GAIN DIGITAL TRUSTHow Financial Institutions are taking a leadership role in the Digital
Economy by establishing a Global Assured Identity Network

With over 150 co-authors

GAIN DIGITAL TRUSTThe Contributors
Nacho Alamillo, Phil Allen, Peter Amrhyn, Martin Azcue Lopez, Daniel Babatola Awe, Simone Baldini,Fred Bär, Donna Beatty, Yoram Bechler, Waleed Beitar, Erik Belluci Tedeschi, Vittorio Bertocci, David
Birch, Wayne Blacklock, Rod Boothby, Gijs Boudewijn, Matthias Bossardt, Andre Boysen, John Broxis,
Katinka Jussie Lønning Bruberg, Nick Cabrera, Kim Cameron, Brad Carr, Peter Carroll, Anik Chawla,
Daniele Citterio, Malcolm Clarke, Uli Coenen, Adam Cooper, Arthur Cousins, Cameron D’Ambrosi,
Arthur Dallau, Scott David, Thibault de Valroger, Thomas Dübendorfer, Christian Duda, Andrei Dumitru,
Vladimir Dzhuvinov, Thomas Egner, David Fennell, Daniel Fett, Conan French, Alexis Fruchaud, Justin
Gage, Elizabeth Garber, Dominik Goergen, Daniel Goldscheider, Will Graylin, James Greaves, Odd
Erling Håberget, Mark Haine, Patrick Harding, Gerard Hartsink, Mehraj Hassan, Joseph Heenan, Ben
Helps, Bjorn Hjelm, Gail Hodges, Johs. Hoehener, Jens Holeczek, Carl Hössner, Stefan Imme, Martin
Ingram, Brenan Isabelle, Ashish Jain, Vincent Jansen, Travis Jarae, Michael Jünemann, Marco Kaiser,
Hitesh Kalra, Peter Kirkwood, Remy Knecht, Valentin Knobloch, Delia König, Adriaan Kruger, Martin
Kuppinger, Julianna Lamb, Oliver Lauer, Rob Laurence, Row Lawrence, Gottfried Leibbrandt, Jörg
Lenz, Johannes Leser, Emma Lindley, Gavin Littlejohn, Torsten Lodderstedt, Tobias Looker, Bianca
Lopes, Douwe Lycklama, Maciej Machulak, Anil Mahalaha, Eve Maler, Piet Mallekoote, Viky Manaila,
Jatin Maniar, Masa Mashita, Reed McGinley-Stempel, Karla McKenna, Tony McLaughlin, Simon
Moffatt, Susan Morrow, Marcus Mosen, Nick Mothershaw, Hiroshi Nakatake, Axel Nennker, Michael
Palage, Steve Pannifer, Radu Popa,

Dima Postnikov, Dan Puterbaugh, David Rennie, Victoria

Richardson, Robert Robbins, Andrea Röck, Timothy Ruff, Nat Sakimura, Michael Salmony, SamuelScheidegger, Christoph Schneider, Schlager Ales, Frank Schlein, Rachelle Sellung, Sahil Shah,
Somnath Shukla, Jesper Skagerberg, Tom Smedinghoff, Joerg Staff, Gabriel Steele, Frank R.
Svendsen, Franco Tafini, Taavi Tamkivi, Antonio Taurisano, Oliver Terbu, Don Thibeau, Lars Gunnar
Tiben, Andreas Toelke, Bob Trojan, Paiak Vaid, Andrea Valle, Francesco Vetrano, Jürgen von der Lehr,
Liz Votaw, Marie Walker, Charles Walton, Laurence White, Edgar Whitley, Johannes Wirtz, Stephan
Wolf, Dirk Woywod, Sudhindra Yapalparvi, Stuart Young
To cite this paper:
E. Garber, M. Haine, V. Knobloch, G. Liebbrandt, T. Lodderstedt, D. Lycklama, N. Sakimura et al., GAIN DIGITAL TRUST,How Financial Institutions are taking a leadership role in the Digital Economy by establishing a Global Assured Identity
Network, European Identity and Cloud Conference, Munich Germany, September 13, 2021.

