Report from the IAB/W3C Workshop on Age-Based Restrictions on Content Access
draft-iab-agews-report-00
This document is an Internet-Draft (I-D) that has been submitted to the Internet Architecture Board (IAB) stream.
This I-D is not endorsed by the IETF and has no formal standing in the
IETF standards process.
| Document | Type | Active Internet-Draft (iab) | |
|---|---|---|---|
| Authors | Mark Nottingham , Martin Thomson | ||
| Last updated | 2026-01-13 (Latest revision 2026-01-09) | ||
| RFC stream | Internet Architecture Board (IAB) | ||
| Intended RFC status | Informational | ||
| Formats | |||
| Stream | IAB state | Active IAB Document | |
| Consensus boilerplate | Unknown | ||
| IAB shepherd | (None) |
draft-iab-agews-report-00
Network Working Group M. Nottingham
Internet-Draft
Intended status: Informational M. Thomson
Expires: 13 July 2026 9 January 2026
Report from the IAB/W3C Workshop on Age-Based Restrictions on Content
Access
draft-iab-agews-report-00
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 its
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.
About This Document
This note is to be removed before publishing as an RFC.
The latest revision of this draft can be found at
https://intarchboard.github.io/draft-iab-agews-report/draft-iab-
agews-report.html. Status information for this document may be found
at https://datatracker.ietf.org/doc/draft-iab-agews-report/.
Source for this draft and an issue tracker can be found at
https://github.com/intarchboard/draft-iab-agews-report.
Status of This Memo
This Internet-Draft is submitted in full conformance with the
provisions of BCP 78 and BCP 79.
Internet-Drafts are working documents of the Internet Engineering
Task Force (IETF). Note that other groups may also distribute
working documents as Internet-Drafts. The list of current Internet-
Drafts is at https://datatracker.ietf.org/drafts/current/.
Nottingham & Thomson Expires 13 July 2026 [Page 1]
Internet-Draft AGEWS Report January 2026
Internet-Drafts are draft documents valid for a maximum of six months
and may be updated, replaced, or obsoleted by other documents at any
time. It is inappropriate to use Internet-Drafts as reference
material or to cite them other than as "work in progress."
This Internet-Draft will expire on 13 July 2026.
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 . . . . . . . . . . . . . . . . . . . . . . . . 3
1.1. Views Expressed in this Report . . . . . . . . . . . . . 3
1.2. Chatham House Rule . . . . . . . . . . . . . . . . . . . 4
2. Overview of the Workshop . . . . . . . . . . . . . . . . . . 4
3. Key Takeaways . . . . . . . . . . . . . . . . . . . . . . . . 6
3.1. There is a Need for Cross-Cutting Collaboration . . . . . 7
3.2. Identifying the Roles Involved is Important . . . . . . . 7
3.3. A Common Vocabulary is Necessary . . . . . . . . . . . . 8
3.4. Privacy and Trust Expectations Need Further Discussion . 9
3.5. More than One Approach will be Required . . . . . . . . . 10
3.6. Mapping the Risks for Architectures is a Useful Next
Step . . . . . . . . . . . . . . . . . . . . . . . . . . 11
3.7. Safety Requires More than a Technical Solution . . . . . 12
4. Security Considerations . . . . . . . . . . . . . . . . . . . 13
5. IANA Considerations . . . . . . . . . . . . . . . . . . . . . 13
6. Informative References . . . . . . . . . . . . . . . . . . . 13
Appendix A. Workshop Agenda . . . . . . . . . . . . . . . . . . 14
A.1. Topic: Introduction . . . . . . . . . . . . . . . . . . . 14
A.2. Topic: Setting the Scene . . . . . . . . . . . . . . . . 14
A.3. Topic: Guiding Principles . . . . . . . . . . . . . . . . 14
A.4. Topic: Potential Impacts . . . . . . . . . . . . . . . . 15
A.5. Topic: Where Enforcement Happens . . . . . . . . . . . . 15
A.6. Topic: Available Techniques . . . . . . . . . . . . . . . 15
A.7. Discussion . . . . . . . . . . . . . . . . . . . . . . . 16
A.8. Summary and Reflection . . . . . . . . . . . . . . . . . 16
A.9. Outcomes . . . . . . . . . . . . . . . . . . . . . . . . 16
Appendix B. Workshop Attendees . . . . . . . . . . . . . . . . . 16
Appendix C. Potential Impacts . . . . . . . . . . . . . . . . . 18
