KGI’s Assigning Responsibility for Age Assurance examines how policymakers can allocate responsibility for age assurance across the digital ecosystem. It provides practical recommendations for assigning age assurance obligations in ways that support youth online safety while appropriately accounting for tradeoffs involving privacy, competition, accessibility, and openness.
As governments around the world increasingly adopt age assurance requirements intended to make online experiences safer for young people, a key policy question is how responsibility for age assurance should be allocated across the digital ecosystem.
Establishing a user’s age and using that information to provide age-appropriate online experiences involves a series of related functions, including assessing a user’s age, communicating age information to the relevant service, and implementing the protections, defaults, or restrictions associated with that age signal. These functions can be carried out by different actors – including app developers, operating system providers, app stores, device manufacturers, and dedicated age verification providers – with important implications for privacy, service availability, competition, and resistance to circumvention.
KGI’s Assigning Responsibility for Age Assurance: Recommendations for Youth Online Safety examines how responsibility for age assurance should be allocated for the case where age assurance requirements are imposed to establish safer defaults for youth. The brief argues that, regardless of how users’ ages are assessed or communicated, app developers should retain primary legal responsibility for ensuring that the age information they rely on to apply age-appropriate settings satisfies applicable legal requirements.
This brief complements KGI’s Age Assurance Online, which assesses existing age assurance technologies, and Age Assurance Rules: An Implementation Guide, which provides broader recommendations for designing effective implementation rules.
The brief offers five recommendations to help policymakers assign responsibility for different age assurance functions to the appropriate entities:
Age assurance can play a role in supporting safer online experiences for young people, but only when implemented in ways that are responsive to the harms being addressed and that appropriately balance the benefits of age assurance against the costs to privacy, service availability, competition, and openness. As policymakers continue to explore age assurance mandates, new obligations should ensure that responsibility for youth safety requirements remains with app developers, as they are the actors best positioned to prevent harm.
Where policymakers choose to involve device intermediaries, such as app stores, operating system providers, or device manufacturers, their role should be narrowly tailored to transmitting privacy-preserving age signals to services that have a legal obligation to act on them. By drawing on these recommendations, policymakers can better support effective age assurance while avoiding unnecessary tradeoffs. Policies that extend beyond this limited role risk creating significant costs for privacy, competition, and open technology ecosystems without meaningfully improving protections for youth.
Resources
Age Assurance Online
Age Assurance Online Report Overview
Age Assurance Rules
Assigning Responsibility for Age Assurance
KGI’s Age Assurance Rules provides practical recommendations for designing age assurance rules that support youth online safety while appropriately accounting for tradeoffs involving privacy, service availability, competition, and openness.
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