Sunday, 1 March 2026

Re: On the unfortunate need for an "age verification" API for legal compliance reasons in some U.S. states

On 2026/03/01 14:48 PM, Aaron Rainbolt wrote:
> Given that this is related to legal stuff, I should preface this by
> saying I am not a lawyer.
>
> Recently, a new law was passed in California that requires OS vendors
> to provide some limited info about a user's age via an API that
> application distribution websites and application stores can use. [1]
> Colorado seems to be working on a similar law. [2] The law will go into
> effect January 1, 2027, it is no longer a draft. I do quite a bit of
> work with an OS vendor (working with the Kicksecure [3] and Whonix [4]
> projects), and we aren't particularly interested in blocking everyone
> in California and Colorado from using our OSes, so we're currently
> looking into how to implement an API that will comply with the laws
> while also not being a privacy disaster. Given that other distributions
> are also investigating what to do with this, and the law requires us to
> make a "good faith effort to comply with [the] title, taking into
> consideration available technology", I figured it would be a good idea
> to bring the issue here.
>
> At its core, the law seems to require that an "operating system"
> (I'm guessing this would correspond to a Linux distribution, not an OS
> kernel or userland) request the user's age or date of birth at "account
> setup". The OS is also expected to allow users to set the user's age if
> they didn't already provide it (because the OS was installed before the
> law went into effect), and it needs to provide an API somewhere so that
> app stores and application distribution websites can ask the OS "what
> age bracket does this user fall into?" Four age brackets are defined,
> "< 13", ">= 13 and < 16", ">= 16 and < 18", and ">= 18". It looks like
> the API also needs to not provide more information than just the age
> bracket data. A bunch of stuff is left unclear (how to handle servers
> and other CLI-only installs, how to handle VMs, whether the law is even
> applicable if the primary user is over 18 since the law ridiculously
> defines a user as "a child" while also defining "a child" as anyone
> under the age of 18, etc.), but that's what we're given to deal with.
>
> The most intuitive place to put this functionality would be, IMO,
> AccountsService. The main issue with that is that stable-release
> distributions, and distributions based upon them, would be faced with
> the issue of how to get an updated version of AccountsService integrated
> into their software repositories, or how to backport the appropriate
> code. The law goes into effect on January 1, 2027, Debian Bookworm is
> going to be supported by ELTS until July 30, 2033, and we don't yet
> know if Debian will care enough about California's laws to want to
> backport a new feature in AccountsService into Debian Bookworm (or even
> Trixie). Distributions based on Debian (such as Kicksecure and Whonix)
> may still want to comply with the law though, so something using
> AccountsService-specific APIs would be frustrating. Requiring a whole
> separate daemon for the foreseeable future just for an age verification
> API would also be annoying.
>
> Another place the functionality could go is xdg-desktop-portal. This
> one is a bit non-ideal for a couple of reasons; for one, the easiest
> place to put the call would be in the Account portal, which returns
> more information than the account's age bracket. This could potentially
> be considered non-compliant with the law, as it states that the
> operating system shall "[s]end only the minimum amount of information
> necessary to comply with this title". This also comes with the
> backporting disadvantages of an AccountsService-based implementation.
>
> For this reason, I'd like to propose a "hybrid" approach; introduce a
> new standard D-Bus interface, `org.freedesktop.AgeVerification1`, that
> can be implemented by arbitrary applications as a distro sees fit.
> AccountsService could implement this API so that newer versions
> of distros will get the relevant features for free, while distros with
> an AccountsService too old to contain the feature can implement it
> themselves as a stop-gap solution.
>
> Taking inspiration from the File Manager D-Bus interface [5], I think
> something like the following might work:
>
> <!DOCTYPE node PUBLIC "-//freedesktop//DTD D-BUS Object Introspection 1.0//EN"
> "http://www.freedesktop.org/standards/dbus/1.0/introspect.dtd">
> <node name="/org/freedesktop/AgeVerification1">
> <interface name="org.freedesktop.AgeVerification1">
> <method name="SetAge">
> <arg type="s" name="User" direction="in"/>
> <arg type="u" name="YearsOfAge" direction="in"/>
> </method>
> <method name="SetDateOfBirth">
> <arg type="s" name="User" direction="in"/>
> <arg type="s" name="Date" direction="in"/>
> </method>
> <method name='GetAgeBracket'>
> <arg type="s" name="User" direction="in"/>
