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Report from the IAB/W3C Workshop on Age-Based Restrictions on Content Access
RFC 9998

This RFC was published on the Internet Architecture Board (IAB) stream. This RFC is not endorsed by the IETF and has no formal standing in the IETF standards process.
Document Type RFC - Informational (June 2026)
Was draft-iab-agews-report (individual)
Authors M. Nottingham , M. Thomson
Last updated 2026-06-15
RFC stream Internet Architecture Board (IAB)
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RFC 9998


Internet Architecture Board (IAB) M. Nottingham
Request for Comments: 9998 
Category: Informational M. Thomson
ISSN: 2070-1721 June 2026

 Report from the IAB/W3C Workshop on Age-Based Restrictions on Content
 Access

Abstract

 The Workshop on Age-Based Restrictions on Content Access was convened
 by the Internet Architecture Board (IAB) and World Wide Web
 Consortium (W3C) in October 2025. This report summarizes the
 significant points of discussion and identifies topics that may
 warrant further consideration and work.

 Note that this document is a report on the proceedings of the
 workshop. The views and positions documented in this report are
 those of the workshop participants and do not necessarily reflect IAB
 or W3C views and positions.

Status of This Memo

 This document is not an Internet Standards Track specification; it is
 published for informational purposes.

 This document is a product of the Internet Architecture Board (IAB)
 and represents information that the IAB has deemed valuable to
 provide for permanent record. It represents the consensus of the
 Internet Architecture Board (IAB). Documents approved for
 publication by the IAB are not candidates for any level of Internet
 Standard; see Section 2 of RFC 7841.

 Information about the current status of this document, any errata,
 and how to provide feedback on it may be obtained at
 https://www.rfc-editor.org/info/rfc9998.

Copyright Notice

 Copyright (c) 2026 IETF Trust and the persons identified as the
 document authors. All rights reserved.

 This document is subject to BCP 78 and the IETF Trust's Legal
 Provisions Relating to IETF Documents
 (https://trustee.ietf.org/license-info) in effect on the date of
 publication of this document. Please review these documents
 carefully, as they describe your rights and restrictions with respect
 to this document.

Table of Contents

 1. Introduction
 1.1. Views Expressed in This Report
 1.2. Chatham House Rule
 2. Overview of the Workshop
 3. Key Takeaways
 3.1. There Is a Need for Cross-Cutting Collaboration
 3.2. Identifying the Roles Involved Is Important
 3.3. A Common Vocabulary Is Necessary
 3.4. Privacy and Trust Expectations Need Further Discussion
 3.5. More Than One Approach Will Be Required
 3.6. Mapping the Risks for Architectures Is a Useful Next Step
 3.7. Safety Requires More Than a Technical Solution
 4. Security Considerations
 5. IANA Considerations
 6. Informative References
 Appendix A. Workshop Agenda
 A.1. Topic: Introduction
 A.2. Topic: Setting the Scene
 A.3. Topic: Guiding Principles
 A.4. Topic: Potential Impacts
 A.5. Topic: Where Enforcement Happens
 A.6. Topic: Available Techniques
 A.7. Discussion
 A.8. Summary and Reflection
 A.9. Outcomes
 Appendix B. Workshop Participants
 Appendix C. Potential Impacts
 C.1. Impact on Children
 C.2. Ecosystem Impact
 C.3. Implementation and Deployment Difficulties
 C.4. Security and Privacy
 C.5. Equity
 C.6. Societal Impacts
 Appendix D. Desirable and Essential Properties of a Solution
 D.1. Functional
 D.2. Accountability and Transparency
 D.3. Privacy and Security
 D.4. Equity
 D.5. Jurisdiction and Geopolitical
 D.6. Usability
 D.7. Implementation and Deployment
 D.8. General/Other
 IAB Members at the Time of Approval
 Authors' Addresses

1. Introduction

 Regulators and legislators around the world are increasingly
 restricting what can be made available to young people on the
 Internet in an effort to reduce the potential for harm.

 In October 2025, the Internet Architecture Board (IAB) and the World
 Wide Web Consortium (W3C) convened the Workshop on Age-Based
 Restrictions on Content Access. This workshop brought together
 technologists, civil-society advocates, business interests, and
 government stakeholders to discuss the nuances of the introduction of
 such measures.

 The primary focus was "to perform a thorough examination of the
 technical and architectural choices that are involved in solutions
 for age-based restrictions on access to content" with a goal of
 "build[ing] a shared understanding of the properties of various
 proposed approaches".

 See the workshop announcement [ANNOUNCE] for details; papers and
 presentation materials are linked from the announcement. This report
 summarizes the proceedings of the workshop.

