CIPL’s Response to ANPD Consultation on the Draft Guidelines on “Age Verification Mechanisms”

CIPL’s response commends the ANPD for a thoughtful, evidence-informed, and risk-based draft. In particular, we welcome:

• the recognition that age verification “is not an end in itself” but rather one pillar of a broader protective ecosystem;
• the structuring of the framework around proportionality and a risk taxonomy;
• the clear preference for privacy-preserving methods, including verifiable credentials, age tokens, double-blind architectures, and zero-knowledge proofs; and
• the emphasis on interoperability and data minimisation.

These positions are aligned with CIPL’s extensive body of work on children’s data privacy and age assurance.

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