> <arg type="u" name="AgeBracket" direction="out"/>
> </method>
> </interface>
> </node>
>
> * The 'User' argument would, in all instances, be expected to be the
> UNIX account username of the user in question. This user account must
> not be a system account (i.e. its UID must fall between UID_MIN and
> UID_MAX as defined by /etc/login.defs). If a user is specified that
> does not exist or whose UID is out of range, these methods will
> return the error 'org.freedesktop.AgeVerification1.Error.NoSuchUser'.
> If the specified user is not the same as the user making the method
> call, and the user making the method call is not root, these methods
> will return the error
> 'org.freedesktop.AgeVerification1.Error.PermissionDenied'.
> * The 'YearsOfAge' argument of the 'SetAge' method should be an
> unsigned integer specifying the age of the user in years at the time
> of the method call. (The law specifically allows providing simply an
> age value rather than a birth date if desired.)
> * The 'Date' argument of the 'SetDateOfBirth' method should be a string
> in ISO8601 format (i.e. YYYY-MM-DD) indicating the day on which the
> user was born. If the argument is invalid, the method will return the
> error 'org.freedesktop.AgeVerification1.Error.InvalidDate'.
> * The 'AgeBracket' output argument of the 'GetAgeBracket' method will be
> an unsigned integer between 1 and 4 inclusive, where 1 indicates that
> the user is under 13 years old, 2 indicates that the user is at least
> 13 and under 16 years old, 3 indicates that the user is at least 16
> and under 18 years old, and 4 indicates that the user is 18 years old
> or older. If no age has been configured for the user yet, the method
> will return the error
> 'org.freedesktop.AgeVerification1.Error.AgeUndefined'.
>
> I propose that the exact way in which age information is stored by the
> daemon should be left implementation-defined. For Kicksecure, the way
> we implement it will almost certainly store only the age bracket and
> require users to explicitly reconfigure their age once they are old
> enough to move from one age bracket to another. Other implementations
> may choose to store the date of birth or the age and date on which the
> age was set so that they can automatically update the age bracket as
> time passes. This interface will be provided *on the system bus* (NOT
> the session bus!), and the D-Bus service that provides these services
> should run as root. The file containing the user-to-age mappings should
> be owned by root and should not be world-readable, to prevent leaking
> the user's specific age to malicious applications.
>
> Some things I did think about when writing the above but ultimately
> decided to not propose:
>
> * Detailed permission gating for the 'GetAgeBracket' method. The only
> reason to do this would be for additional privacy, and
> privacy-conscious users can simply lie about their age or the age of
> the intended user. There isn't anything in the law (that I can tell)
> that prevents the user from just saying "I'm 18" when the prompt
> appears and going with it. This would also be really difficult to
> implement outside of the context of xdg-desktop-portal, and would
> probably only work with sandboxed apps if it was implemented that way.
> * UX for actually requesting the age from the user. IMO this is out of
> scope for FreeDesktop; individual distros should see to it that they
> prompt for the user's age or birth date at "account setup" (whatever
> that happens to be defined as for the distro in question), nudge the
> user to provide the information later on for existing installations,
> etc. Furthermore, this mechanism needs to work even on CLI-only
> installs and maybe even on server installs, depending on how one
> defines "general purpose computing device" (as specified by the law
> in question), so defining any specific UX is likely infeasible. (If
> this is required on servers, end-users will probably want to
> auto-provision the age information somehow, and specifying how to do
> that in a distribution-agnostic way is impossible given that Ubuntu
> uses cloud-init, Fedora uses Kickstart and Ignition, etc.)
> * Omitting the 'SetDateOfBirth' method. It can be lived without
> legally, but without the method, it becomes difficult for software
> that already records the user's date of birth to accurately implement
> automatic age bracket adjustment as time passes. This isn't a feature
> Kicksecure would use, but it's a feature some projects might be
> interested in.
>
> Thanks for taking a look at this.
>
> --
> Aaron
>
> [1] https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202520260AB1043
> [2] https://leg.colorado.gov/bill_files/110990/download
> [3] https://www.kicksecure.com/
> [4] https://www.whonix.org/
> [5] https://www.freedesktop.org/wiki/Specifications/file-manager-interface/

By definition, not a Debian or Ubuntu problem:
https://www.merriam-webster.com/dictionary/vendor

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