1.1. Views Expressed in This Report

 This document is a report on the proceedings of the workshop. The
 views and positions documented in this report were expressed during
 the workshop by participants and do not necessarily reflect the views
 or positions of the IAB or W3C, nor those of all participants.

 Furthermore, the content of the report comes from presentations given
 by workshop participants and notes taken during the discussions,
 without interpretation or validation. Thus, the content of this
 report follows the flow and dialogue of the workshop but does not
 attempt to capture a consensus.

1.2. Chatham House Rule

 Participants agreed to conduct the workshop under the Chatham House
 Rule [CHATHAM-HOUSE], so this report does not attribute statements to
 individuals or organizations without express permission. Most
 submissions to the workshop were public and thus attributable; they
 are used here to provide substance and context.

 Appendix B lists the workshop participants, unless they requested
 that this information be withheld.

2. Overview of the Workshop

 The IAB/W3C Workshop on Age-Based Restrictions on Content Access
 brought together a diverse group of participants from technical,
 policy, regulatory, and research communities to examine how the
 Internet might accommodate demands for age-based access controls.
 Over three days, discussions traversed the intersection of
 technology, governance, human rights, and social expectations, with a
 recurring emphasis on privacy, accountability, and the preservation
 of the open architecture of the Internet.

 The workshop began with a framing session that emphasized the
 Internet's original design as a universal, non-segmented space.
 Participants observed that the Web does not innately distinguish
 between adult and child users, and that governments are creating
 regulatory environments that shift responsibility from parents and
 individuals to service providers. The scope of discussion was
 tightly defined: not the morality or policy of age restrictions, but
 the technical, architectural, and human-rights implications of
 enforcing them. The challenge, many participants agreed, lay in
 building mechanisms that are accurate, respect privacy, maintain
 global interoperability, and avoid creating infrastructure that could
 be repurposed for censorship or surveillance.

 Early exchanges focused on terminology and scope: whether "age
 verification" should be understood narrowly as identity checking or
 more broadly as "age assurance". The conversation also touched on
 the diversity of cultural expectations about parental authority and
 the variety of legal frameworks emerging across jurisdictions. Some
 participants warned of "slippery slope" effects, where mechanisms
 designed for age checks might evolve into tools for broader identity
 enforcement. Several noted that while liability drives many policy
 decisions, technical design should aim to minimize harm and avoid
 over-centralization. The question of who bears responsibility for
 child safety -- platforms, regulators, or device manufacturers --
 surfaced repeatedly.

 Human-rights principles were foregrounded as a basis for evaluation.
 Privacy was discussed not only in terms of data protection law
 (including techniques like minimization) but also as protection from
 unwanted exposure or interaction. Freedom of expression and opinion
 was considered, particularly how both adults and children have rights
 to communicate, access information, and associate free from the
 chilling effects of surveillance or discrimination. The group
 revisited long-standing Internet design tenets, such as
 decentralization and the end-to-end principle, asking how they should
 inform modern architectures that could easily drift toward central
 control. Some argued that successful systems must remain open,
 interoperable, and reversible; others cautioned that any solution --
 even a well-intentioned one -- would inevitably reshape the
 Internet's social and economic balance.

 Technical sessions explored a spectrum of enforcement models:
 service-based, network-based, and device-based. Service-based
 enforcement systems place a compliance burden on websites, risking
 fragmentation and user fatigue from repeated verification flows.
 Network-based filtering -- already common in some jurisdictions --
 offers broad coverage but limited accuracy and significant privacy
 trade-offs. Device-based enforcement, in which operating systems
 mediate access based on a one-time verification, were praised for
 their potential usability and consistency but criticized for
 potential concentration of power among major vendors. Many
 participants noted that a pluralistic approach is more likely to be
 successful, recognizing that no single architecture can meet all
 requirements equally across jurisdictions.

 Privacy-enhancing technologies (PETs) such as anonymous credentials
 and zero-knowledge proofs (ZKPs) were discussed as promising, though
 not necessarily sufficient, tools. In particular, PETs don't address
 all privacy concerns and, likewise, don't address wider issues around
 access to underlying sources of truth. Furthermore, some
 participants cautioned that PETs cannot prevent circumvention or
 censorship and are relatively untested. They also cautioned that
 open-sourcing code does not automatically make systems trustworthy.
 A recurring concern was that while credential-based verification may
 work well in countries with unified ID systems, it risks excluding
 people without access to such credentials and entrenching
 inequalities.

