Input data and information sources
The person supplies the ID and camera image; they may be impersonating someone else. The system processes the person's facial image, name and identity document data.
Also known as: Biometric verification and remote identity proofing
The system checks whether a person is who they claim to be, for example by comparing a live image with their ID photograph.
Understand the use case
The person shows their ID and face to the camera. The system compares the images and checks that a real person is present, rather than a photograph, mask or replayed video. Border controls and government portals use this approach; Germany's BSI publishes a technical guideline for video identification.
This page describes a typical system design. Actual data flows and permissions depend on your implementation.
System design and data flows
The person presents or photographs their ID and shows their face to the camera.
The person supplies the ID and camera image; they may be impersonating someone else. In video identification, the system checks live images, ID photographs and often audio together.
The system checks that a live person is present and compares their face with the ID photograph.
The system compares a captured biometric characteristic with the reference for a claimed identity. Unlike searching an entire population database, this verifies a single identity claim. Liveness detection may be an additional check, where it is integrated.
The system reports whether the images show the same person, usually with a match score.
The result describes the defined model task. A match, category or forecast acquires its professional significance only in conjunction with the underlying data and intended use.
A match opens the barrier, creates the account or enables login; otherwise, a person investigates further.
Integration determines whether the result is simply displayed, adopted after approval or written directly into a business application. These variants differ in their data flows and permissions.
Explore the system design: Select a component to see its task, incoming and outgoing data, and role in the use case. The guided walkthrough explains each phase. Then use Yes, Uncertain and No to represent your specific system variant.
13 review first4 clarify7 baseline threats
The diagram shows the typical architecture. Select a component to see what happens there and adapt its features to your system. Enable “Analysis guidance” to see which threats need reviewing for this architecture. The page's checklist continues to describe the typical case.
None yet. Each change will appear here.
In this system design: 13 to review first, 4 to clarify, 7 baseline threats.
External access: Present
Review first
Input: Part of every AI system
Review first
Third-party content: Present
AI model: Part of every AI system
Baseline for every AI system
Provider service: Present
Review first
To clarify
Training and feedback: Present
Review first
To clarify
Result: Part of every AI system
Review first
Business application or equipment: Depends on your system
To clarify
person: Part of every AI system
Baseline for every AI system
Affected person: Present
Unapproved AI services: Depends on your system
To clarify
Supply chain and technical foundations: 5 baseline threats applying to every AI system
Baseline for every AI system
Remote biometric identification (facial recognition)
Searches for an unknown person among many stored faces without their active participation
The person supplies the ID and camera image; they may be impersonating someone else. The system processes the person's facial image, name and identity document data.
Deployers generally purchase face matching and liveness detection from specialist providers, such as iProov for GOV.UK One Login.
Logging, retention periods and possible use for training must be established for the specific implementation.
Depending on the procedure, a positive result activates an account directly or requires human confirmation first. If checks run in a provider's cloud, facial images and ID data leave the organisation's environment.
Using a provider does not automatically determine where processing takes place. Storage location, subcontractors, deletion periods and use for training must be checked for the specific deployment.
Assess risks and determine measures
Record data, participants, interfaces and permissions. Resolve uncertain characteristics in the model.
Relate review candidates to actual data flows: what could happen, and who would be affected?
Assess impacts and likelihood in the deployment context. The number of review candidates is not a risk score.
Select appropriate controls, assign responsibilities and define effectiveness checks. Document residual risks and approvals.
A total of 24 threats from the threat catalogue may be relevant to this use case.
Also review: whether the system disadvantages groups
Check whether selection, ranking or assessment disadvantages people with protected characteristics, such as sex, age or origin.
An impersonator presents a photograph, mask or synthetic video to the camera. If it defeats liveness detection, the system opens an account or barrier for the wrong person.
Downstream processes treat the result as a verified identity. Accepting it without further checks means a single error can create an account or grant access under a false name.
Injecting a synthetic video directly into the camera stream bypasses liveness detection without anyone standing before the camera. The system then confirms an identity nobody has physically presented.
Targeted Poisoning / Label Poisoning
Falsified training labels can deliberately shift model outputs.
Listed because of this characteristic
Training data or an adopted base model can introduce hidden triggers for misbehaviour.
