A passport is normally issued for ten years, and the fees to be charged are laid down by a Statutory Instrument. There is no provision in this Statutory Instrument to permit the Passport Office to waive the fee for persons aged less than 65 years.
Apart from the legal dimension, the reality is that, if this attractive concessionary scheme is to work satisfactorily, there clearly has to be a fixed starting date and fixed qualifications for persons to benefit under it. However, unless the passport holder has immediate travel plans, new passports do not of course have to be applied for on, or be valid from, the date when the previous passport expired. A person approaching 65 years may well wish, therefore, to wait until they reach that age and then apply for a free passport.