On 11 April 2024, the French Audiovisual and Digital Communications Regulatory Authority (ARCOM) published a public consultation on the draft reference framework aimed at establishing minimum technical requirements for age verification systems designed to restrict minors' access to online pornographic content. In line with the ban imposed on 1 March 1994 under article 227-24 of the French Criminal Code, this ban aims to protect young people from the risks associated with early exposure to sensitive content. It has been reinforced over the years by various legislative and regulatory measures. The initiative of this reference framework therefore represents a further step in the regulatory effort, by ensuring that platforms distributing this type of content effectively comply with their obligations while using systems that respect users' privacy.

In summary, Adan strongly supports the privacy and confidentiality principles included in ARCOM's draft standards. The association actively promotes innovative Web 3 solutions that not only meet regulatory requirements but go beyond by minimising the collection and retention of personal data, in accordance with European Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, known as the "RGPD".

Adan welcomes the initiative taken by the French Audiovisual and Digital Communications Regulatory Authority to open this public consultation. It seems appropriate that the players deploying age verification solutions should be able to contribute their expertise to the discussions on the standards that will be defined for these systems. The association's objectives are to promote the existence of solutions that adequately meet the regulator's objectives, i.e. to protect minors while managing personal data in a strictly respectful manner.

Adan's response to the consultation can therefore be broken down into three main areas:

1. Recommends that the established repository should enable online sites to integrate cutting-edge Web 3 technology solutions such as Zero Knowledge Proofs (ZKP).

2. Support the opening up of the repository to other technical devices, provided that they offer similar or better guarantees than those offered by Web 3 solutions in terms of confidentiality and security, i.e. that they can guarantee the anonymity of users and the reliability of information transmitted, without disclosing superfluous and sensitive personal data.

3. Encourage clear guidelines on the quality and independence of auditors of technical solutions and the frequency of audits, ensuring that solutions are both compliant and economically viable for all stakeholders, including new technology companies. The association recommends that audits should not be excessively frequent or costly, to avoid penalising innovative small and medium-sized enterprises.