 Discussions on parental controls and network operator roles
 highlighted practical tensions between effectiveness, usability, and
 user rights. Although some participants saw value in layered
 approaches combining device, service, and network measures, others
 noted the high complexity and low adoption of parental-control tools
 even where available. The workshop also revisited the ethical
 dimension: whether designing better tools might unintentionally
 legitimize overbroad or intrusive regulation.

 By the third day, participants reflected on the need for
 collaboration across disciplines and institutions. Many acknowledged
 that while complete solutions are unlikely in the short term,
 articulating shared vocabulary, architectural roles, and evaluation
 properties was an essential foundation. There was broad agreement
 that future work should map risks against possible architectures,
 document trade-offs in neutral terms, and communicate clearly with
 policymakers to prevent outcomes that could undermine Internet
 openness.

 The meeting closed with reflections on what process might be followed
 to take proposed solutions through a standards process. Both IETF
 and W3C representatives outlined how exploratory work might proceed
 within their respective frameworks, stressing that standardization
 would require consensus, open participation, and time.

 While a workshop is not able to provide specific standards proposals
 or take positions on the advisability of regulatory proposals, it was
 suggested that leadership bodies, including the IAB and the Technical
 Architecture Group (TAG), could make statements to that effect.

 While the current status quo -- where age restrictions are piecemeal,
 opaque, and often privacy-eroding -- was unsatisfactory to most
 participants, many cautioned that hasty solutions could entrench
 worse problems. This led to growing recognition that protecting
 children online must not come at the expense of the Internet's
 foundational freedoms and that sustained, multi-stakeholder
 collaboration is the only viable path forward.

3. Key Takeaways

 This section highlights aspects of discussion at the workshop that
 appeared to be most impactful.

3.1. There Is a Need for Cross-Cutting Collaboration

 Many participants remarked that the workshop allowed them to
 appreciate perspectives that they had not fully considered
 previously. Although several substantial efforts have included
 industry, civil society, government, and technologists, collaboration
 across all stakeholders appears to be rare.

 This was especially evident when considering the involvement of the
 technical community. Although there have been a number of
 consultations by governments and other bodies, involvement of the
 technical community is often limited to participation by the policy
 representatives of technology companies. This can lead to an
 underappreciation of the architectural impact and related harm of the
 design decisions made.

 Architectures effective for the goals and less likely to have
 profound harmful consequences may require the cooperation of multiple
 actors fulfilling different roles (see Section 3.2). To that end,
 standardization may be especially important for interoperable,
 collaborative development of architectures involving both servers and
 clients.

 Some participants also noted that approaches where liability rests
 only on one party -- for example, a content or platform provider --
 are unlikely to lead to the desired results because this creates
 disincentives for the cooperation that is necessary for meaningful
 reduction of harm. An approach that considers the roles of the
 young, their parents, device manufacturers, operating system vendors,
 content providers, and society overall was believed to be more likely
 to succeed.

3.2. Identifying the Roles Involved Is Important

 One of the more substantive discussions on architecture involved
 presentations on the functional roles involved in any system
 [HANSON].

 Four key roles were identified:

 Verifier: The verifier role determines whether a person falls into a
 target age range.

 Enforcer: The enforcer is responsible for ensuring that a person who
 does not satisfy the verifier is unable to access age-restricted
 content or services.

 Policy selector: The policy selector is responsible for determining
 which policies should apply to the user, based on their
 jurisdiction, status, or preferences.

 Rater: The rater is responsible for determining whether content or
 services require age restrictions and the age ranges that apply.

 In addition, it was noted that ratings and laws are often limited by
 geography or jurisdiction, so it is often necessary for services to
 first identify the applicable jurisdiction. It was generally
 accepted that this function often uses IP geolocation mappings,
 despite acknowledged limitations around accuracy and susceptibility,
 to circumvent using VPNs.

3.3. A Common Vocabulary Is Necessary

 Early discussions highlighted how not all participants used the same
 terminology when referring to different activities or functions.
 There was a recognition of the value of shared language, and some
 participants pointed to [ISO-IEC-27566-1]. Definitions of key terms,
 as discussed by participants, include:

 Age assurance: Age assurance is an umbrella term for technology that
 provides some entity with information about the age of a person.
 This is understood to encompass multiple classes of specific
 methods, including age verification, age estimation, and age
 inference. Age assurance does not need to result in a specific
 age; age ranges are often preferred as they can have better
 privacy properties.

 Age verification: Age verification refers to gaining high assurance
 that a person is within a given age range. Strong assurances are
 often tied to official or governmental documentation, so age
 verification can involve the use of government-issued digital
 credentials.

