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For anyone pursuing this, consider that the EU age verification apps are the EU’s first foray into digital anti-cheat systems at population scale. If you take the time to research how those are being designed and implemented and incorporate awareness of their work into your complaint about anti-cheats in gaming, your missive will be a lot more likely to strike the target and be taken seriously.

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The age verification is it's own can of worms. I'm currently waiting for my native country (but not the one where I reside) to actually publish their wallet implementation. I'm planning to make complaint around it because the whole thing almost certainly breaches ePD. ePD's exceptions are actually for "information society service" rather than just any service. The ISS itself has it's own sets of requirements, but the important one here is that "normally provided for remuneration". Service provided by government as part of their public duty almost never fulfills that requirement.

So in order to store or read data they would need consent. But consent requirements come from GDPR and it's unlikely that this type of consent would be "freely given" given the impact of refusal.

From a technical standpoint, there’s no functional difference: without secure boot and OS attestation, age verification is as ineffective as EAC on Linux, because you can simply `insmod GameGenie.ko code=A456-GH4C` to have your mobile device simulator kernel patch success into any challenge. At the surface level they’re different — one is PvP, the other is PvG, one uses webcams for Twitch, the other uses webcams for facial recognition — but the same set of kernel defenses enable both.

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