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This is indeed the reason.

When making ID cards for my children, I was too lazy to also apply for a passport at the same time. Applied a few weeks later and the photos got rejected because they were the same as the ID ones. According to the clerk, they can be identical only when both submissions are on the same day.

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In the UK, when I renewed my driving license online I was offered the option to have them pick up the photo from my passport record, rather than send in a new photo.

Since the passport had been issued about 9 years before, the new driving license contained a picture already 9 years old (and identical to the passport).

Nearly ten years later (nearing expiry), it therefore contains a photo about 19 years old. I like to think I still look like that youthful person, of course.

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