 Age estimation: Age estimation uses statistical processes that
 process physical or behavioral characteristics of a person to
 produce a probabilistic value for how old someone is or whether
 their age is in a target range. A variety of techniques are used,
 the most common being facial age estimation, which uses machine
 learning models to estimate how old a person is based on still or
 moving images of their face.

 Age inference: Age inference draws on data sources to determine
 whether a person fits a given age range. This method can require
 identification information, such as an email address or phone
 number, to find relevant records. For example, evidence of online
 activity prior to a certain date in the past might support the
 view that a person is older than a target threshold.

 Age gating: Age gating is the process of restricting access to
 something based on the age of the person requesting access.

 Relating these functions to the roles described in Section 3.2, all
 age assurance types fit the "verifier" role, whereas age gating
 applies to the "enforcer" role.

3.4. Privacy and Trust Expectations Need Further Discussion

 Privacy was a recurrent theme at the workshop, but it was clear that
 there are multiple considerations at play when talking about it. The
 question of privacy was often caught up in discussions of trust,
 where approaches each depend on different sorts of trust between the
 different actors.

 Participants identified privacy as important to maintaining trust in
 any system that involves age assurance or age gating.

 Where private information is used by the actors in a proposed
 architecture, those actors might need to be trusted to handle that
 private information responsibly. In that approach, the importance of
 different safeguards on personal information, such as the prompt
 disposal of any personal information -- a practice that many age
 verification providers promise -- becomes a core part of what might
 allow people to trust that system.

 Several people observed that the sort of trust that is asked from
 people might not correspond with the role that certain entities play
 in people's lives. This will depend on context, where "adult"
 content providers generally serve anonymous users, whereas social
 media often already has a lot of personal information on users.

 In either case, users might have no prior knowledge of -- or trust in
 -- providers that are contracted to provide age assurance functions.
 It was observed that one likely consequence of some arrangements is
 to train people to become more trusting of strange sites that ask for
 personal information.

 Alternatively, it might be that trust in the system is not vested in
 actors, but in the system as a whole. This is possible if no
 information is made available to different actors, removing the need
 to trust their handling of private information. For this to be
 achievable, the use of ZKPs or similar cryptographic techniques was
 seen as a way to limit what each entity learns. However, some
 participants noted that these techniques do not address circumvention
 or censorship risks, still introduce new information into the
 ecosystem, and may concentrate trust in particular software
 implementations.

 Other aspects of trust were considered equally important from
 different perspectives. Services that rely on an independent age
 assurance provider need to trust that the provider makes an accurate
 determination of age, at least to the extent that they might be held
 liable in law. They also need to trust that the service respects
 privacy, lest the use of a low-quality provider could create other
 forms of liability or drive away potential customers.

3.5. More Than One Approach Will Be Required

 A recurrent theme in discussion was the insufficiency of any
 particular age assurance technique in ensuring that people are not
 unjustifiably excluded. All age assurance methods discussed fail to
 correctly classify some subset of people:

 * Age verification that depends on government-issued credentials
 will fail when people do not hold accepted credentials. This
 includes people who do not hold credentials and those who hold
 credentials that are not recognized.

 * Age estimation produces probabilistic information about age that
 can be wrong by some number of years, potentially excluding people
 near threshold ages. This manifests as both false acceptance
 (people who are outside the target age range being accepted) and
 false rejection (people who are in the target age range being
 rejected). Where there is a goal of minimizing the false
 acceptance rate, that increases the number of false rejections.

 * Age inference techniques can fail due to lack of information.

 Discussion often came back to an approach that is increasingly
 recommended for use in age verification, where multiple methods are
 applied in series. Checks with lower friction -- those that require
 less active participation from people -- or that are less invasive of
 privacy are attempted first. Successive checks are only used when a
 definitive result cannot be achieved.

 Some participants noted that inconsistent friction and invasiveness
 create a different kind of discrimination, one that can exacerbate
 existing adverse discrimination. For example, the accuracy of age
 estimation for people with African ancestry is often significantly
 lower than for those with European ancestry [FATE]. This is
 attributed to the models used being trained and validated using
 datasets that have less coverage of some groups. People who are
 affected by this bias are more likely to need to engage with more
 invasive methods.

 One consequence of having multiple imperfect techniques is the need
 to recognize that any system will be imperfect. That creates several
 tensions:

 * Some people will never be able to satisfy age assurance checks and
 will therefore be excluded by strict assurance mandates. Here,
 discussions acknowledged that purely technical systems are likely
 inadequate.

