UK AADC Standard 3 — Age appropriate application: age estimation/verification methods (ICO Age Appropriate Design Code, statu…
Age verification methods must be proportionate, robust, and data-minimizing
Where this comes from
Provision: Standard 3 — Age appropriate application: age estimation/verification methods (ICO Age Appropriate Design Code, statutory guidance under DPA 2018 s 123)
Instrument: UK Age Appropriate Design Code
Citation: Data Protection Act 2018 s 123/s 127; ICO Age Appropriate Design Code, Standard 3 — Age appropriate application, 'Methods' guidance subsection
Text version: ICO Age Appropriate Design Code (statutory code of practice under Data Protection Act 2018 s 123; in force from 2 September 2020 with a transition period to 2 September 2021 - date not independently verified on the ICO pages), fifteen standards as displayed on ico.org.uk on 2026-09-23. The Data (Use and Access) Act 2025 has amended UK GDPR and the ICO has signalled a revised code: check for a reissued code before relying on this text.
Who it applies to
It applies when all of these are true:
- Service is likely to be accessed by children under 18
…unless:
- Q3_AGE_VERIFICATION is not Yes
- The level of certainty is appropriate to the risks arising from the data processing; self-declaration is among the methods the code discusses and may suit lower-risk processing, while higher-risk processing calls for more robust assurance. (ICO AADC Standard 3 - age assurance methods)
Scope in the source's own terms
- Service needs to establish user age
- Service operates under GDPR (EU scope; block moved from UK-GDPR authorship)
What engineering work it implies
Sample acceptance criteria Landfall generates for this obligation:
- Age gate appears before accessing age-restricted content/features
- DOB input uses dropdowns (not free text) to reduce typos
- System calculates age from DOB, not from user-entered age
- Age is stored and doesn't need to be re-entered on each visit
- Age verification cannot be bypassed by direct URL access
Evidence an auditor expects
- Technical controlTechnical audit
Age verification mechanism implementation
Technical documentation of age verification method including error rates and data collected
- Assessment documentDocument review
Proportionality assessment for verification method
Risk-based justification for chosen verification approach vs. alternatives
Questions people ask
- Does UK AADC Standard 3 — Age appropriate application: age estimation/verification… apply to my service?
- It applies when Service is likely to be accessed by children under 18. It does not apply where Q3_AGE_VERIFICATION is not Yes.
- From when does this apply?
- UK AADC Standard 3 — Age appropriate application: age estimation/verification… applies from 2 September 2021. Its current status is: in force.
- What evidence does an auditor expect?
- Age verification mechanism implementation; Proportionality assessment for verification method.
Find out whether this one lands on you
Landfall's pre-scan answers the applicability question above for your product in minutes, then turns every obligation that applies into traceable engineering tickets with a citation chain your auditors can follow.
Not legal advice. Landfall maps regulatory obligations to engineering work for planning purposes. Its verdicts are not legal advice and create no attorney-client relationship — verify with qualified counsel before relying on them.