Sourcing Age-Verification: Vendor Evaluation Checklist for Platforms Facing New Child-Safety Law

Urgent procurement checklist for platforms racing to meet new child-safety laws

If your platform must verify user age at scale after Australia’s late‑2025 rollout, you can’t afford slow vendor selection or an incomplete security review. This guide gives engineering leaders, security teams and IT admins a production‑ready vendor evaluation checklist, a battle‑tested security questionnaire, and an integration playbook to evaluate, pilot and deploy age‑verification providers without compromising privacy, performance or compliance.

Executive summary — what you must decide in the next 30 days

Australia’s eSafety rollout (effective December 2025) forced social platforms to remove access to millions of under‑age accounts and put global regulators on alert. Platforms now face simultaneous constraints: legal timelines, user experience expectations, privacy rules and high throughput. Your procurement decision must balance four priorities:

• Compliance & privacy: minimal personal data collection, auditable DPIAs, cross‑border rules.
• Security & third‑party risk: rigorous vendor controls, pen tests, breach responsibilities.
• Scalability & performance: low latency, high throughput, graceful failure modes.
• Operational & legal SLAs: incident response, forensic support, notification timelines.

Australia’s eSafety Commissioner reported that platforms “removed access” to roughly 4.7 million accounts after the under‑16 ban took effect in December 2025 — a stark indication of enforcement pace and scale expectations. (reported in late 2025)

Quick decision checklist (one page)

• Require SOC 2 Type II or ISO 27001, recent pen test report and active bug bounty program.
• Insist on privacy‑preserving options (verifiable credentials, selective disclosure, tokenized attestations).
• Define SLA targets: 99.95% availability, median verification latency <300ms for fast paths, 95th percentile <800ms.
• Ask for vendor commitment to 24‑hour breach notification and forensic evidence sharing.
• Specify data retention: ephemeral proofs preferred, PII retention ≤30 days unless legally required.
• Validate integration patterns: server‑side API, edge SDK, and webhook security (HMAC signatures).
• Plan a 30/60/90 day PoC: functionality, load, privacy audit, and UX testing with appeals.

How to evaluate age verification vendors — scoring matrix

Use a weighted scoring matrix across five domains. Example weights (customize to your risk profile):

• Security & compliance — 30%
• Privacy & data minimization — 25%
• Integration & developer experience — 15%
• Scalability & performance — 20%
• Commercial, SLAs & legal terms — 10%

Score vendors 1–5 per criterion and require a minimum threshold in Security & Privacy before proceeding to PoC.

Key evaluation criteria (detailed)

• Assurance & audits: Current SOC 2 Type II and scope coverage, ISO 27701/27001. Ask for SOC report and request redacted evidence where necessary.
• Pen testing & vulnerability management: Frequency of tests, responsible disclosure program, CVE handling, remediation SLAs.
• Data handling & retention: What PII is stored? Can the vendor operate with hashed/ephemeral tokens? Is there an option for on‑device attestations or verifiable credentials?
• Privacy‑preserving options: Support for selective disclosure, decentralized identifiers (DIDs) and verifiable credentials (VCs), or cryptographic age attestations.
• Accuracy & fairness: False positive/negative rates, bias testing across demographics and device classes, appeals & manual review workflow.
• Operational SLA: Uptime, latency targets, disaster recovery, incident response time, and error budget definitions.
• Global compliance: GDPR, Australian privacy law, COPPA where applicable, and data localization constraints.
• Third‑party risk: Sub‑processor list, contractual audit rights, indemnities for breaches and regulatory fines.

Security questionnaire: 40 high‑value questions (with expected responses and red flags)

Below are condensed items to include in procurement RFIs and security questionnaires. For each question, require an answer plus evidence (reports, architecture diagrams, or logs).

Identity, access & secrets

• Do you use least privilege and role‑based access control for production systems? (Expect: yes; Red flag: broad admin access.)
• Is multi‑factor authentication enforced for all admin accounts? (Expect: enforced; Red flag: optional MFA.)
• How are encryption keys managed? (Expect: KMS/HSM with rotation policies; Red flag: key material in source or unprotected storage.)

Infrastructure & network security

• Hosting model and regions (cloud provider, shared tenancy vs private VPC). (Expect: private VPC, restricted egress; Red flag: unclear hosting.)
• Do you perform network segmentation and egress filtering? (Expect: yes; Red flag: flat network.)

