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National Conference of State Legislatures

Real ID Draft Regulations: Brief #4

Requirements for the Real ID Compliant Card

March 7, 2007

Requirements for the Real ID Compliant Card

This is the fourth brief in a series summarizing the draft regulations for implementation of the Real ID Act of 2005.  This brief will focus on the features of the Real ID card.  Brief 5 will address regulations for the non-compliant card and temporary cards.  A copy of the draft regulations and other NCSL resources on Real ID, including other briefs, are available at: http://www.ncsl.org/realid/

Minimum Data Element Requirements

The Real ID Act prescribes that a certain set of information and features appear on state-issued driver’s licenses (DL) and identification cards (ID).  The law stipulates the following nine as minimums:

1. The person’s full legal name;
2. The person’s date of birth;
3. The person’s gender;
4. The person’s DL or ID number;
5. A digital photograph of the person;
6. The person’s address of principal residence;
7. The person’s signature;
8. Physical security features designed to prevent tampering, counterfeiting, or duplication of the document for fraudulent purposes; and
9. A common machine-readable technology, with defined minimum data elements.

NCSL, governors and motor vehicle administrators made a number of recommendations addressing data element requirements.  They include: requiring the capture of up to 125 characters for full legal name; requiring the federal government to adopt and universally apply common naming conventions to its systems; and, with input from states, develop and apply naming truncation guidelines to all systems accessed under the Real ID. In addition, states recommended that the regulations provide states the necessary flexibility to engineer their system and business processes as it relates to the capture of facial images as long as the image is captured when a DL/ID is issued and before a DL/ID is denied.

The draft regulations detail these nine elements and add issue date and expiration date to the list.

Full Legal Name
The full legal name for the Real ID card must be identical to the name shown on the identity document used to obtain the DL/ID (see Brief 2 for more on identity documents).  Any name variations due to marriage, divorce, adoption, or court order must be supported by original or certified copies of documents that also bear the person’s date of birth or age.  States must maintain this name change in their database without deleting any previously recorded name so as to retain a complete record of an individual’s name history.  DHS proposes to adopt the International Civil Aviation Organization (ICAO) 9303 Standard for the name as it will appear on the face of the DL/ID.  This standard requires Roman alphabet characters, allows a total of 39 characters on the face of the card, and provides standards for truncation of longer names.  Up to 125 characters of the name must be captured in the machine-readable portion of the card using the proposed PDF-417-2D bar code.  More on the machine-readable technology (MRT) follows.

DL/ID Number
Each DL/ID must display a unique card number.  As federal law prohibits the display of a person’s Social Security Number (SSN) on a DL, states must generate a different and unique document number.

Digital Image
States must capture a full facial color digital image of everyone applying for a DL/ID.  If a DL/ID is issued, the image must appear on the face of the card.  If a DL/ID is not issued, DHS suggests that states retain the image for one year.  Digital photographs should comply with ICAO standards, including diffused lighting over the full face eliminating shadows or “hotspots,” a full face image from the crown to the base of the chin and from ear-to-ear, and prohibition of veils, headdresses or eyewear that obscure facial features or the eyes.  DHS contends that the law makes no allowances for facial photographs based on religious or other beliefs, but states could use profiles for a DL/ID issued to those under 21 years of age.  An applicant’s photo should be updated upon reapplication and any prior photos should be discarded in favor of the image associated with the issued DL/ID.  If a state does not issue a DL/ID on suspicion of fraud, DHS requires that the record be maintained for 10 years and note the reason for non-issuance.

Address of Principal Residence
The person’s address of principal residence must appear on the face of the card.  Conforming to recommendations from NCSL, governors, and motor vehicle administrators, DHS proposes that state exemption processes for confidential addresses (of judges, victims of domestic violence, protected witnesses, etc.) and applicants with no fixed address be continued.

Signature
DHS proposes that the person’s signature meet the size, scaling, cropping, color, borders, and resolution requirements stated in existing American Association of Motor Vehicle Administrators (AAMVA) standards.

Machine-Readable Technology
DHS is proposing to use the existing AAMVA standard 2D bar code for the machine-readable technology on the card.  DHS suggests that the PDF-417 2D bar code approved by AAMVA store the minimum data elements – expiration date, bearer’s name, issue date, date of birth, gender, address, unique number, DL/ID format revision date, and inventory control number – necessary to fulfill the purpose of the Act.  DHS is encouraging but not requiring encryption of this machine-readable information.

Physical Security Features

The Real ID Act requires states to utilize multiple layers of physical security features on a DL and ID that are not reproducible using commonly used or available technologies in order to deter forgery and counterfeiting and to promote an adequate level of confidence in the authenticity of the document. 

NCSL, governors and motor vehicle administrators recommended that the regulations establish performance requirements for DL/ID cards rather than mandating use of a specific set of security features.  Recommendations also included initiating an advisory group composed of document security experts from federal and state agencies to establish national performance criteria and creating a testing program, in cooperation with states, to determine the resistance of DL/ID cards to tampering, counterfeiting or duplication for fraudulent purposes.

The draft regulations mandate certain security feature—such as intricate, fine-line, multicolored background design produced by offset lithography in place of dye sublimation printing; microline printing; an intentional error/field check; an optically variable feature; an ultraviolet (UV) responsive feature; tamper-proof printed information; and covert taggants and/or markers – with a performance standard based on impartial adversarial testing of the card and security features.

The card stock must comply with the following performance standards:  durability up to an eight-year life span, a controlled UV response, a counterfeit resistant background pattern that avoids enumerated primary colors and typical digital printing technologies, serial numbers with inventory control measures such that missing cards can be recorded and reported to law enforcement, and a format revision date.

States must provide DHS with samples of Real ID compliant DLs and IDs.  States must also annually review, via a recognized independent laboratory experienced with adversarial analysis, and report to DHS on the integrity and security of the card. 

For more information contact NCSL staff Molly Ramsdell (Molly.Ramsdell@ncsl.org, 202-624-3584), Jeremy Meadows (Jeremy.Meadows@ncsl.org, 202-624-8664).