 * Some people who should be blocked from accessing content or
 services will find ways to circumvent restrictions. In this
 context, the term "advanced persistent teenager" was recognized as
 characterizing the nature of the "adversary": individuals who are
 considered too young to access content, but who are highly
 motivated, technically sophisticated, and have time to spare.

 * Offering more choices to people can improve privacy because they
 get to choose the method that suits them. However, when a chosen
 method fails, having to engage with additional methods has a
 higher privacy cost.

 Some participants argued that accepting these risks is necessary in
 order to gain any of the benefits that age-based restrictions might
 confer. Other participants were unwilling to accept potential
 impositions on individual rights in light of the insufficiency of
 restrictions in providing meaningful protection; see Section 3.7.

3.6. Mapping the Risks for Architectures Is a Useful Next Step

 How the identified roles (see Section 3.2) are arranged into
 architectures was some of the more substantive discussion. [JACKSON]
 describes some of the alternatives, along with some of the
 implications that arise from different arrangements.

 Throughout this discussion, it was acknowledged that active
 deployments tend to fall into a common pattern, where content
 providers are required to age-gate access and contract a third party
 to interpose that service. Several participants noted that this is a
 somewhat natural consequence of some of the constraints that actors
 are subject to. Figure 1 shows the typical deployment model for age-
 gated content and services, along with the roles from Section 3.2.

 o
 ---+--- +------------+ +-----------+
 | | | Visits | | Rater +
 + | Browser |--------------------->| Website | Policy
 / \ | | .---| | Selector
 / \ +------------+ | +-----------+
 | | Redirected To |
 | | | +-----------+
 | | '-->| |
 | | Evidence of Age | Age |
 | '----------------------->| Assurance | Verifier
 | | Service |
 | .---| |
 | | +-----------+
 | Redirected To |
 | | +-----------+
 | '-->| Age- |
 | Admitted | Gated | Enforcer
 '--------------------------->| Content |
 or Blocked +-----------+

 Figure 1: Typical Deployment Model

 Some participants also noted that certain approaches may carry higher
 path-dependence risk once widely deployed, even if they remain
 theoretically possible to withdraw or replace. This can arise from
 accumulated architectural dependencies, operational integration with
 third-party services, and evolving expectations among users and
 service providers. As a result, architectures that tightly couple
 functionality with external verification services or embed
 assumptions about routine age signaling may increase the practical
 cost of transition if alternative approaches later emerge that
 address privacy, equity, or effectiveness concerns more effectively.

 Figure 2 shows a deployment model for parental-control software,
 showing how the roles from Section 3.2 might apply. Here, parental
 controls do any verification of age necessary and select policies;
 content ratings might be performed by websites or the parental-
 control software on the device, or both (noted with a "*" in the
 figure); enforcement is performed on-device.

 o
 ---+--- +------------+ Visits +-----------+
 | | |--------------------->| |
 + | Browser | (Rated) Content | Website | Rater*
 / \ | |<---------------------| |
 / \ +------------+ +-----------+
 ^ ^
 | \
 | \__ Rater* +
 | Enforcer
 |
 +------------+
 | Parental | Verifier +
 | Controls | Policy Selector
 +------------+

 Figure 2: Parental-Control Deployment Model

 An observation was made that laws often seek to designate a single
 entity as being responsible for ensuring that age restrictions are
 effective. That lawmakers feel the need to designate a responsible
 entity is due to constraints on how laws function, but one that
 creates other constraints.

 Another constraint identified was the need for specialist expertise
 in order to administer all of the multiple different age assurance
 techniques; see Section 3.5. This means that there is a natural
 tendency for services to contract with specialist age assurance
 services.

 Some of the proposed architectures were better able to operate under
 these constraints. Others required greater amounts of coordination,
 further emphasizing the importance of collaboration identified in
 Section 3.1.

 In discussion of the constraints on different architectures, it was
 common for participants to point to a particular aspect of a given
 approach as carrying risks. Indeed, the final reckoning of risks
 produced a long list of potential issues that might need mitigation
 (see Appendix C).

 Architectures are not equally vulnerable to different risks, so a
 more thorough analysis is needed to identify how each risk applies to
 a different approach. An analysis that considers the constraints and
 assumptions necessary to successfully deploy different architectures
 is a contribution that would likely be welcomed by participants.

3.7. Safety Requires More Than a Technical Solution

 Experts in child safety frequently acknowledged that restricting
 access to selected content cannot be assumed to be sufficient. The
 task of ensuring that children are kept appropriately safe while
 preparing them for the challenges they will face in their lifetimes
 is a massively complex task.

 A recurrent theme was the old maxim, "it takes a village to raise a
 child". This concept transcends cultural boundaries and was
 recognized. The roles played by parents, guardians, educators,
 governments, and online services in creating an environment in which
 children can thrive and grow were also discussed.

