employees may sell alcohol while the DPS or personal licence holder is away from the premises—but effective monitoring and management must continue.
Does employing somebody authorise them to sell alcohol?
Employment alone should not be treated as evidence of authorisation.
Job titles such as bartender, cashier, waiter or supervisor do not automatically demonstrate that a personal licence holder has authorised that person to sell alcohol.
The employee should be clearly identified, trained and given defined authority before completing alcohol transactions.
Consider this scenario:
A new employee has completed a general workplace induction but has not been trained on:
The premises licence and its conditions
Permitted alcohol hours
Challenge 25
Acceptable identification
Refusing sales
Proxy purchases
Sales to intoxicated customers
Incident reporting and escalation
The premises suddenly becomes busy, and a supervisor tells the employee to start serving.
Allowing the employee to sell alcohol without appropriate training, assessment and clear authorisation creates an avoidable compliance risk.
Is written authorisation legally required?
Written authorisation is not expressly required by the Licensing Act 2003, and its absence alone should not result in enforcement action.
However, the Home Office’s February 2026 statutory guidance strongly recommends that personal licence holders provide specific written authorisation to each person they authorise to sell alcohol.
A single written authorisation can cover multiple sales over an unlimited period.
Written authorisation helps:
Identify who has been authorised
Define the limits of that authority
Demonstrate due diligence
Protect an employee whose authority is questioned
Provide evidence during a licensing inspection
Remove uncertainty after an incident or unlawful sale
A verbal instruction may be difficult to prove. A signed and current document provides much stronger evidence.
What should an alcohol-sales authorisation include?
A practical authorisation record should identify:
Who?
The employee’s full name and job role
The premises at which they are authorised
The personal licence holder granting the authority
The relevant personal licence details
What?
The activities the employee may perform
The permitted hours and licensed areas
Any limits or restrictions placed on their authority
The requirement to comply with the premises licence and company procedures
How?
The training completed before authorisation
Any knowledge or competency check
The date authorisation begins
How performance will be monitored
How authorisation may be suspended or withdrawn
Signatures from the employee and personal licence holder
The current version should be easily accessible and capable of being produced during an inspection.
Authorise competence—not simply attendance
Completing a training session does not automatically prove that someone understands the procedure.
Before authorising an employee, the business should check that they can explain and apply:
The premises’ age-verification policy
Which forms of identification are accepted
When an alcohol sale must be refused
How to respond to a suspected proxy purchase
How to deal with a person who appears intoxicated
The premises’ alcohol hours and relevant licence conditions
When to seek support from a manager
How to record refusals and significant incidents
A short knowledge check, scenario assessment or supervised observation can help establish whether the employee is ready.
Would you make this sale?
A customer appears to be approximately 22 years old but cannot produce acceptable identification.
They tell the employee:
“I come here every week.”
“My friend can confirm my age.”
“I have a photograph of my driving licence on my phone.”
If the premises operates Challenge 25, the sale should be refused.
Familiarity, reassurance from another customer or a photograph of an identity document does not override the premises’ age-verification policy.
The refusal should then be recorded in accordance with the premises’ procedure.
Some transactions require additional control
Employees under 18
Specific approval and supervision requirements may apply when somebody under 18 sells or supplies alcohol. General staff authorisation may not be sufficient.
The business should establish a clear approval process and check any relevant premises-licence conditions.
Alcohol deliveries
Delivery sales require controls at both stages of the transaction:
When the alcohol is selected and prepared at the licensed premises.
When the alcohol is handed to the customer.
Delivery employees need suitable training, authority, acceptable ID rules and a safe procedure for refusing and returning an order.
The six-action authorisation system
A strong alcohol-sales authorisation system can be remembered through six actions:
1. TRAIN
Train the employee on licensing law, the premises licence and your operational procedures.
2. CHECK
Assess their understanding using questions, scenarios or supervised observation.
3. AUTHORISE
Provide clear, preferably written, authorisation from a personal licence holder.
4. SUPPORT
Ensure a manager or supervisor is available when the employee faces a difficult decision.
5. RECORD
Maintain training, authorisation, refusal and incident records.
6. REVIEW
Monitor performance, refresh training and suspend or withdraw authority where necessary.
Could your business prove authorisation?
Ask yourself three questions:
Can every employee who sells alcohol identify the personal licence holder who authorised them?
Can you immediately produce their training and authorisation records?
Can you demonstrate how their alcohol-sales activity is monitored and reviewed?
If the answer to any of these questions is no, your premises have an avoidable weakness.
Correcting it now is far easier than attempting to explain an unclear system following an underage sale, licensing inspection or enforcement visit.
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This article provides general information and is not a substitute for legal advice. Businesses should check their premises licence, current legislation, statutory guidance and any applicable local requirements.
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