On his first visit to India since becoming the United Kingdom’s prime minister last year, Keir Starmer has met with his Indian counterpart, Narendra Modi, in Mumbai, the country’s financial capital, alongside a caravan of British business and cultural leaders.
In particular, Starmer wants to know more about India’s mammoth digital ID system – which logs the world’s largest population, with more than 1.3 billion cards issued – two weeks after announcing a controversial digital ID system for the UK.
Starmer hailed India’s ID system as a “massive success” as he defended that announcement, which has been met with criticism from rights groups.
During his trade-centric visit to Mumbai, Starmer also held a meeting with Nandan Nilekani, cofounder and chair of Indian tech services group Infosys, who headed the government body which delivered the ID database more than a decade ago.
So, why is Starmer so interested in India’s ID system? What are the concerns in the UK? And what can London learn from mistakes made in New Delhi?
Why is the UK introducing a digital ‘Brit Card’?
Starmer has pitched the new digital ID, to be known as a “Brit Card”, at the core of his plans to tackle irregular migration and exploitative work practices in the UK.
A digital ID system “will make it tougher to work illegally in this country, making our borders more secure”, Starmer said last month.
In addition to verifying that a person is permitted to work in the UK, the Brit Card will also offer citizens “countless benefits, like being able to prove your identity to access key services swiftly”, he said.
While ID cards have long been common in other Western European countries, the UK has a history of strong resistance towards them.
Speaking to reporters on his way to Mumbai this week, Starmer said he hopes, however, that digital IDs, which will become mandatory by 2029, will gain public confidence because of the convenience they will be able to provide.
“I don’t know how many times the rest of you have had to look in the bottom drawer for three bills when you want to get your kids into school or apply for this or apply for that – drives me to frustration,” he said. “I do think that we could gain a significant advantage.”
However, rights groups have strongly criticised the proposal of digital IDs, which, they say, would infringe on people’s right to privacy – and more than 2.2 million people have signed a petition opposing the introduction.
The petition describes the Brit Card as a “step towards mass surveillance and digital control”, and adds that “no one should be forced to register with a state-controlled ID system.”
How does India’s ‘Aadhaar’ digital ID system work?
India’s digital ID system, Aadhaar, is much bigger and far more detailed than the one the UK is planning. New Delhi stores people’s fingerprints, eye scans, photos, home addresses and phone numbers, and its system processes about 80 million authentications each day.
By comparison, the UK’s proposed digital ID system will be much narrower in scope, focusing on basic identity verification, without collecting biometric data like fingerprints or iris scans.
Under Aadhaar, every Indian citizen receives a 12-digit number that aims to replace many paper documents. All adults and children more than the age of five must provide biometric information.
The system is used to verify identities when people open bank accounts or apply for a new SIM card for their mobile phones, for example. The system has also aimed to streamline the disbursement of government benefits, giving the holder instant proof of identity and access to basic services.
Launched in 2009, the Indian government has issued more than 1.3 billion cards and claims to have saved nearly $10bn in administration costs. Some critics say that is an overstatement, however.
UK officials have made it clear that they do not wish to replicate the Aadhaar system – rather, to learn from how it has been implemented.
A government spokesperson denied that the system would store biometric data of holders, adding that “one of the core priorities is inclusivity and that’s what the British consultation will be about.”
Why is India’s Aadhaar controversial?
India’s Aadhaar has suffered several mass data leaks, at times exposing the personal information belonging to as much as 85 percent of the population and raising concerns about privacy.
At least three large-scale Aadhaar data leaks were reported in 2018, 2019 and 2022, with personal information put up for sale on the dark web, including one from the government’s COVID-vaccination portal.
In January 2025, the Indian government allowed private companies to access Aadhaar’s databases for authentication purposes. To gain access, private companies must apply and be vetted by the government. Critics have opposed this access to behavioural and biometric data.
“The core problem with Aadhaar was conceptual – centralisation of digital ID and accompanying biometric information should be avoided,” said Vrinda Bhandari, a Supreme Court lawyer with a focus on digital rights and privacy. “More importantly, it should never be linked or seeded into other databases.”
Public confidence is low. A survey conducted earlier this year by civic-tech company LocalCircles revealed that 87 percent of Indian citizens believe elements of their personal data are already in the public domain or on compromised databases. That number is a rise from 72 percent in 2022.
The government body, Unique Identification Authority of India, which issues Aadhaar cards, maintains that personal data is secure. But India does not yet have a robust data protection law in practice, so critics say there is no way to be sure of this.
“The creation of a digital ID architecture requires strong legal and data privacy protections,” said Bhandari. “Without this supporting law and the surrounding complaints infrastructure, citizens are forced to fight expensive legal battles in courts.”