 Content and service restrictions are likely only a small part of a
 suite of actions that combine to provide children with protection,
 but also support and encouragement. This theme was raised several
 times, despite the goal of the discussion being to explore technical
 and architectural questions.

 Restrictions are necessarily binary and lacking in nuance. Though
 questions of what to restrict were out of scope for the workshop,
 discussions often identified subject matter that highlighted the
 challenges inherent in making simplistic classifications.
 Participants acknowledged the importance of the role of the adults
 who support children in their life journey. For example, on the
 subject of eating disorders, which can be challenging to classify,
 participants pointed to the importance of being able to recognize
 trends and inform and engage responsible adults. Ultimately, each
 child has their own challenges, and the people around them are in the
 best position to provide the support that best suits the child.

 The concept of age-appropriate design was raised on several
 occasions. This presents significant privacy challenges in that it
 means providing more information about age to services. However, it
 was recognized that there are legal and moral obligations on services
 to cater to the needs of children of different age groups. This is a
 more complex problem space than binary age restrictions, as it
 requires a recognition of the different needs of children as they get
 older.

4. Security Considerations

 Age verification has a significant potential security impact upon the
 Internet; see Section 3.4.

5. IANA Considerations

 This document has no IANA actions.

6. Informative References

 [ANNOUNCE] Internet Architecture Board, "IAB/W3C Workshop on Age-
 Based Restrictions on Content Access (agews)",
 <https://datatracker.ietf.org/group/agews/about/>.

 [CHATHAM-HOUSE]
 Chatham House, "Chatham House Rule",
 <https://www.chathamhouse.org/about-us/chatham-house-
 rule>.

 [FATE] Ngan, M., Grother, P., and A. Hom, "Face Analysis
 Technology Evaluation (FATE) Part 10: Performance of
 Passive, Software-Based Presentation Attack Detection
 (PAD) Algorithms", National Institute of Standards and
 Technology, NIST IR 8491, DOI 10.6028/NIST.IR.8491,
 September 2023,
 <https://nvlpubs.nist.gov/nistpubs/ir/2023/
 NIST.IR.8491.pdf>.

 [HANSON] Hanson, J., "Where Enforcement Happens", IAB/W3C Workshop
 on Age-Based Restrictions on Content Access, October 2025,
 <https://datatracker.ietf.org/doc/slides-agews-slides-
 where-enforcement-happens/>.

 [ISO-IEC-27566-1]
 ISO/IEC, "Information security, cybersecurity and privacy
 protection - Age assurance systems - Part 1: Framework",
 ISO/IEC 27566-1:2025, December 2025,
 <https://www.iso.org/standard/88143.html>.

 [JACKSON] Jackson, D., "Where Enforcement Happens", IAB/W3C Workshop
 on Age-Based Restrictions on Content Access, October 2025,
 <https://datatracker.ietf.org/doc/slides-agews-where-
 enforcement-happens/>.

Appendix A. Workshop Agenda

 This section contains a copy of the workshop agenda.

A.1. Topic: Introduction

 We will launch the workshop with a greeting, a round of
 introductions, and an explanation of the terms of engagement,
 background, goals and non-goals of the workshop.

A.2. Topic: Setting the Scene

 Successfully deploying age restrictions at Internet scale has many
 considerations and constraints. We will explore them at a high level
 in order. The goal is to discuss within the group about the scope of
 topics that the workshop will seek to address.

A.3. Topic: Guiding Principles

 Architectural principles give us a framework for evaluating additions
 and changes to the Internet. Technical principles are subject to a
 number of other considerations, in particular human-rights
 principles. We will review the principles that might apply to age-
 based restrictions, explain their function, impact, and how they are
 applied. Including human-rights impacts, such as:

 * Privacy and Security
 * Safety and Efficacy
 * Censorship and Access
 * Access to the Internet
 * Freedom of Expression

 And effects on the Internet and Web architecture, such as:

 * Deployment, Extensibility, and Evolution
 * Avoid Centralization
 * End-to-End
 * One Global Internet/Web
 * Layering and Modularity

A.4. Topic: Potential Impacts

 We now want to look at some of the higher-level considerations that
 apply regardless of approach. We will look at some different
 perspectives on how to think of the overall problem. Discussion will
 seek to find how those perspectives can be shaped to guide choices.

A.5. Topic: Where Enforcement Happens

 The Internet standards community is in the unique position to make
 controlled changes to the architecture of the Internet, and so there
 are multiple ways and places to deploy age restrictions. We will
 examine the options, with an eye to the deployment properties of each
 location and configuration, as related to the architectural
 principles. In particular, it will consider the establishment of new
 roles as well as the use of existing ones.

