Trust, policy, and the road ahead for breeder document standardisation

Reliable technology is an essential element of trust – but not a sufficient one. Cryptographic standards are superseded, storage technologies become obsolete, and the institutions of today will not be those of fifty years from now. What gives a breeder document its long-term credibility is the integrity of the data it contains and the reliability of the process behind it. Policy and a trust framework must therefore address what technology alone cannot, ensuring confidence in the data and processes while mitigating the technical limitations that will inevitably arise over a document's lifetime. Part 5 of the TS 17489 series is CEN’s answer to this challenge.

Beyond the document

Parts 1 through 4 of the TS 17489 series deal with frameworks, data models, technologies, and document profiles. Part 5 – published in 2024 – takes a different perspective. Rather than specifying what a document must contain or how it must be secured, it addresses the conditions under which breeder documents can be trusted: the processes, institutions and governance structures that give a certificate its credibility.

This distinction matters because the vulnerabilities in breeder document systems are not purely technical. Even a perfectly secured birth certificate can serve as a vehicle for fraud if the registration process that produced it is weak, if the issuing authority is not held accountable, or if there is no means for a receiving administration in another country to assess the reliability of what it has been given. Part 5 sets out a framework for analysing and responding to these processes and institutional dimensions.

What a trust framework involves

The starting point for Part 5 is a principle borrowed directly from ICAO's Traveller Identification Programme: principle 1 of the TRIP Guide on Evidence of Identity states that "the identity is genuine." Two supporting objectives follow from this – that the identity exists and is not fictitious, and that it belongs to a living person. Simple as they sound, these objectives expose the full weight of what a trust framework for breeder documents must deliver.

Three hypotheses have guided the development of Part 5.

• Hypothesis 1: a secure credential is worth little if the underlying data is not reliable.

Every data field must be clearly defined, its source known and verifiable, and the process that produced it monitored and enforced.

• Hypothesis 2: informed trust stems from knowledge and shared values.

Civil registration varies widely and frequently lacks transparency across borders. Building confidence between administrations requires sufficient transparency, while respecting sovereignty and security so that a verifier can perform due diligence without subjecting the individual presenting the document to unnecessary scrutiny.

• Hypothesis 3: no single entity can impose specific regulations or standard operating procedures for civil registration on other administrations.

CEN's mandate does not extend to a normative dimension, and the working group remains highly attentive of respecting administrative sovereignty. The framework therefore provides a normative process for developing and reviewing systems, drawing inspiration from ISO 900x and 2700x management system standards. The guidance in Part 5 is advisory rather than mandatory; it does not mandate specific outcomes but provides a structured set of considerations for authorities working to establish trustworthy breeder document systems. Three objectives frame the work.

The first aims to create a common understanding of issues in nationally applied procedures that have international relevance, allowing different countries to address the same challenge with a shared vocabulary. The second is to place particular emphasis on identity fraud prevention, specifically the misuse of breeder documents to obtain national and international identity documents, a vulnerability already identified in the previous articles of this series. The third is to strengthen inter-agency confidence by providing transparent reporting on implementation progress, so that a receiving authority has a solid foundation for assessing the reliability of a document issued in another jurisdiction.

Taken together, these objectives describe something more ambitious than a technical specification alone can deliver. They describe a governance framework meant to evolve with both its practical application by member states and the insights gained from experience.

The policy dimension

Breeder documents sit at an intersection of several policy areas: civil registration, identity management, border control, data protection, and civil rights. Reforms in this space inevitably involve multiple ministries, legal systems, and administrative traditions. Part 5 of TS 17489 is designed to support rather than pre-empt national policy decisions, providing tools that governments can use as they see fit within their own constitutional and administrative frameworks. Competent bodies assessing the standard's objectives are free to adopt recommendations, choose their own implementation approach, or even depart from an objective entirely, provided the decision is recorded and internally justified. This flexibility is deliberate: the framework demands accountability and transparency, not uniformity.

Two tangible tools put transparency into practice. The first is the Declaration of Implementation – a detailed, selective account of how an authority has evaluated and acted upon the framework’s objectives, shared with specific partners on an individual basis. Conceptually, it resembles the ICAO Electronic Filing of Differences but adapted for civil registration.

Instead of submitting data to a central repository, an authority communicates its implementation status directly, much like sharing new specimen travel documents. The second instrument is a scorecard, which calculates a score across the framework's twelve key themes, indicating the degree of adoption of objectives and adherence to recommendations.

Together, these tools offer receiving administrations a clear and structured means to assess the reliability of breeder documents issued by a partner authority, without compromising the sovereignty of either system. The European Commission has been kept informed of the group's progress, as have national authorities responsible for breeder documents and the ICAO ICBWG. The intention is for the TS 17489 series to act as a reference point for the development of future policies at both European and international levels.

What this means for the identity industry

This series of standards gives identity industry professionals a clear framework of questions and opportunities. On the supply side, the specification of physical document security requirements, chip technologies and data models provides a roadmap for developing products and services adapted to the breeder document market. On the assurance side, the trust framework creates a demand for audit, certification, and inspection capabilities – areas where the industry already has significant expertise through existing certification schemes. In this context, the security management processes and certification frameworks developed by Intergraf are directly relevant: ISO 14298, governing the management of security printing processes, and Intergraf 15374, addressing the security of the supply chain and production of document elements, represent established recommended practices that align naturally with the assurance requirements embedded in TS 17489. Producers certified under these schemes are well positioned to demonstrate the process integrity and accountability that the breeder document framework demands.

Perhaps most importantly, the TS 17489 series reflect a broader recognition that the identity chain is only as strong as its weakest link. Having spent decades strengthening travel documents and border systems, the community now has both the opportunity and the tools to address the security gap at the very beginning of that chain.

The standardisation work continues. Those who wish to contribute can do so through their national standardisation body, or by reaching out to participating experts. Participation is open.

Author: Stephan D. Hofstetter, Editor of CEN prTS 17489-5 and Managing Partner of SECOIA Executive Consultants AG, updated for Noted. by Intergraf.

For feedback on the CEN TC224 WG19 breeder document standardisation project, please contact us (contact us with link: intergrafconference@intergraf.eu cc breederdoc@secoia.ltd)