Nottingham & Thomson Expires 13 July 2026 [Page 2]
Internet-Draft AGEWS Report January 2026
C.1. Impact on Children . . . . . . . . . . . . . . . . . . . 18
C.2. Ecosystem Impact . . . . . . . . . . . . . . . . . . . . 18
C.3. Implementation and Deployment Difficulties . . . . . . . 19
C.4. Security and Privacy . . . . . . . . . . . . . . . . . . 19
C.5. Equity . . . . . . . . . . . . . . . . . . . . . . . . . 19
C.6. Societal Impacts . . . . . . . . . . . . . . . . . . . . 20
Appendix D. Desirable and Essential Properties of a Solution . . 20
D.1. Functional . . . . . . . . . . . . . . . . . . . . . . . 20
D.2. Accountability and Transparency . . . . . . . . . . . . . 21
D.3. Privacy and Security . . . . . . . . . . . . . . . . . . 21
D.4. Equity . . . . . . . . . . . . . . . . . . . . . . . . . 21
D.5. Jurisdiction and Geopolitical . . . . . . . . . . . . . . 22
D.6. Usability . . . . . . . . . . . . . . . . . . . . . . . . 22
D.7. Implementation and Deployment . . . . . . . . . . . . . . 23
D.8. General / Other . . . . . . . . . . . . . . . . . . . . . 23
Authors' Addresses . . . . . . . . . . . . . . . . . . . . . . . 23
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 online harms that they
encounter.
In October 2025, the Internet Architecture Board and the World Wide
Web Consortium convened the Workshop on Age-Based Restrictions on
Content Access. It 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. This report
summarises 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 IAB's
or W3C's views and positions, nor those of all participants.
Nottingham & Thomson Expires 13 July 2026 [Page 3]
Internet-Draft AGEWS Report January 2026
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 natively 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
Nottingham & Thomson Expires 13 July 2026 [Page 4]
Internet-Draft AGEWS Report January 2026
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 as protection from
unwanted exposure or interaction. Freedom of expression and opinion
was considered, particularly how adults and children both 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, while 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-enforced
systems place the 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-enforced models, 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 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, are relatively untested, and 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.
Nottingham & Thomson Expires 13 July 2026 [Page 5]
Internet-Draft AGEWS Report January 2026
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 over-broad 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 this workshop would not provide specific standards proposals or
take positions on the advisability of regulatory proposals, it was
suggested that leadership bodies, including the Internet Architecture
Board and Technical Architecture Group, could be places to make such
statements.
While the current status quo -- 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.
Nottingham & Thomson Expires 13 July 2026 [Page 6]
Internet-Draft AGEWS Report January 2026
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 tech companies. This can lead to an
underappreciation of the architectural impact and related harms 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 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 harms. 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
Nottingham & Thomson Expires 13 July 2026 [Page 7]
Internet-Draft AGEWS Report January 2026
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 circumvention 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], which establishes key
terms, including:
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 these 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 external data sources to
Nottingham & Thomson Expires 13 July 2026 [Page 8]
Internet-Draft AGEWS Report January 2026
determine whether a person fits a given age range. This method
requires 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, where 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 privacy.
