Scotland and England could use facial recognition but lots of decisions needed

4th December 2025

The Scottish Government and Police Scotland could and appear to be preparing for adoption of facial recognition (or at least live-facial-recognition, LFR) in Scotland. But it's not a guaranteed "roll-out everywhere" yet. Here's how things stand as of late 2025.

Police Scotland has recently confirmed plans to move ahead with future use of live facial recognition.
Scottish Biometrics Commissioner
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The legal basis for police biometrics in Scotland already exists: the Scottish Biometrics Commissioner Act 2020 provides for oversight of "acquisition, retention, use and destruction of biometric data" for criminal-justice and policing purposes.
Legislation.gov.uk
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The office of the Scottish Biometrics Commissioner has signalled conditional support for LFR — under a framework that ensures use is justified, proportionate, and subject to safeguards.

The institutions and regulatory structures are in place, and there's official momentum (from police leaders and biometric-oversight bodies) toward deploying LFR in Scotland.

The ruling political party (Scottish National Party, SNP) recently passed a resolution that opposes deployment of LFR by police unless there's new primary legislation passed.

As of 2025, there is no specific, dedicated legislation in Scotland authorising general live-facial-recognition policing. The frameworks in place cover biometric data broadly — but not necessarily LFR in public spaces by default.

There remains substantial opposition from human-rights and civil-liberties groups, warning that LFR could lead to "mass surveillance," bias, wrongful identification, and threats to democratic freedoms.

Even from within policing circles, there are cautions: some experts argue LFR is not "fit for purpose," or that there's insufficient evidence that it reliably catches serious criminals — especially given concerns over bias, accuracy, and ethics.

Police Scotland may deploy live-facial-recognition cameras (for example on vans or at events) provided that "use cases," necessity, and proportionality are clearly defined.

The Scottish Parliament or relevant bodies may need to pass new legislation (or revise existing biometric-use laws) to formalise and regulate LFR.

Use would at least nominally be subject to oversight by the Scottish Biometrics Commissioner, and subject to data-protection and human-rights safeguards (in principle).

Given the alignment of police interest, biometric-oversight framework, and ongoing decision-making there is a real chance that facial-recognition could become part of policing in Scotland within the next few years.

But public opinion and politics are likely to slow things up.

England

Recent reporting suggests the government is pushing to widen deployment of facial-recognition technology across the UK (or at least across most of England and Wales). But it's not quite a simple "facial recognition for everyone always" decision yet.

The government — through the Home Office — recently announced a plan to expand the use of live facial-recognition (LFR) technology across more police forces in England and Wales.

As part of that, 10 new LFR-equipped vans are being deployed across seven forces (e.g. Greater Manchester, West Yorkshire, Surrey, Sussex, etc.).

The government is also working on a "national facial-matching service" — a centralized system intended to allow police nationwide to match photos (e.g. from CCTV, passport/immigration databases, etc.).

Alongside deployment, they've launched a public consultation (10-week) aimed at shaping new regulation and oversight for use of biometrics, including facial recognition.

In other words there is a concerted plan to scale up police access to facial recognition across large parts of the country, with infrastructure and regulation under development.

The expansion is framed as targeted: the vans and LFR systems are to be used "when there is specific intelligence" — i.e. to catch serious or "high-harm" offenders, not casual surveillance of everyone.

The legal framework is still under development there is no dedicated law yet that standardises LFR across all contexts. Its current use still relies on a patchwork of existing powers.

There remain strong objections from civil-liberties and human-rights organisations (as well as a statutory regulator — Equality and Human Rights Commission, EHRC) pointing out risks of unlawful surveillance, privacy breaches, misuse and bias.

So the system is being expanded but it's not yet a fully “ubiquitous mass-surveillance” setup mandated nationwide. The implementation is still uneven and under negotiation/consultation.