NO2ID

Passport renewal applications are now being checked against credit agency data to ensure that they are 'safe'.

Enhanced application and checking will be introduced soon. But what is to stop the Identity and Passport Agency at some point next year writing to holders of recently renewed passports and informing them that have been placed on the Register?

No need to issue a card. They could build up the information required for all the data fields over time, and the obligation to inform them of changes in circumstances for life, address etc, would be imposed at a stroke.

The trigger event for the notification obligations under the Act appears to be an application to be registered. Though there is provision for information to be entered on the NIR by the Secretary of State without an application, he has no obligation to inform you that such an entry is being made, and you do not therefore seem to be registered in quite the same way. It is one of the stranger bits of the Act.