A.6. Topic: Available Techniques

 There are several active and proposed systems for age restriction on
 the Internet. We will review them from the perspective of their
 interaction with the architectural principles, potential impacts, and
 with consideration of the enforcement options. Including:

 * Age verification: including server-side solutions using government
 identity systems and ZKPs
 * Age estimation: including biometrics and data analysis
 * Age "inference" approaches
 * In-network solutions
 * Classification and on-device/parental-control designs

A.7. Discussion

 We will follow up on incomplete discussions and revisit architectural
 learnings.

A.8. Summary and Reflection

 We will summarize what we have discussed and learned thus far.

A.9. Outcomes

 We will outline the potential outcomes, further actions, and next
 steps.

Appendix B. Workshop Participants

 Attendees of the workshop are listed with their primary affiliation.
 Attendees from the program committee (PC), the Internet Architecture
 Board (IAB), and W3C Technical Architecture Group (TAG) are also
 marked.

 * Steve Bellovin
 * Hadley Beeman, TAG (PC)
 * Matthew Bocci, IAB (Observer)
 * Christian Bormann, SPRIND
 * Marcos Cáceres, TAG (Observer)
 * Andrew Campling, 419 Consulting
 * Sofía Celi, Brave
 * David Cooke, Aylo
 * Iain Corby, Age Verification Providers Association
 * Dhruv Dhody, IAB (Observer)
 * Nick Doty, Center for Democracy and Technology (PC)
 * Sarah Forland, New America Open Technology Institute
 * Jérôme Gorin, École Polytechnique
 * Alexis Hancock, Electronic Frontier Foundation
 * Julia Hanson, Apple
 * Wes Hardaker, University of Southern California Information
 Sciences Institute
 * Kyle den Hartog, Brave
 * Dennis Jackson, Mozilla
 * Leif Johansson, SIROS Foundation
 * Mallory Knodel, Article 19
 * Mirja Kühlewind, IAB (Observer)
 * Jonathan Langley, Ofcom UK
 * Veronica Lin, Carnegie Mellon University
 * Thibault Meunier, Cloudflare
 * Tom Newton, Qoria
 * Mark Nottingham, IAB (PC Co-Chair)
 * Georgia Osborn, Ofcom UK
 * Tommy Pauly, IAB (PC)
 * John Perrino, Internet Society
 * Eric Rescorla, Knight-Georgetown Institute
 * Beatriz Rocha, Ceweb.br
 * Omari Rodney, Yoti
 * Gianpaolo Scalone, Vodafone
 * Sarah Scheffler, Carnegie Mellon University
 * Andrew Shaw, UK National Cyber Security Centre
 * Aline Sylla, German Federal Commissioner for Data Protection and
 Freedom of Information
 * Martin Thomson, TAG (PC Co-Chair)
 * Carmela Troncoso, EPFL, the Swiss Federal Institute of Technology
 in Lausanne
 * Benjamin VanderSloot, Mozilla
 * Tara Whalen, World Wide Web Consortium (PC)

Appendix C. Potential Impacts

 During the workshop, participants were asked to name potential
 impacts -- whether positive or negative -- that could be seen in
 association with the introduction of age-based restrictions. This
 list is not exhaustive, focuses largely on the challenges surrounding
 the introduction of mechanisms, and does not imply that all points
 were agreed to by all participants.

C.1. Impact on Children

 1. Children encounter online harm
 2. Pushing kids to less safe resources
 3. Kids lose the ability to explore on their own
 4. Diminishing children's rights

C.2. Ecosystem Impact

 1. Centralization
 2. Fragmentation of the Internet
 3. Increased costs for running a website
 4. Chilling effects on use of the Internet
 5. VPNs proliferate
 6. Chilling effects on the publication of borderline content
 7. Less content being available online
 8. Restricting people to a few platforms/services
 9. More use/utility of the Internet due to a perception of safety
 10. More (or all) online services require a verified login

C.3. Implementation and Deployment Difficulties

 1. Device compatibility
 2. "Advanced Persistent Teenagers"
 3. Difficulties regarding jurisdiction checking
 4. Spillover to other software (e.g., VPNs)
 5. Displacing users from compliant to non-compliant sites
 6. False sense of addressing the problem
 7. Dealing with conflict of laws
 8. Operators pulling out of territories
 9. Increasing the footprint of the deep web
 10. Imposition of cultural norms on other jurisdictions
 11. Technical solutions are reused for other purposes (scope creep)
 12. Dealing with obsolete and non-compliant systems

