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
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   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



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