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GAIN DIGITAL TRUST

Executive Summary
The lack of verified Digital Identity presents an urgent problem and a meaningful opportunity forsociety. There are substantive risks to unfettered anonymity, ranging from the spread of
misinformation to the enablement of criminal markets.1 Meanwhile, to engage in the digital
economy, individuals disclose myriad private data, including biometrics, with organizations that
may sell, misuse, or lose it.2 Yet, digital engagement is a key driver of economic growth - andinclusive participation requires access to high-trust identity verification services.3
The 150+ authors of this paper propose a shift towards a user-centric and high-trust identity
paradigm: the Global Assured Identity Network (GAIN). Instead of logging in directly, an EndUser asks a trusted and regulated provider (e.g., their bank, telecommunications provider, or
another regulated entity) to verify that they are the person and/or have the credentials that theyclaim. Rather than managing over 100 passwords,4 people will bring their identities with themand exercise greater control over data about them. This high-trust identity assurance, therefore,
introduces an accountability layer to the internet even as it increases privacy and security.

Financial Institutions taking a lead in Digital Identity
This paper is directed at the leaders of Financial Institutions and is intended to catalyse acollaborative effort to develop the GAIN. Taking such action plays into core strengths, puts
capital-hungry assets to work, and staves off disintermediating threats. Financial Institutions
have done this before: they built global rails for trade, cards, digital payments, and securities.
Similarly, institutions whose leaders recognise that Digital Identity is a critical frontier for the
global economy will drive this transformation. Underpinned by broad collaboration and strong
principles, such as those put forward by the World Economic Forum,5 it paves the way for
greater inclusivity and access - even for today’s unbanked populations.
The knowledge, skills, and technology exist to deliver the GAIN: it is now a matter of those withhigh-trust identity data - starting with Financial Institutions - joining together to unite disparate
schemes and achieve the global reach required to underpin a truly digital economy.

Join the GAIN Proof-of-Concept

Under the auspices of:which will be shared at the 2021 IIF
Annual Membership Meeting on 14
October in Washington, DC

Cloud Signature Consortium
Global Legal Entity Identifier Foundation
Institute of International FinanceOpen Identity Exchange
OpenID Foundation

Please contact DigitalTrust@iif.com to register interest.

Page 2 of 49

GAIN DIGITAL TRUST

Understanding Key Terms
While the main body of this paper seeks to avoid jargon, there are many references toparticipants in the identity ecosystem. For the purposes of this paper, the following terms havebeen used based upon international standards (ISO/IEC 24760 1) wherever possible.1

Term

How the term is used in this paper

Identity Information
ProviderAn entity that makes identity information, i.e., a set of
attributes, available to Relying Parties.5
For example: a bank may act as an Identity Information
Provider because it has verified its customers’ identity
information using government issued identity documents. It
may pass that information, such as age, name, address, toother entities.

Relying Party

An organization that wishes to ensure that an End-User is the
person they claim to be and is entitled to an activity, based on
identity information. Thus, they consume information from
Identity Information Providers for the purpose of providing
services to their End-Users.
For example: a liquor store needs to know that a customer isthe true owner of an ID document, e.g. a driver’s licence, thatshows they are over a minimum age.

End-User
A natural person that wishes to have an Identity Information
Provider share identity information with a Relying Party.

1

Note that more precise terms are defined in Appendix C.
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GAIN DIGITAL TRUST

Chapter 1: The Value of a Global Assured
Identity Network
Key Points from Chapter 1:
 Trust between parties is critical to our global economy, but - as evidenced by risingdata breaches, privacy concerns, and financial crime - trust online is broken.
 Financial Institutions have historically built infrastructures that underpin trust:
together and with partners, they can develop a solution that benefits a wide range ofstakeholders.
 The Digital Identity landscape is fragmented and 2 important factors will determine
success: trust and reach.
 To realise benefits and stave off disintermediation, Financial Institutions must
collaborate quickly to deliver high trust with global reach.

