Public Comment - FCC: Age Verification and Open-Source Impact

Generated 2026-03-12

RE: Connected Device Age Verification - Open-Source Impact

Date: 2026-03-12

Submitted to: Federal Communications Commission

Subject: Comment on Age Verification Requirements for Connected Devices and Their Impact on Open-Source Firmware and Operating Systems

Summary of Position

As the Commission considers frameworks for age-appropriate content access on connected devices, we urge consideration of the impact on open-source firmware and operating systems. Many connected devices - from routers to IoT sensors to educational computers - run Linux-based software. Mandating device-level age verification infrastructure would effectively require commercial firmware on all consumer connected devices.

Open-Source in the Connected Device Ecosystem

Open-source software is the backbone of the connected device ecosystem:

Routers and networking: OpenWrt, DD-WRT, and similar Linux-based firmware power millions of consumer routers
IoT devices: Linux runs on the majority of IoT hardware
Educational computing: Raspberry Pi and similar platforms use Linux-based operating systems for STEM education
Assistive technology: Many accessibility devices run open-source software

Mandating device-level age verification would require these devices to integrate with commercial identity services, adding cost, complexity, and privacy concerns.

Technical Incompatibility

Age verification at the device/OS level assumes:

A mandatory user account tied to a verified identity
Network connectivity to a verification service
A legal entity liable for verification accuracy

Open-source firmware and operating systems are designed to operate without these dependencies. Requiring them would foreclose open-source alternatives for an entire category of consumer electronics.

Competitive Concerns

We note that vertically integrated platform companies (including Meta Platforms with Horizon OS for VR/AR devices) benefit disproportionately from device-level age verification mandates. These companies already maintain the required identity infrastructure and face negligible compliance costs.

Research Evidence

Task horizon-os-audit: Horizon OS has 5 built-in compliance features: Meta Account Age Verification; Get Age Category API; Family Center; Quest
Task horizon-os-audit: Linux distros have 7 major compliance gaps: Account System Age Bracket; Age Category D-Bus API; Parent-Child Account Lin
Task 2.1: Meta employees hold 0 maintainer and 0 reviewer positions across 0 kernel subsystems (kernel mainline HEAD). 0 unique in
Task 2.4: Meta employees hold 0 of 0 BPF maintainer/reviewer positions (0.0%). BPF-related subsystem sections: 0.
Task 2.4: Alexei Starovoitov: BPF co-maintainer and original author. Co-created eBPF (extended BPF) while at PLUMgrid, then joined
Task 2.4: Andrii Nakryiko: BPF libraries maintainer, libbpf author. Primary author and maintainer of libbpf, the canonical BPF use
Task 2.4: Martin KaFai Lau: BPF networking maintainer. Maintains BPF networking components. Contributed BPF socket storage, cgroup
Task 2.4: Song Liu: BPF contributor, live patching. Contributed BPF trampoline and live-patching support. Works on BPF performance
Task 2.4: Yonghong Song: BPF compiler/BTF contributor. Key contributor to BTF (BPF Type Format) and BPF CO-RE compiler support in
Task 2.7: Licensing pattern identified: ‘Restrict-then-Open Cycle’. Meta repeatedly introduces restrictive licensing, faces commun

Requested Commission Action

We respectfully request that the Commission:

Exempt open-source firmware and operating systems from device-level age verification requirements
Adopt service-level rather than device-level verification frameworks that do not discriminate by operating system
Engage the open-source community in developing any technical standards for connected device safety
Evaluate the competitive impact of device-level mandates on the open-source hardware/software ecosystem