Facial recognition technology (FRT) should not become a “routine or firsthand policing tool” in the UK, the Home Office-commissioned study into the views of minority groups has found.
Conducted as part of the government’s police biometrics consultation by Thinks Insight & Strategy, the study was run as “a small-scale deliberative dialogue” with 56 people, including those from racially minoritised communities, who were either cautious or opposed to the police use of facial recognition in the UK.
Published alongside the government’s formal response to its police biometrics consultation on 4 November 2026, the authors said “trust emerged as a central theme” of the study, which found that support for police use of facial recognition is “cautious and conditional”.
Rather than becoming a “routine” policing tool, participants instead “felt it should be used only where demonstrably necessary and proportionate, in clearly defined circumstances and subject to time limits and targeted deployment”.
They were also clear that UK law enforcement bodies will need to build trust in the communities they police before they roll out facial recognition more widely.
“While some participants believed that policing is largely undertaken by well-intentioned officers whose work is undermined by a minority of ‘bad apples’, others, particularly participants from Black African, Black Caribbean and Mixed Black backgrounds, described experiences of discriminatory treatment that had significantly impacted their confidence and trust in the police,” it said.
“This context is critical. Participants consistently assessed police and law enforcement use of facial recognition technology through the lens of whether they trust the police to use their powers fairly and proportionately.”
The study added that, within this context, safeguards and independent oversight were viewed by participants as necessary pre-conditions to building trust and increasing confidence in police use of these technologies.
As part of its wider police biometrics consultation response, the government welcomed the findings of the study, noting that it aligned with its “intention to provide greater public assurance and give police forces in England and Wales greater confidence to use facial recognition within a strong and well-defined legal framework”.
It added: “As part of the framework, the government intends to make public participation in oversight a statutory requirement for both police forces and the new independent oversight body.”
Specific concerns
Areas of particular concern for those involved in the study included the potential for inaccuracy or misidentification, the deliberate misuse of the technology by individual officers, bias and discrimination, disproportionate use, the stifling of freedom of expression, and scope creep.
Many of these areas interlock. For example, on the risks of bias and discrimination, participants cited the potential for the technology to disproportionately impact on racially minoritised communities through misidentification rates (linked to inaccuracy), over-deployment at cultural events attended by Black communities (which would stifle expression), and wider patterns of deployment that could contribute to the over-policing of Black communities.
“Taken together, all of this information led to fear that police use of FRT could mean institutionalised entrenchment of existing bias against minoritised communities,” said the authors.
Participant concerns also overlapped when it came to the potential for disproportionate use and scope creep, with many feeling it would not be proportionate to use the technology for detecting individuals suspected of minor or petty crimes (which they felt was currently the case with how police forces use FRT), and expressing further concern over widespread deployment in public spaces without clear justification.
“Participants expressed an overarching concern that the ways in which facial recognition is used, and the purposes it is used for, could keep expanding,” it said.
“Given low levels of trust in police, participants feared that once normalised, safeguards around facial recognition technology use could gradually weaken. This raised concerns that these technologies could be used beyond their original, intended purposes as outlined in any new legal framework.”
To overcome the clear trust deficit, participants made a number of suggestions for how police facial recognition can be effectively regulated.
This included introducing strict rules to regulate access to government databases, stronger transparency requirements for police forces deploying the tech, and the creation of an independent oversight body, which many participants wanted to operate “without influence from the police or politicians”.
“They felt an independent body would ensure decisions are handled fairly, without bias in favour of police or policies,” the study’s authors wrote. “They were concerned that existing bodies have relationships with the police already, which could lead to decisions in favour of the police.”
In terms of what functions such an oversight body should have, participants suggested it could conduct pre-deployment approvals every time police want to use facial recognition, have strong powers to enforce against misuse, and conduct audits.
Participants were broadly in favour of public involvement in the oversight body, with some suggesting this involvement could be scheduled on a revolving basis, similar to how jury service operates.
Participants also emphasised the need for strict rules around necessity and proportionality.
“In exploring cases where someone had committed a less serious crime, participants felt the positives of catching that criminal did not outweigh the level of intrusion into privacy, or the risks of misidentification or over-surveillance,” the authors said, adding that participants also emphasised that FRT should be used only in cases where other means of solving the crime would not be effective.
“They did not consider FRT, and particularly Live FRT, to be a first line measure. Instead, it should only be used if a wanted criminal had not been caught through other means, and this criminal was a threat to public safety.”
In summarising the study, authors noted that while participants did not entirely reject the use of facial recognition by police, “they made clear that confidence in facial recognition will depend on its deployment having clear limits, fair use, strong accountability and independent oversight”.
While the government acknowledged the study – and in the process committed to statutory public participation in the oversight of police facial recognition – its wider consultation response lacks detail on what specific safeguards the government is considering, and how it will address wider concerns around bias and discrimination, proportionality and necessity (a key legal test for UK police), the protection of freedom of expression, and scope creep.