The Digital Trust Challenge
As transactions shift online, society faces a Digital Trust challenge: how to reliably andseamlessly identify one another while keeping private information safe. Financial crime, borne ofillicit activities with untold human impact, amounts to an estimated 2-5% of global GDP per year6($800 billion - $2 trillion USD7). These criminal markets often depend upon digital infrastructuresthat are anonymous by design or vulnerable to attack. It is in this context that Digital Identity is
increasingly cited as a national security issue.8 Meanwhile, it is also described as a pillar of
growth9 - one with the potential to expand access,10 bolster human rights,11 and grow the global
economy.12 In the absence of robust Digital Identity solutions, individuals and organizations (ofany size) bear the cost: they carry the risk that someone is not who they claim to be, that theiridentities will be stolen,13 or that private information about them will be used in unexpected often perceived as unethical - ways.14
Establishing and maintaining Digital Trust infrastructure, therefore, is at a critical frontier ofglobal economic innovation.15 Chapter 1 of this paper shows that Financial Institutions have an
opportunity to create and absorb significant value by offering high-trust identity services, andthat doing so requires collaboration on a global scale. Chapter 2 lays out the critical next steps
that will make it happen.

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GAIN DIGITAL TRUST

Benefits to Financial Institutions
Financial Institutions will reap many benefits from catalysing an interoperable global identity
network: the first is strategic.16 They face disintermediating threats on multiple fronts.17 Large
technology firms have global reach and are firmly entrenched in people’s lives. Meanwhile,
many more players compete for slices of an increasingly disaggregated value chain. Bank
leaders argue that their competitors benefit from the uneven playing field that is created by afragmented, entity-based approach to regulation and the one-way data flows mandated byregulators in some jurisdictions.18 Yet Financial Institutions have the opportunity to offer Digital
Identity solutions that address these concerns. Specifically, Figure 1 shows how Financial
Institutions’ investments in Know Your Customer (KYC) and digital authentication enable themto verify information on behalf of the organizations that need high-confidence data to offer
services, referred to herein as ‘Relying Parties.’
Figure 1: Financial Institutions Answer Key Questions as Identity Information Providers

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GAIN DIGITAL TRUSTSuch networks show promising results inregions where they operate (see sidepanel). When they facilitate thesetransactions, Financial Institutions
maintain their day-to-day relevance with
consumer and business customers.
Benefits extend further - and many could
be realised within two years. Digital
Identity solutions create efficiencies for
Financial Institutions: they turn a costcentre into a profit-centre, simplify
processes (login, password recovery,
customer onboarding, signing), andenable cross-border platforms thatfacilitate scale. Ongoing efforts toremove barriers (e.g., data sharing within
and between institutions) and to movetowards comparative legal and regulatory
structures will serve to expand the total
opportunity.

Results from Established Trust Networks
 BankID Sweden achieves 840 interactions
per user per year - and is used by over 98%
of those aged 21-67.
 BankID Norway has 99% market penetration
within the adult population and 215
transactions per user per year.
 Over 1000 German banks form the yes®
network.
 itsme® in Belgium has onboarded over 60%of the population: the Digital Identity app
offers identification, authentication,
confirmation, and digital signatures.
 Over 17m Canadians use Verified.Me(powered by the banks) at 85 federal
government services; its use is expanding
across the economy.

As Chapter 2 will show, working groups
and a proof-of-concept are mobilising
now for a late 2022 launch. Institutions
will begin realising benefits soon and, bybuilding this ecosystem, may instigate the shift toward frameworks that maximise return andsupport globally-scaled platforms more broadly.