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 instead 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
Nottingham & Thomson Expires 13 July 2026 [Page 9]
Internet-Draft AGEWS Report January 2026
achievable, the use of zero-knowledge proofs or similar cryptographic
techniques was seen as a way to limit what each entity learns. Some
participants noted, however, 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, but not those that are 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 heritage is often significantly
Nottingham & Thomson Expires 13 July 2026 [Page 10]
Internet-Draft AGEWS Report January 2026
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 cuts in both
directions:
* 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. However, it was clear that 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 tended to fall into a common basic pattern. Several
participants noted that this is a somewhat natural consequence of
some of the constraints that actors are subject to.
Nottingham & Thomson Expires 13 July 2026 [Page 11]
Internet-Draft AGEWS Report January 2026
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.
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 the community.
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 both 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 role of parents, guardians, educators, governments,
and online services in creating an environment in which children can
thrive and grow.
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.
Nottingham & Thomson Expires 13 July 2026 [Page 12]
Internet-Draft AGEWS Report January 2026
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)",
<https://nvlpubs.nist.gov/nistpubs/ir/2023/
NIST.IR.8491.pdf>.
Nottingham & Thomson Expires 13 July 2026 [Page 13]
Internet-Draft AGEWS Report January 2026
[HANSON] Hanson, J., "Where Enforcement Happens",
<https://datatracker.ietf.org/doc/slides-agews-slides-
where-enforcement-happens/>.
[ISO-IEC-27566-1]
ISO, "Information security, cybersecurity and privacy
protection — Age assurance systems Part 1: Framework",
<https://www.iso.org/standard/88143.html>.
[JACKSON] Jackson, D., "Where Enforcement Happens",
<https://datatracker.ietf.org/doc/slides-agews-where-
enforcement-happens/>.
Appendix A. Workshop Agenda
The following sections cover each of the main topics of discussion
sessions.
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
Nottingham & Thomson Expires 13 July 2026 [Page 14]
Internet-Draft AGEWS Report January 2026
* 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 / ZKP
* Age estimation: including biometrics and data analysis
* Age "inference" approaches
* In-network solutions
* Classification and On-device / parental control designs
Nottingham & Thomson Expires 13 July 2026 [Page 15]
Internet-Draft AGEWS Report January 2026
A.7. Discussion
We will follow up on incomplete discussions and revisit architectural
learnings.
A.8. Summary and Reflection
We will summarise 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 Attendees
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
* Sofıa 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, Ecole Polytechnique
* Alexis Hancock, Electronic Freedom Foundation
Nottingham & Thomson Expires 13 July 2026 [Page 16]
Internet-Draft AGEWS Report January 2026
* 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)
Nottingham & Thomson Expires 13 July 2026 [Page 17]
Internet-Draft AGEWS Report January 2026
* 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 an age control mechanism. This
list is not exhaustive, focuses largely on the challenges surrounding
the introduction of such a mechanism, and does not imply that all
points were agreed to by all participants'
C.1. Impact on Children
1. Children encounter online harms
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 Web site
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
Nottingham & Thomson Expires 13 July 2026 [Page 18]
Internet-Draft AGEWS Report January 2026
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
Nottingham & Thomson Expires 13 July 2026 [Page 19]
Internet-Draft AGEWS Report January 2026
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 recognised 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
Nottingham & Thomson Expires 13 July 2026 [Page 20]
Internet-Draft AGEWS Report January 2026
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. Minimises the need for trust decisions
3. Can be independently / publicly verifiable and tested
4. Auditability
5. Appeal mechanism for incorrect labelling 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 minimises bias
3. Does not create inequalities (e.g., across education, other
properties)
Nottingham & Thomson Expires 13 July 2026 [Page 21]
Internet-Draft AGEWS Report January 2026
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
Nottingham & Thomson Expires 13 July 2026 [Page 22]
Internet-Draft AGEWS Report January 2026
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
Authors' Addresses
Mark Nottingham
Email: mnot@mnot.net
Martin Thomson
Email: mt@lowentropy.net
Nottingham & Thomson Expires 13 July 2026 [Page 23]