yoti – Bredemarket

Federal Trade Commission Age Verification (and estimation?) Workshop January 28

A dizzying array of federal government agencies is interested in biometric verification and biometric classification, for example by age (either age verification or age estimation). As Biometric Update announced, we can add the Federal Trade Commission (FTC) to the list with an upcoming age verification workshop.

Rejecting age estimation in 2024

The FTC has a history with this, having rejected a proposed age estimation scheme in 2024.

“Re: Request from Entertainment Software Rating Board, Yoti Ltd., Yoti (USA) Inc., and Kids Web Services Ltd. for Commission Approval of Children’s Online Privacy Protection Rule Parental Consent Method (FTC Matter No. P235402)

“This letter is to inform you that the Federal Trade Commission has reviewed your group’s (“the ESRB group”) application for approval of a proposed verifiable parental consent (“VPC”) method under the Children’s Online Privacy Protection Rule (“COPPA” or “the Rule”). At this time, the Commission declines to approve the method, without prejudice to your refiling the application in the future….

“The ESRB group submitted a proposed VPC method for approval on June 2, 2023. The method involves the use of “Privacy-Protective Facial Age Estimation” technology, which analyzes the geometry of a user’s face to confirm that the user is an adult….The Commission received 354 comments regarding the application. Commenters opposed to the application raised concerns about privacy protections, accuracy, and deepfakes. Those in support of the application wrote that the VPC method is similar to those approved previously and that it had sufficient privacy guardrails….

“The Commission is aware that Yoti submitted a facial age estimation model to the National Institute of Standards and Technology (“NIST”) in September 2023, and Yoti has stated that it anticipates that a report reflecting NIST’s evaluation of the model is forthcoming. The Commission expects that this report will materially assist the Commission, and the public, in better understanding age verification technologies and the ESRB group’s application.”

You can see the current NIST age estimation results on NIST’s “Face Analysis Technology Evaluation (FATE) Age Estimation & Verification” page, not only for Yoti, but for many other vendors including my former employers IDEMIA and Incode.

But the FTC rejection was in 2024. Things may be different now.

Revisiting age verification and age estimation in 2026?

The FTC has scheduled an in-person and online age verification workshop on January 28.

The in-person event will be at the Constitution Center at 400 7th St SW in Washington DC.
Details regarding online attendance will be published on this page in the coming weeks.

“The Age Verification Workshop will bring together a diverse group of stakeholders, including researchers, academics, industry representatives, consumer advocates, and government regulators, to discuss topics including: why age verification matters, age verification and estimation tools, navigating the regulatory contours of age verification, how to deploy age verification more widely, and interplay between age verification technologies and the Children’s Online Privacy Protection Act (COPPA Rule).”

Will the participants reconsider age estimation in light of recent test results?

Age Estimation is Challenging

(Part of the biometric product marketing expert series)

Two Biometric Update stories that were published on March 27, 2025 reminded me of something I wrote before.

One involved Paravision.

An announcement from Paravision says its biometric age estimation technology has achieved Level 3 certification from the Age Check Certification Scheme (ACCS), the leading independent certification body for age estimation. The results make it one of only six companies globally to receive ACCS’s highest-level designation for compliance.

San Francisco-based Paravision’s age estimation tech posted 100 percent precision in Challenge 25 compliance, with 0 subjects falsely identified as over 25 years old. It also scored a 0 percent Failure to Acquire Rate, meaning that every image submitted for analysis returned a result. Mean Absolute Error (MAE) was 1.37 years, with Standard Deviation of 1.17.

Now this is an impressive achievement, and Paravision is a quality company, and Joey Pritikin is a quality biometric executive, but…well, let me share the other story first, involving a Yoti customer (not Yoti).

Fenix responded that it set a challenge threshold at 23 years of age. Any user estimated to be that age or younger based on their face biometrics is required to use a secondary method for age verification.

Fenix had set OnlyFans challenge age, it turns out, at 20 years old. A correction to 23 years old was carried out on January 16, and then Fenix changed it again three days later, to 21 years old, Ofcom says.

Now Biometric Update was very clear that “Yoti provides the tech, but does not set the threshold.”

Challenge ages and legal ages

But do challenge thresholds have any meaning? I addressed that issue back in May 2024.

Many of the tests used a “Challenge-T” policy, such as “Challenge 25.” In other words, the test doesn’t estimate whether a person IS a particular age, but whether a person is WELL ABOVE a particular age….

So if you have to be 21 to access a good or service, the algorithm doesn’t estimate if you are over 21. Instead, it estimates whether you are over 25. If the algorithm thinks you’re over 25, you’re good to go. If it thinks you’re 24, pull out your ID card.

And if you want to be more accurate, raise the challenge age from 25 to 28.

NIST admits that this procedure results in a “tradeoff between protecting young people and inconveniencing older subjects” (where “older” is someone who is above the legal age but below the challenge age).

You may be asking why the algorithms have to set a challenge age above the lawful age, thus inconveniencing people above the lawful age but below the challenge age.

The reason is simple.

Age estimation is not all that accurate.

I mean, it’s accurate enough if I (a person well above the age of 21 years) must indicate whether I’m old enough to drink, but it’s not sufficiently accurate for a drinker on their 21st birthday (in the U.S.), or a 13 year old getting their first social media account (where lawful).

If you have a government issued ID, age verification based upon that ID is a much better (albeit less convenient) solution.

(Kid computer picture by Adrian Pingstone – Transferred from en.wikipedia, Public Domain, https://commons.wikimedia.org/w/index.php?curid=112727.)

(Fake driver license picture from https://www.etsy.com/listing/1511398513/editable-little-drivers-license.)