Binding an agent to a verified identity

As agents act for users across government services, a relying party has no way to confirm on its own that the user behind a delegation is who they are claimed to be. The difficulty is tying a delegation to an identity verified to a defined assurance level, rather than to a username an agent could present for anyone.

Login.gov (United States). The service offers three levels (authentication, basic identity verification, and enhanced identity verification) mapped to the NIST identity and authentication assurance levels, supports SAML and OIDC, and holds a FedRAMP Moderate authorization. It has added passport-based remote identity verification. It supports no delegation and no agent authorization.

The ATO's myID and RAM (Australia). The ATO operates Australia's digital identity system, proofing identity by biometric verification against government-held documents, and RAM records who may act for a business. It is representative-and-represented modeling running in production. It does not extend to an individual delegating to a software agent.

EU Digital Identity Wallet under eIDAS 2.0. Representation is operative in the instrument: Annex VI item 9 lists 'Powers and mandates to represent natural or legal persons' among the minimum attributes a qualified trust service provider must verify against an authentic source, and Article 3(5a) defines the user as including 'a natural person representing another natural person or a legal person'. Qualified Electronic Attestations of Attributes are the vehicle by which such an attestation carries legal effect. Representation is a named attribute class in the Regulation itself.

EUDI Architecture and Reference Framework 3.0.0, Topic 29. Annex 2's 'Representation paradigm' topic carries two SHALL requirements: a rulebook for representation attestations must specify 'attributes used for defining a validity period, the nature of the representation, and the operations the representative is authorised to perform', and those attestations must be short-lived or revocable. The binding is specified down to validity period and revocability.

The OOTS representation attributes. The Once-Only Technical System defines a PowerOfRepresentationScope attribute and pairs a representative attribute set with a represented-person set, so a cross-border request carries both identities and the scope joining them. The pairing is specified for that system, and the wallet architecture's own requirements for legal-person wallet units are still empty placeholders. A production cross-border channel already models the representative and the represented person as two linked attribute sets.

Of the three, the EU model is the only one whose representation is specified rather than absent: a representation attestation has its own type, and the rulebook governing it must bound the operations the representative may perform. The EU's representation-attestation shape could extend to agent delegation: the agent presents a credential attesting to the user's delegation, and the verifying agency can inspect both the agent's identity and the user's identity. But the specification itself stops at one natural person representing another.

Login.gov and myID currently lack delegation capabilities: they verify "who you are" but not "who you can act for." For agent delegation, the identity provider must verify the user's identity, bind the delegation grant to that verified identity, optionally verify the agent operator's identity, and issue a delegation credential or token that relying parties can verify. The EUDIW's QEAA model could accommodate this: a Qualified Trust Service Provider issues an attestation that "User X has authorized Agent Operator Y to perform actions Z until date W."