Policy brief

Bill C-34 readiness: age assurance without ID

Bill C-34, the Safe Social Media Act, requires operators to implement “age-verification or age-estimation measures” for under-16 social media accounts (s. 27) and for access to pornographic content (s. 22). a-eye provides age estimation built to the bill’s own adequacy criteria.

Statutory criteria in ss. 22(2) and 27(2), mapped to a-eye’s design
C-34 adequacy criterion	a-eye design
Measures are effective	Live-camera estimation with built-in spoof and liveness protection.
Personal information is collected and used only for age purposes	No identity determination and no account linkage. The image is used solely to produce an age estimate.
Destruction once estimation is complete	Nothing is retained once the estimate is produced: no images, no video, no documents.
Information is protected until destroyed	Camera images are encrypted in transit and destroyed immediately after the estimate is produced.
No unreasonable limit on users’ expression	No ID requirement. Adults are never asked for government documents to speak online.

The 16 threshold, honestly

Age estimation is strongest well away from a threshold. Around 16, borderline results need conservative handling: challenge-age buffers, re-checks, or operator-chosen fallbacks. We say this plainly because C-34’s standards should be written around how the technology actually performs.

Also relevant to C-34

The same API covers content moderation, including the CSAM detection duties platforms carry under the Act. Rave will carry obligations under the Act too: we build what we must also use.

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