IIW 2026 › Session 2 of 3

Session 2 of 3  ·  Internet Identity Workshop  ·  April 2026

Why Incomplete Legislation Is a Practitioner Problem

Three failure scenarios with direct commercial consequences for identity vendors and protocol designers

Session Overview

The Fiduciary Commons framework only works as a complete, uniform whole. Enacting pieces of it without the others creates specific failure scenarios with direct commercial consequences. VIDA without PDTA: a technically correct credential architecture that still enables surveillance through the verification metadata layer. PDTA without VIDA: legal duties imposed on infrastructure that cannot structurally meet them, with the vendor bearing the consequences. Fragmentation: compliance cost that is multiplicative, not additive, across incompatible state frameworks. Practitioners who engage with the legislative process to ensure complete and consistent enactment are protecting their own commercial interests, not acting as advocates for an external cause.

Key Arguments
1
VIDA without PDTA: the surveillance problem survives correct architecture. Verification metadata is unprotected by VIDA alone. In the absence of purpose limitation and fiduciary duties, that residue can be aggregated into a behavioral profile constitutionally indistinguishable from the surveillance the credential was designed to prevent. The vendor’s name is on the contract. The missing statute has no name.
2
PDTA without VIDA: the legal duty is architecturally unachievable. Fiduciary duties requiring data minimization and purpose limitation are imposed on agencies whose infrastructure cannot structurally meet them. Vendors certify compliance with a standard the system cannot fulfill and face liability for secondary data use they had no power to prevent.
3
Fragmentation: the cost is multiplicative, not additive. Each additional state with an incompatible partial framework multiplies the complexity of every decision that crosses state lines. A uniform multi-state framework produces one compliance architecture, one audit standard, and competitive procurement conditions for everyone.
Downloads
PPTX
Session 2 Slide Deck  ·  16 slides
Complete presentation deck in Fiduciary Commons visual identity
Download PPTX →
DOCX
Session 2 Refresher
Two-page leave-behind for attendees: three failure scenarios, CIO conversation guide, key terms
Download DOCX →
DOCX
PDTA Draft Legislation
The data governance layer whose absence creates Scenario One and whose presence without VIDA creates Scenario Two.
Download full draft (DOCX) →    View on Google Drive →
DOCX
VIDA Draft Legislation
The identity infrastructure layer whose absence makes PDTA duties structurally unachievable.
Download full draft (DOCX) →    View on Google Drive →