C.4. Security and Privacy

 1. Increased cybersecurity risks
 2. Fingerprinting risk
 3. Ad targeting could get creepier
 4. Needing to trust someone on their word without evidence
 5. Normalizing online identity requests -- increase to phishing risk
 6. Data breaches

C.5. Equity

 1. Lack of access (e.g., due to lack of device support)
 2. Refugees, stateless people, people without identity
 3. Harm to vulnerable people
 4. Not addressing other vulnerable groups (i.e., not age-based)
 5. Lack of availability of redress mechanisms
 6. Users' rights to restitution
 7. Loss of control over and access to data
 8. Risk to anonymity
 9. Loss of ability to run software of your choice

C.6. Societal Impacts

 1. Air cover for blocking the Internet
 2. User control of the content they see online
 3. Costs to society (e.g., regulatory overhead)
 4. Increased online tracking and state surveillance
 5. Use as a censorship mechanism
 6. Advancing foreign policy goals with censorship
 7. Abuse of guardians who don't cut off their wards

Appendix D. Desirable and Essential Properties of a Solution

 During the workshop, participants were asked to nominate the
 properties that they believed would be advantageous or even essential
 for a solution in this space to have. This set of requirements and
 desiderata was recognized as not all being achievable, as some goals
 are in tension with others.

D.1. Functional

 1. Underage don't access content that's inappropriate
 2. Not trivially by-passable
 3. Flexible enough to be provided through different means
 4. Bound to the user
 5. Reliable
 6. Handles user-generated content
 7. Enables differential experiences or age-appropriate design (not
 just blocking)
 8. Agile by design -- assume adversarial engagement
 9. Difficult to bypass
 10. Accurate

D.2. Accountability and Transparency

 1. Transparency and accountability regarding what is blocked
 2. Minimizes the need for trust decisions
 3. Can be independently/publicly verifiable and tested
 4. Auditability
 5. Appeal mechanism for incorrect labeling of content

D.3. Privacy and Security

 1. Issuer-Verifier and Verifier-Verifier unlinkability
 2. Unlinkability across components
 3. Purpose limitation of the data processed
 4. Security of data processed
 5. Phishing-resistant
 6. Doesn't process or transfer any more data than is necessary
 7. Avoids becoming a tracking vector

D.4. Equity

 1. Inclusive
 2. Fair -- avoids or minimizes bias
 3. Does not create inequalities (e.g., across education, other
 properties)
 4. Discriminates solely upon age, not other properties
 5. Works on open devices
 6. Device independence
 7. Usable by people of all ages to increase their safety online
 8. User choice in who verifies their age, and how
 9. No clear losers
 10. Accessible to people with disabilities
 11. Includes appeal mechanisms for incorrect age determinations

D.5. Jurisdiction and Geopolitical

 1. Able to handle arbitrary composition of different jurisdictional
 requirements (possibly down to school level)
 2. Applicable globally
 3. Applies the rule of law in the jurisdiction where it applies
 universally
 4. No concentration of power in any one entity (or small group of
 them)
 5. No concentration of power in any country
 6. Aligned to legal duties
 7. Based upon a valid legal basis

D.6. Usability

 1. Economically sustainable
 2. Low friction for adults
 3. Fast
 4. Comprehensible by users

D.7. Implementation and Deployment

 1. Low dependency on a single root of trust
 2. Enforceable by a good mix of technology and law
 3. Broad deployability -- not expensive or complex
 4. Decentralized
 5. Future-proof
 6. Ability to report/learn when there are issues in the system/
 telemetry

D.8. General/Other

 1. Not perfect
 2. Technically robust
 3. Not a single, sole solution
 4. Stable -- resilient
 5. Alignment of incentives among participants
 6. Simple to implement
 7. Resistance to repurposing for censorship
 8. Unable to be used for surveillance
 9. Addresses risk of verification becoming over-prevalent
 10. Accountable governance
 11. Open Standards-based

IAB Members at the Time of Approval

 Internet Architecture Board members at the time this document was
 approved for publication were:

 * Ali C. Begen

 * Matthew Bocci

 * Roman Danyliw

 * Dhruv Dhody

 * Jana Iyengar

 * Suresh Krishnan

 * Warren Kumari

 * Jason Livingood

 * Mark Nottingham

 * Yingzhen Qu

 * Alvaro Retana

 * Yaroslav Rosomakho

 * Nick Sullivan

Authors' Addresses

 Mark Nottingham
 Email: mnot@mnot.net

 Martin Thomson
 Email: mt@lowentropy.net