Listed because of this characteristic
Anyone able to query the model can replicate it through many queries. Internally trained weights can be stolen through network access.
Listed because of this characteristic
Complex or high-volume inputs can exhaust model computing resources.
Listed because of these characteristics
Paid or publicly triggered queries can be abused to consume computing resources and money.
Listed because of this characteristic
Targeted queries can recover some personal or protected training data from the model.
Listed because of these characteristics
Sensitive Information Disclosure
Confidential content can appear in answers, supplied context or logs.
Listed because of these characteristics
Exfiltration from ML Application
Protected data can leak through tools, network connections, storage or insiders.
Listed because of this characteristic
A network-accessible application can be overwhelmed by mass requests.
Listed because of this characteristic
Targeted queries can reveal the model's architecture and safeguards.
Listed because of this characteristic
Up to 4 further threats may apply, depending on your system design. Nine threats need to be reviewed for every AI system. Two of these are particularly important here and are therefore listed above.
Each Yes adds further threats to your checklist, up to 4 in total. If you cannot yet answer a question, include its threats in your review.
How your system is built
How you operate the system
Depending on the procedure, a positive result activates an account directly or requires human confirmation first.
If yes, add
At an automated border gate, a positive result opens the barrier.
If yes, add
If yes, add
If yes, add
These questions arise for almost every AI system.
If yes, add
If yes, add
Measures for the priority review areas are expanded. Each linked measure explains how to implement it.
Controls for the remaining threats are available on their pages in the threat catalogue.
For every AI system Applies since 2 February 2025.
Depending on use Review trigger from 2 December 2027.
Applies if staff or appointed representatives operate or use AI systems.
Applies since 2 February 2025.
Detailed obligations
Applies if border authorities use the system to recognise or identify people beyond checking travel documents.
Applies from 2 December 2027.
Detailed obligations
The system only confirms the identity claimed by an actively participating person. Annex III, point 1(a), expressly excludes this verification.
Detailed obligations
Classify your system with the quick checker All obligations in the obligations compass
Review these threats for every AI system, whatever its purpose.
If any of these features does apply to your system, add the listed threats.
Does the system generate its own text, such as answers, drafts or summaries?
The system returns “match” or “no match” with a score and does not generate text.
If yes, add
Does the system generate or edit images, sounds, voices or videos?
If yes, add
Does the system create new content from open-ended requests that people read, see or hear directly? Translation, reading aloud and transcription do not count.
If yes, add
Can users give the system natural language tasks that it then performs?
If yes, add
Does the system search its own collection of documents or records for relevant content?
The system compares two images of the same person and does not search a collection of faces.
If yes, add
Does the system formulate answers from retrieved documents?
If yes, add
Does the system use a knowledge graph storing concepts and their relationships?
If yes, add
Does the system remember content from earlier conversations or tasks and reuse it later?
If yes, add
Does the system call other programs, interfaces or search services itself, even if only to read?
If yes, add
Does the system determine its next steps itself based on earlier results?
If yes, add
Does the system delegate tasks to other AI agents or incorporate their results?
If yes, add
Is the system connected to tools or data sources through the Model Context Protocol (MCP)?
If yes, add
Do documents from several customers, departments or permission groups share one search store?
If yes, add
Does the system generate code, scripts or database queries for further use?
If yes, add
Does the system execute programs, scripts or commands itself?
If yes, add
Is the system intended to maximise a specified metric, such as revenue, utilisation or clicks?
If yes, add
Federal Police, Partially automated border control with EasyPASS According to the deployer
The Federal Police describes partially automated border checks in which travellers place their passport on a reader and look into a camera.
UK Algorithmic Transparency Record, GOV.UK One Login Liveness and Likeness Checks
The entry describes selfie matching with liveness detection for government login.
BSI, Technical Guideline TR-03147
The BSI guideline sets out how to verify people's identities remotely, for example through video identification.
EU AI Act, Annex III, point 1(a)
The Act excludes verification that merely confirms a claimed identity from remote biometric identification.
Updated: 30 September 2026. Review checklist rules version 0.3.2, threat catalogue version 2026.10.24.2. How these pages are structured