Identity Assurance Level 3 (IAL3): When Identity Assurance Level 2 (IAL2) Isn’t Good Enough

(Picture designed by Freepik.)

(Part of the biometric product marketing expert series)

I’ve talked about Identity Assurance Levels 1, 2, and 3 on several occasions. Most notably regarding Login.gov’s initial failure to adhere to Identity Assurance Level 2 (IAL2). (Old news; after the pilot, Login.gov is now certified for IAL2.)

But as usually happens, IAL2 is yesterday’s news. Because biometric tech always gets harder better faster stronger.

Refresher on IAL1, IAL2…and IAL 3

Let’s review the three identity assurance levels.

For our purposes, the big difference between IAL2 and IAL3 is that IAL2 allows “either remote or physically-present identity proofing,” while IAL3 requires “[p]hysical presence” for identity proofing. However, the proofing agent may “attend the identity proofing session via a CSP-controlled kiosk or device.” In other words, supervised enrollment.

When do you need IAL3? Mitek’s Adam Bacia clarifies:

“IAL3 is reserved for high-risk environments such as sensitive government services.”

How are solutions approved for a particular Identity Assurance Level?

Now I could get on my product marketing soapbox and loudly proclaim that my service is IAL2 compliant, or IAL3 compliant, or IAL4 compliant. (“What? You don’t know about IAL4? Obviously you’re not authorized to know about it.”)

But I doubt you would, um, trust my declaration.

Enter the Kantara Initiative, which manages an Identity Assurance Approval Process. For our purposes, we want to focus on the NIST 800-63 rev.3 class of approval:

“Available to Credential Service Providers offering Full or Component Credential Management Services. Modeled on best practice (drawing from, among other sources, ISO/IEC 27001, ISO/IEC 29115), this Class of Approval ensures the provider organization’s good standing and management / operational practices and assesses criteria which are derived strictly from NIST SP 800-63 rev.3 requirements, ensuring a conformant technical provision of the provider organization’s service.

“Assurance Levels: IAL2, IAL3; AAL2, AAL3; FAL2, FAL3”

  • You see that the Kantara Initiative doesn’t even offer an approval for IAL1, just for IAL2 and IAL3.
  • It also offers approvals for AAL2 and AAL3. I’ve previously discussed Authenticator Assurance Levels (AALs) in this post. Briefly, IALs focus on the initial identity proofing, while AALs focus on the authentication of a proven identity.
  • And you can also see that it offers approvals for FAL2 and FAL3. I’ve never discussed Federation Assurance Levels (FALs) before.

Component Services IAL2 approvals…and an IAL3 approval

Now if you go to the Kantara Initiative’s Trust Status List and focus on the Component Services, you’ll see a number of companies and their component services which are approved for NIST 800-63 rev.3 and offer an assurance level of IAL2.

With one exception.

“NextgenID Trusted Services Solution provides Supervised Remote Identity Proofing identity stations to collect, review, validate, proof, and package IAL-3 identity evidence and enrollment data for CSPs operating at IAL-3. The NextGenID TSS Identity Stations enable remote operators to remotely supervise NIST SP 800-63A compliant Supervised Remote Identity Proofing (SRIP) sessions for credentialing.”

So if remote identity assurance is not good enough for you, there’s a solution. I’ve already discussed NextgenID’s SUPERVISED remote identity proofing in this post. And there’s a video.

Trust Swiftly has also designed a remote IAL3 solution, but I couldn’t find Trust Swiftly on the Kantara Initiative’s Trust Status List. Perhaps it was processed under another accredited assessor.

But clearly biometric product marketers are paying attention to the identity assurance levels…at least the real ones (not IAL4). But are they communicating benefit-oriented messages to their prospects?

Biometric product marketing has to be targeted to the right people, with the right message. And the biometric product marketing expert at Bredemarket can help a company’s marketing organization create effective content. Talk to Bredemarket.

Login.gov May Not Be Pining for the Fjords

My question regarding Login.gov’s future may have been answered.

You will recall that the General Service Administration’s 18F organization was unceremoniously shut down over the weekend. Since 18F was the original developer of Login.gov, it was unclear whether the government’s identity service had also fallen victim to the chopping block.

Well, Anthony Kimery of Biometric Update provided a…well, update. According to Thomas Shedd, who heads the GSA’s Technology Transformation Services (the organization in which the former 18F resided), we have nothing to worry about:

“‘“I can assure you that Login.gov’s work carries forward as a critical part of government-wide efforts to promote efficiency and fight fraud,’ Shedd wrote in a Monday email. ‘To that end we are working to accelerate Login’s roadmap. More to come on that soon.’”