Application security

• Provide latest SAST/DAST summary and remediation timelines. (Expect: continuous scanning, <30‑day fix SLA for critical.)
• Do you use content security policies and certificate pinning in SDKs? (Expect: mitigation measures for mobile SDKs.)

Data protection & privacy

• What minimum data is collected to verify age? Can you operate in a privacy‑preserving mode that returns a boolean or age bucket without PII? (Expect: privacy modes.)
• Retention policies for PII and audit logs. (Expect: short default retention, configurable.)
• How do you support data subject requests and right to erasure? (Expect: documented processes, SLAs.)

Forensics & incident response

• Incident response plan, tabletop cadence, and IR contact for clients. (Expect: 24/7 IR contacts, runbooks.)
• Will you provide forensic exports for incidents that implicate our users? (Expect: yes; Red flag: refusal.)

Third parties & supply chain

• List of sub‑processors and whether there are any subcontracted biometric providers. (Expect: full list and contracts.)
• Audit rights: Can we commission an independent review or review SOC reports? (Expect: yes.)

Operational resilience

• Real‑world throughput tested (TPS) and evidence of load testing under your largest customers. (Expect: test results.)
• RTO/RPO for verification service and database backups. (Expect: RTO ≤ 1 hour for core services.)

Red flags to stop shortlisting

• Refusal to provide redacted SOC 2/ISO certificates.
• No documented data retention or deletion process.
• Inability to deliver privacy‑preserving modes or operate without storing full PII.
• No documented appeals or manual review process for false positives.
• Unclear incident response and forensic support commitments.

Integration guide — patterns that work at scale

Architect your integration for low friction, observability and fallbacks. Choose one or more of the following verified patterns based on your product UX and compliance needs.

1) Non‑blocking, server‑side verification (recommended default)

Flow: client collects minimal user input → server creates verification request → server calls vendor API → vendor returns an age token (signed, opaque) → server enforces policy.

• Pros: Keeps PII off the client, simpler to log and audit.
• Implementation notes: Use mutual TLS to vendor API where supported. Validate vendor JWT signatures and expiry. Store only a hashed token and audit ID.

2) Edge / on‑device attestations (privacy‑preserving fast path)

Flow: device attests age/attestation from an identity provider (e.g., mobile attestation, eID, or verifiable credential) → device sends signed token to server → server validates token signature and issuer trust chain.

• Pros: Less PII leaving device, lower vendor processing cost per verification.
• Implementation notes: Support WebAuthn, Apple/Google attestation, and VCs. Validate key IDs, nonce, and audience. Ensure tokens are single‑use or short‑lived.

3) Asynchronous verification with progressive access

Flow: allow limited functionality while verification completes asynchronously; escalate or block on failure.

• Pros: Better UX for network slow clients; reduces peak latency and cost.
• Implementation notes: Design temporary grace tokens, set timeouts for completion (e.g., 24‑72 hours), and define fallback manual review procedures.

Common integration best practices

• Validate webhooks: require HMAC signatures, timestamp windows, and replay protection.
• Use exponential backoff and circuit breaker patterns on vendor APIs. Cache verification tokens when valid.
• Implement instrumentation: latency, error rates, success/fail ratios, and demographic breakdowns to monitor bias.
• Provide a surgeon’s toolset in admin UI for manual review and appeals with full audit trails.
• Use feature flags to roll out vendor verification selectively and perform canary tests at 1–5% of traffic.

Scaling considerations — architecture & cost control

Age verification will be high volume for large platforms. Design for cost and resiliency.

• Edge caching: Cache vetted age tokens at the CDN or application edge to reduce repeated verification calls.
• Batch verification: For onboarding flows where many accounts are created rapidly, use batched verification jobs with parallelism controls.
• Throttling & quotas: Implement rate limits and priority for critical verification paths to protect vendor APIs and avoid cascading failures.
• Autoscaling & capacity planning: Validate vendor’s SLO under traffic spikes (e.g., 5x baseline during campaigns). Require capacity guarantees in contract for predictable peak events.
• Cost model: Pay attention to per‑verification pricing vs subscription or throughput tiers. Calculate TCO using expected MAU and verification frequency.