The reliance on Aadhaar has also led to greater hardship for some of the country’s most marginalised and poorest citizens, denying them medical care or food rations, critics say.
Technical problems have often halted the payment of pensions when fingerprints don’t match or internet connectivity has stalled, with researchers claiming that Aadhaar has often made welfare delivery more difficult, not easier.
India’s Supreme Court approved Aadhaar’s use for welfare and taxes but restricted its use by private companies or in education in 2018, following a case lodged by civil society groups. This year’s access to the system for private groups was made possible by policy changes which introduced government vetting into the process.
Furthermore, critics argue, India’s digital ID system has created an “architecture of surveillance” without strong enough safeguards.
Have other countries drawn inspiration from the Indian model?
Yes. In 2019, Kenya attempted to build a national digital ID system that closely followed India’s Aadhaar model.
The government launched the National Integrated Identity Management System (NIIMS), also called Huduma Namba, to streamline government services and fight fraud. Its design drew heavily from the Aadhaar framework.
But the project quickly faced pushback from civil society groups, who argued that it was fraught with privacy and exclusion flaws, with no adequate legal safeguards to protect citizens. In 2020, these groups lodged a case against the introduction of the system in the High Court in Nairobi, which halted the rollout.
The following year, Kenya passed its Data Protection Act, which created a legal framework for collecting, storing, and processing personal data, and later rebranded its system as “Maisha Namba”, promising stronger oversight of how citizens’ biometric and personal data would be stored and used. Various legal challenges, which argue that gaps in safety have not been adequately addressed, however, are ongoing.
The national ID systems in other countries, including the Philippines, Morocco and Ethiopia, are also modelled on Aadhaar.
In the UK, rights groups have raised concerns about Starmer’s Brit Card plan. Silkie Carlo, the director of Big Brother Watch, a UK-based civil liberties and privacy advocacy organisation, warned that the system would “make Britain less free” and create “a domestic mass surveillance infrastructure that will likely sprawl from citizenship to benefits, tax, health, possibly even internet data and more”.
Addressing these concerns in September when the ID system was announced, the UK’s culture secretary, Lisa Nandy, said ministers had “no intention of pursuing a dystopian mess”.
What else did Modi and Starmer discuss in Mumbai?
On Thursday, Modi and Starmer were hoping to capitalise on their July free-trade agreement. Aiming to turbocharge commercial links, the UK delegation included more than 100 leaders from British businesses and universities.
Under the trade agreement signed in July, India and the UK agreed to cut tariffs on goods ranging from textiles and whisky to cars in order to double trade to $120bn by 2030.
“India’s dynamism and the UK’s expertise together create a unique synergy,” Modi said, after talks with the British prime minister on Thursday, adding that the industry leaders accompanying Starmer “reflect the new energy and broad vision” in the partnership.
Starmer said: “When we leave India tonight, I expect that we will have secured major new investments creating thousands of high-skilled jobs in the sectors of the future.”
Ultimately, the two countries announced a string of new agreements on Thursday.
A statement by the Indian Ministry of External Affairs said the two sides had agreed to set up an India-UK connectivity and innovation centre and a joint centre for the development of artificial intelligence (AI), and unveiled a critical minerals industry guild to bring together businesses and researchers and to coordinate the safe mining and processing of minerals.
An official handout from the UK government noted that 64 Indian companies would collectively invest 1.3 billion pounds ($1.73bn) in the UK.
“The UK-India trade deal is already unlocking growth, and today’s announcements mark the beginning of a new era of collaboration between our two nations,” Starmer said.
What difficulties remain?
London and New Delhi do not see eye to eye on all issues, however.
One major bone of contention is Russia’s invasion of and ongoing war in Ukraine. The UK, as part of NATO, has taken a strong position against Moscow, imposing sanctions and sending weapons to Kyiv. India avoids condemning Russia, however, and has continued to buy Russian oil – part of the reason United States President Donald Trump said he was imposing 50 percent trade tariffs on India earlier this year.
Indian officials describe their position towards Russia as a policy of strategic autonomy, while British and European leaders view it as a major point of divergence within their broader partnership.
Another area of tension is Khalistan-related activism in the UK. India has repeatedly raised concerns about Sikh separatist groups operating from British soil, especially after the 2023 vandalism of the Indian High Commission in London.
In 2023, a BBC documentary that portrayed Modi in an unflattering light was denounced by Indian officials as “anti-India propaganda”.
At the same time, tensions between India and Canada – a member of the UK’s Five Eyes intelligence alliance – deepened after Ottawa alleged Indian involvement in the killing of Sikh separatist Hardeep Singh Nijjar.
