DRAFT FOR A LAWYER TO REVIEW. Not final legal advice. Swiss JSFVG applicability in particular is unresolved — see below — and blocks this document's final wording (PLAN.md §11, item L9).
Age Verification Policy
LAGOON is for adults. Every visitor confirms they're 18 or older at the door (see
brand/voice.md's age-gate microcopy — "We don't check ID at the door. Confirming your age
here is a real legal statement, and we log it."). That click-through self-declaration is
the operator's confirmed call (run 10) as the baseline for the general channel — the industry-standard
approach, and sufficient. It is not a placeholder awaiting a "real" ID check; it is the
design. Some jurisdictions legally require more than a self-declaration for specific content,
and where that's true, we do more — this document says exactly which jurisdictions, what they
require, and what we actually do. Treat those jurisdictions as a future-market note, not a gap
in the default gate.
Jurisdictions with a confirmed legal requirement
| Jurisdiction | Law | Standard required | Status | What we do |
|---|---|---|---|---|
| United Kingdom | Online Safety Act 2023, s.81 | Age verification or estimation that is "highly effective at correctly determining whether or not a particular user is a child," plus a written record of the method and a published summary statement. In force since 17 January 2025. | Confirmed, in force. | Default-verify for UK-detected traffic accessing the mature lane. Written record kept per our Record-Keeping Policy. |
| United States, Texas | HB 1181, upheld by the US Supreme Court (Free Speech Coalition v. Paxton, 27 June 2025) | "Reasonable age verification methods" required once more than one-third of a site's content is "sexual material harmful to minors." Penalty: $10,000/day of non-compliance, up to an additional $250,000 if a minor actually accessed the content. | Confirmed, in force. | We track the content-mix ratio, not just a binary gate, and verify Texas-detected traffic once the threshold is crossed. |
| European Union | Digital Services Act, Art. 28 | A general "appropriate and proportionate measures" duty for platforms accessible to minors — not a specific verification method mandate, unlike the UK. | In force (general DSA applicability) — but our quotation of Art. 28's text comes from a secondary commercial mirror, not EUR-Lex; re-verify from the primary source before treating the quoted standard as authoritative (flagged in services/moderation/denylist.yaml). | Age gate applies EU-wide as part of the general channel entry; no EU-specific stricter standard beyond what's described here has been identified. |
| Switzerland | JSFVG (Federal Act on the Protection of Minors in Film and Video Games) | Unresolved. We could not reach the administering federal office's page or a working government-law-portal page for this statute during research. Whether "AI-generated, chat-steered video" counts as "film" under JSFVG's own definitions, what standard it requires, and its in-force date are all genuinely unknown, not merely uncited. | Open — do not assume this doesn't apply. | Pending legal review before any Switzerland-specific gate is finalized. This is the single most important open item in this document, precisely because it's our home jurisdiction. |
What "verify" means in practice
At launch: Veriff, a third-party identity/age verification provider, invoked only when a visitor attempts to enter the mature lane in a jurisdiction where verification is required — not at signup for every user, which would verify identity for people who never touch the gated content. We receive a pass/fail result; see our Privacy Policy for what data that involves and how long it's kept.
Content-mix tracking (Texas)
Because the Texas threshold is a ratio (more than one-third of content), not a fixed content-type flag, our system tracks what proportion of broadcast content over a given window falls into "sexual material harmful to minors" and triggers verification for Texas-detected traffic once that ratio is crossed — this is a live measurement, not a one-time classification of the whole service.
Written record and public summary (UK)
The Online Safety Act's s.81 duty is specific: keep a written record of the age-assurance method used, and publish a summary statement. Our written record lives in the systems described in Record-Keeping Policy; the public summary statement will be published alongside this policy once the method itself (Veriff at launch) is live and its accuracy characteristics can be honestly described.
What we don't do
We don't apply the strictest jurisdiction's standard globally by default — a UK-grade verification requirement for a visitor in a jurisdiction with no such requirement is friction with no legal purpose behind it, and friction that has no legal purpose behind it is exactly the kind of thing this whole product exists to avoid adding. The gate is jurisdiction-aware, not maximal-by-default.
Changes
This table will be updated as the Swiss JSFVG question resolves, as other US states pass age-verification laws in the wake of the Texas Supreme Court ruling (the legal theory is now settled nationally; which specific states follow is a moving target we're tracking, not a one-time list), and as our verification provider or method changes.