Privacy & regulatory compliance checklist (2026 focus)

Regulators in 2025–2026 show two clear trends: they demand privacy‑preserving proofs and insist on auditable DPIAs. Your vendor must support both.

• Provide DPIA templates and support for joint controller/processor options.
• Offer privacy‑preserving verification (VCs, selective disclosure, ZK‑proofs) to avoid transferring full DOB or ID documents.
• Permit data localization where required; support region‑based data handling or on‑premise installations for regulated platforms.
• Clarify cross‑border transfer mechanisms: SCCs, adequacy decisions, or binding corporate rules.
• Document lawful bases (consent vs legitimate interest) and UX consent flows aligned to privacy laws.

SLAs, legal terms and breach obligations

Don’t accept vague commitments. Define precise SLAs and consequences.

• Availability: 99.95% for verification API; include error budgets and credits for downtime.
• Latency: median <300ms on fast path; 95th percentile <800–1000ms depending on verification complexity.
• Incident response: initial acknowledgement within 1 hour, remediation updates every 4 hours for critical incidents, full incident report within 10 business days.
• Data breach notification: notification to client within 24 hours of confirmation and forensic cooperation.
• Forensic assistance: vendor must preserve logs for a minimum period and provide exports in standard formats.
• Indemnity & liability: define caps, carve‑outs for negligence, and who bears regulatory fines arising from vendor actions.

Pilot & procurement timeline (30/60/90 day PoC template)

Run a structured PoC to validate technical fit, UX and compliance before rolling to production.

1. 0–30 days: Discovery & legal
   • Send security questionnaire; request SOC/ISO artifacts.
   • Sign NDA + Data Processing Addendum (DPA) with clear data scope.
   • Agree PoC success criteria: latency, throughput, false positive rate, privacy mode capability.
2. 30–60 days: Integration & tests
   • Integrate SDKs or server API in staging environment.
   • Run functional tests, webhook validation, and simulate user flows including appeals.
   • Perform small scale load test (1–2% of production traffic).
3. 60–90 days: Load & compliance validation
   • Perform stress tests to peak expectations; validate capacity commitments.
   • Complete privacy and DPIA review; conduct internal tabletop incident exercise with vendor.
   • Sign commercial contract with SLAs and audit rights if PoC passes.

Human review & appeals — operational essentials

Automated systems will produce false positives. You must include a robust appeals process.

• Design an appeals UI that preserves anonymity and allows document upload under secure handling.
• Ensure manual reviewers are trained, logged and rate‑limited to prevent abuse and privacy creep.
• Retain original verification evidence only as long as necessary and scoped by the DPA.

2026 trends & future predictions you should plan for

Watch these near‑term shifts and bake them into your vendor selection and contract language:

• Wider adoption of verifiable credentials and DIDs for age attestations — expect more vendors to support VC issuance and verification chains in 2026.
• Regulators will prioritize privacy‑preserving verification; solutions that require full ID uploads will face scrutiny and higher compliance overhead.
• Increased M&A in the age‑verification market — include change‑of‑control clauses and revalidation rights in contracts.
• More proactive enforcement from national regulators: Australia’s rollout shows speed; other jurisdictions will follow — prepare for cross‑border obligations.

Operationalizing vendor risk: internal checklist

• Assign an executive sponsor and a cross‑functional steering committee (Legal, Privacy, Security, Product).
• Maintain an approved vendor playbook with escalation paths and runbooks for vendor outages or data incidents.
• Schedule quarterly audits and biannual tabletop exercises with priority vendors.

Final takeaways — what to do now

Time is non‑negotiable. Start with a focused procurement sprint: issue an RFI using the security questionnaire above, shortlist two vendors for PoC, and require privacy‑preserving verification as a gating criterion. Ensure contracts include strict SLAs, rapid breach notifications and forensic cooperation clauses.

Actionable first steps (today):

• Send the condensed security questionnaire to 3–5 vendors and demand SOC/ISO evidence.
• Plan a 30‑day PoC window and reserve engineering time for integration and load testing.
• Prepare your DPIA and decide whether to accept third‑party attestations (VCs) or require vendor proofing.

Call to action

Download the full procurement checklist and vendor security questionnaire template to use in your RFI (includes machine‑readable scoring matrix and contract clause examples). If you need an expert vendor audit or a 30‑day technical PoC runbook customized to your platform, contact our incident‑response advisory team to schedule a consult.

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