So that’s the story as of this week…

How Does Private Sector Firm X Handle Identity Verification?

As I mentioned earlier, I don’t know if Login.gov is affected by the abrupt shutdown of GSA’s 18F. Was 18F still maintaining Login.gov code, or had the Login.gov folks established their own code maintenance, independent of the now-deprecated 18F?

Perhaps we will find out Monday.

But what if 18F were still responsible for Login.gov, which therefore is nearly impossible to update or maintain? 

No, Mark Cuban, DOGE will not contract with the ex-18F workers. DOGE doesn’t need them. Look at what they’ve already done with verifying identities.

IDV via SMS

For example, at the private sector company X, you cannot get a paid X Premium subscription unless you have a confirmed phone number. Because everybody knows that confirming identities via an SMS text message is a foolproof method.

Well, maybe not.

“According to information provided by Google, the decision to move away from SMS verification stems from numerous security vulnerabilities associated with text message codes. These include susceptibility to phishing attacks, where users might inadvertently share codes with malicious actors, and dependence on phone carriers’ security practices, which can vary widely in effectiveness.”

IDV via doc plus selfie

Now I’m not being fair to X, because X offers an identity verification procedure using a government issued ID…as a voluntary (not mandatory) service. It uses known third party providers (Au10tix, Persona, and Stripe as of February 2025) for IDV.

“X will provide a voluntary ID verification option for certain X features to increase the overall integrity and trust on our platform. We collect this data when X Premium subscribers optionally choose to apply for an ID verified badge by verifying their identity using a government-issued ID. Once confirmed, a verified label is added to the user’s profile for transparency and potentially unlocking additional benefits associated with specific X features in the future.”

But the public sector needs IDV

Identity verification isn’t mandatory on X because some people plain do not want it. Not because they’re crooks, but because they don’t want to hand their PII over to anyone if they don’t have to.

Of course, the Internal Revenue Service, the Social Security Administration, and many other government agencies HAVE to implement identity verification from Login.gov, ID.me, or some other provider.

When a .gov Becomes an .org

When techies (the ones who developed Login.gov among other things) get fired from their government jobs, a website is sure to follow.

Here is how 18f.org begins:

“For over 11 years, 18F has been proudly serving you to make government technology work better. We are non-partisan civil servants. 18F has worked on hundreds of projects, all designed to make government technology not just efficient but effective, and to save money for American taxpayers.

“However, all employees at 18F – a group that the Trump Administration GSA Technology Transformation Services Director called “the gold standard” of civic tech – were terminated today at midnight ET.”

18F is Not a Female Who Can Vote (An Identity Verification Post)

If you are a government agency who uses Login.gov, or if you are a U.S. citizen who has a Login.gov account, I’m not sure about the future of the service.

Back in November 2023, I wrote a post that included the three letters “18F.” Specifically:

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.

Now perhaps I’m, um, biased, but I happen to think that identity verification, whether performed by a public entity, is kinda sorta important.

Which is why I took notice when I saw Brian Krebs’ Saturday night LinkedIn post. Here’s a short excerpt:

This is from the executive director of the 18F, the digital services agency within the General Services Administration (GSA) that develops open-source tools to improve digital services across the federal government.

“I am the Executive Director of 18F and 18F’s longest running employee- I have been at 18F for 10 years. You may not have heard of us, but last night proved that we are powerful. The way the administration ran to get rid of us under the cover of night and shut us down without warning proves that they were scared. They are too afraid to even speak to us.”

Krebs also links to a FedScoop article.

The General Services Administration has eliminated its 18F program, an internal team of tech consultants and engineers that develops open-source tools to improve digital services across the federal government. 

The announcement, which came overnight, is the latest in the Trump administration’s ongoing efforts to slash the federal workforce. It was foreshadowed weeks ago when Elon Musk, who’s become a highly influential and controversial voice in the White House, tweeted that the decade-old program had been “deleted.” 

At this point I am not sure how this affects future updates to Login.gov. As far as I know the service itself remains operational.

To be continued? Or not continued?

Take Me to the (Login.gov IAL2) Pilot

As further proof that I am celebrating, rather than hiding, my “seasoned” experience—and you know what the code word “seasoned” means—I am entitling this blog post “Take Me to the Pilot.”

Although I’m thinking about a different type of “pilot”—a pilot to establish that Login.gov can satisfy Identity Assurance Level 2 (IAL2).

A recap of Login.gov and IAL2-non compliance

I just mentioned IAL2 in a blog post on Wednesday, with this seemingly throwaway sentence.

