Back in August 2023, the U.S. General Services Administration published a blog post that included the following statement:
Login.gov is on a path to providing an IAL2-compliant identity verification service to its customers in a responsible, equitable way. Building on the strong evidence-based identity verification that Login.gov already offers, Login.gov is on a path to providing IAL2-compliant identity verification that ensures both strong security and broad and equitable access.
From https://www.gsa.gov/blog/2023/08/18/reducing-fraud-and-increasing-access-drives-record-adoption-and-usage-of-logingov
It’s nice to know…NOW…that Login.gov is working to achieve IAL2.
This post explains what the August 2023 GSA post said, and what it didn’t say.
But first, I’ll define what Login.gov and “IAL2” are.
What is Login.gov?
Here is what Login.gov says about itself:
Login.gov is a secure sign in service used by the public to sign in to participating government agencies. Participating agencies will ask you to create a Login.gov account to securely access your information on their website or application.
You can use the same username and password to access any agency that partners with Login.gov. This streamlines your process and eliminates the need to remember multiple usernames and passwords.
From https://www.login.gov/what-is-login/
Obviously there are a number of private companies (over 80 last I counted) that provide secure access to information, but Login.gov is provided by the government itself—specifically by the General Services Administration’s Technology Transformation Services. Agencies at the federal, state, and local level can work with the GSA TTS’ “18F” organization to implement solutions such as Login.gov.
Why would agencies implement Login.gov? Because the agencies want to protect their constituents’ information. If fraudsters capture personally identifiable information (PII) of someone applying for government services, the breached government agency will face severe repurcussions. Login.gov is supposed to protect its partner agencies from these nightmares.
How does Login.gov do this?
- Sometimes you might use two-factor authentication consisting of a password and a second factor such as an SMS code or the use of an authentication app.
- In more critical cases, Login.gov requests a more reliable method of identification, such as a government-issued photo ID (driver’s license, passport, etc.).
What is IAL2?
At the risk of repeating myself, I’ll briefly go over what “Identity Assurance Level 2” (IAL2) is.
The U.S. National Institute of Standards and Technology, in its publication NIST SP 800-63a, has defined “identity assurance levels” (IALs) that can be used when dealing with digital identities. It’s helpful to review how NIST has defined the IALs. (I’ll define the other acronyms as we go along.)
Assurance in a subscriber’s identity is described using one of three IALs:
IAL1: There is no requirement to link the applicant to a specific real-life identity. Any attributes provided in conjunction with the subject’s activities are self-asserted or should be treated as self-asserted (including attributes a [Credential Service Provider] CSP asserts to an [Relying Party] RP). Self-asserted attributes are neither validated nor verified.
IAL2: Evidence supports the real-world existence of the claimed identity and verifies that the applicant is appropriately associated with this real-world identity. IAL2 introduces the need for either remote or physically-present identity proofing. Attributes could be asserted by CSPs to RPs in support of pseudonymous identity with verified attributes. A CSP that supports IAL2 can support IAL1 transactions if the user consents.
IAL3: Physical presence is required for identity proofing. Identifying attributes must be verified by an authorized and trained CSP representative. As with IAL2, attributes could be asserted by CSPs to RPs in support of pseudonymous identity with verified attributes. A CSP that supports IAL3 can support IAL1 and IAL2 identity attributes if the user consents.
From https://pages.nist.gov/800-63-3/sp800-63a.html#sec2
So in its simplest terms, IAL2 requires evidence of a verified credential so that an online person can be linked to a real-life identity. If someone says they’re “John Bredehoft” and fills in an online application to receive government services, IAL2 compliance helps to ensure that the person filling out the online application truly IS John Bredehoft, and not Bernie Madoff.
As more and more of us conduct business—including government business—online, IAL2 compliance is essential to reduce fraud.
One more thing about IAL2 compliance. The mere possession of a valid government issued photo ID is NOT sufficient for IAL2 compliance. After all, Bernie Madoff may be using John Bredehoft’s driver’s license. To make sure that it’s John Bredehoft using John Bredehoft’s driver’s license, an additional check is needed.
This has been explained by ID.me, a private company that happens to compete with Login.gov to provide identity proofing services to government agencies.
Biometric comparison (e.g., selfie with liveness detection or fingerprint) of the strongest piece of evidence to the applicant
From https://network.id.me/article/what-is-nist-ial2-identity-verification/
So you basically take the information on a driver’s license and perform a facial recognition 1:1 comparison with the person possessing the driver’s license, ideally using liveness detection, to make sure that the presented person is not a fake.
So what?
So the GSA was apparently claiming how secure Login.gov was. Guess who challenged the claim?
The GSA.
Now sometimes it’s ludicrous to think that the government can police itself, but in some cases government actually identifies government faults.
Of course, this works best when you can identify problems with some other government entity.
Which is why the General Services Administration has an Inspector General. And in March 2023, the GSA Inspector General released a report with the following title: “GSA Misled Customers on Login.gov’s Compliance with Digital Identity Standards.”
The title is pretty clear, but Fedscoop summarized the findings for those who missed the obvious:
As part of an investigation that has run since last April (2022), GSA’s Office of the Inspector General found that the agency was billing agencies for IAL2-compliant services, even though Login.gov did not meet Identity Assurance Level 2 (IAL2) standards.
GSA knowingly billed over $10 million for services provided through contracts with other federal agencies, even though Login.gov is not IAL2 compliant, according to the watchdog.
From https://fedscoop.com/gsa-login-gov-watchdog-report/
So now GSA is explicitly saying that Login.gov ISN’T IAL2-compliant.
Which helps its private sector competitors.
Bredemarket 