So if you think you can use Login.gov to access a porn website, think again.

From https://bredemarket.com/2024/04/10/age-assurance-meets-identity-assurance-level-2/.

The link in that sentence directs the kind reader to a post I wrote in November 2023, detailing that fact that the GSA Inspector General criticized…the GSA…for implying that Login.gov was IAL2-compliant when it was not. The November post references a GSA-authored August blog post which reads in part (in bold):

Login.gov is on a path to providing an IAL2-compliant identity verification service to its customers in a responsible, equitable way.

From https://www.gsa.gov/blog/2023/08/18/reducing-fraud-and-increasing-access-drives-record-adoption-and-usage-of-logingov.

Because it obviously wouldn’t be good to do it in an irresponsible inequitable way.

But the GSA didn’t say how long that path would be. Would Login.gov be IAL2-compliant by the end of 2023? By mid 2024?

It turns out the answer is neither.

Eight months later we have…a pilot

You would think that achieving IAL2 compliance would be a top priority. After all, the longer that Login.gov doesn’t comply, the more government agencies that will flock to IAL2-compliant ID.me.

Enter Steve Craig of PEAK.IDV and the weekly news summaries that he posts on LinkedIn. Today’s summary includes the following item:

4/ GSA’s Login.gov Pilots Enhanced Identity Verification

Login.gov’s pilot will allow users to match a live selfie with the photo on a self-supplied form of photo ID, such as a driver’s license

Other interesting updates in the press release 👇

From https://www.linkedin.com/posts/stevenbcraig_digitalidentity-aml-compliance-activity-7184539504504930306-LVPF/.

And here’s what GSA’s April 11 press release says.

Specifically, over the next few months, Login.gov will:

Pilot facial matching technology consistent with the National Institute of Standards and Technology’s Digital Identity Guidelines (800-63-3) to achieve evidence-based remote identity verification at the IAL2 level….

Using proven facial matching technology, Login.gov’s pilot will allow users to match a live selfie with the photo on a self-supplied form of photo ID, such as a driver’s license. Login.gov will not allow these images to be used for any purpose other than verifying identity, an approach which reflects Login.gov’s longstanding commitment to ensuring the privacy of its users. This pilot is slated to start in May with a handful of existing agency-partners who have expressed interest, with the pilot expanding to additional partners over the summer. GSA will simultaneously seek an independent third party assessment (Kantara) of IAL2 compliance, which GSA expects will be completed later this year. 

From https://www.gsa.gov/about-us/newsroom/news-releases/general-services-administrations-logingov-pilot-04112024#.

In short, GSA’s April 11 press release about the Login.gov pilot says that it expects to complete IAL2 compliance later this year. So it’s going to take more than a year for the GSA to repair the gap that its Inspector General identified.

My seasoned response

Once I saw Steve’s update this morning, I felt it sufficiently important to share the news among Bredemarket’s various social channels.

With a picture.

B-side of Elton John “Your Song” single issued 1970.

For those of you who are not as “seasoned” as I am, the picture depicts the B-side of a 1970 vinyl 7″ single (not a compact disc) from Elton John, taken from the album that broke Elton in the United States. (Not literally; that would come a few years later.)

By the way, while the original orchestrated studio version is great, the November 1970 live version with just the Elton John – Dee Murray – Nigel Olsson trio is OUTSTANDING.

From https://www.youtube.com/watch?v=cC1ocO0pVgs.

Back to Bredemarket social media. If you go to my Instagram post on this topic, I was able to incorporate an audio snippet from “Take Me to the Pilot” (studio version) into the post. (You may have to go to the Instagram post to actually hear the audio.)

Not that the song has anything to do with identity verification using government ID documents paired with facial recognition. Or maybe it does; Elton John doesn’t know what the song means, and even lyricist Bernie Taupin doesn’t know what the song means.

So from now on I’m going to say that “Take Me to the Pilot” documents future efforts toward IAL2 compliance. Although frankly the lyrics sound like they describe a successful iris spoofing attempt.

Through a glass eye, your throne
Is the one danger zone

From https://genius.com/Elton-john-take-me-to-the-pilot-lyrics.

Postscript

For you young whippersnappers who don’t understand why the opening image mentioned “54 Years On,” this is a reference to another Elton John song.

And it’s no surprise that the live version is better.

From https://www.youtube.com/watch?v=rRngmF-AcFQ.

Now I’m going to listen to this all day. Cue the Instagram post (if Instagram has access to the 17-11-70/11-17-70 version).

Login.gov and IAL2 #realsoonnow

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.