Financial Institutions within the Competitive Landscape
These advantages are fully realisable if Financial Institutions work together. The establishednetworks (above) have shown that banks are able to create and absorb value in the identity
ecosystem because of the unique strengths that build trust and underpin their core offer today.
They are in the business of trust: since the founding of the Medici Bank in 1397, they havepioneered the development of trust infrastructures that enable trade between distant parties andacross borders. As described above, they are bound by KYC regulations to invest in verifying
the identities of their customers. They have a fiduciary responsibility to keep that data private
and invest in security. This is why, although numbers vary by jurisdiction, Financial Institutions
are some of the most trusted across the world on matters of data and security.19
This high degree of trust establishes Financial Institutions’ market opportunity. They offer EndUsers security, control, and convenience. Meanwhile, Relying Parties benefit from, not only
‘Financial-Grade’ Identity Assurance, but also a dramatically simplified user experience. As EndUsers enjoy an easier online life with far fewer passwords and forms, Relying Parties will
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GAIN DIGITAL TRUST

improve their conversion rates and contain servicing interactions in digital channels.20 As shownin Figure 2, such a network adds value for Relying Parties across the economy: energy,
insurance, health, education, mobility, and beyond (Figure 2). More details about the Value
Proposition to End-Users and Relying Parties can be found in Appendix A.
Figure 2: Use Cases in the Identity Ecosystem

However, Relying Parties require cross-border collaboration between Financial Institutions –and other high-trust Identity Information Providers (e.g., public sector, energy,
telecommunications) – to realise benefits. Since Relying Parties cannot contract and integratewith every Identity Information Provider, they need a network. Since they operate internationally,
with customers and suppliers in many countries, that network must be globally interoperable.
Global reach, therefore, is critical to success (Figure 3): without it, the benefits to Relying
Parties and End-Users diminish.

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GAIN DIGITAL TRUST

Figure 3: The Dynamic of Trust and Reach

As shown in Figure 3, strategic relevance depends upon the dynamic between 2 factors: Trustand Reach. Large technology firms provide a simple experience that has led to broad adoption
and global scale. Their current capabilities, however, do not extend to contexts requiring a highdegree of certainty about an individual’s identity. Financial Institutions, by virtue of theirinvestments in KYC and authentication, offer a high-degree of Trust. However, alone or as
discrete in-country networks, they do not have the reach to provide Identity Information to
Relying Parties that operate globally. To achieve that scale requires collaboration between
those institutions with high-trust identity information: Financial Institutions and other regulated(or otherwise trusted) entities around the world.
By catalysing a decentralised and interoperable global network, as has been achieved for
payments, Financial Institutions will offer high-trust identity assurance within a safe, sufficiently
regulated environment: a major step toward Digital Trust.

Time is Running Out
Global reach requires interoperability akin to the global rails that connect localised payments,
securities, and mobile communications solutions: this demands collaboration between
institutions. A series of seminal publications have called on banks to collaborate on this type ofhigh-trust identity solution - the World Economic Forum’s A Blueprint for Digital Identity, 21 David
Birch’s Identity is the New Money, 22 Citi’s The Age of Consent,23 and McKinsey’s Digital
Identification: A key to inclusive growth.24 Meanwhile, the solutions that have emerged (e.g., in
Norway, Germany, Australia, Sweden, The Netherlands, Belgium, and Canada) prove thatdemand for financial-grade identity assurance exists.
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GAIN DIGITAL TRUST

Figure 4: The Fragmented Global Identity Market

The ecosystem in Figure 4 remains fragmented: a lack of interoperability constrains scale andadoption. In turn, the absence of scaled high-trust identity assurance constrains the benefits toall actors. Relying Parties must negotiate many contracts and integrate multiple systems toreach their customers. Each End-User experiences limited opportunity to verify credentials
digitally.
Competitors recognise the gaps in this market and aremobilising: the time for Financial Institutions to act is now.
Recent market movements reveal that key players arelaying the groundwork to compete in a global high-trust
identity market (see right) and major venture capital firms(e.g. Andreessen Horowitz, Accel, Felicis Ventures25) are
expanding their investments in this space. At the sametime, governments and regulators aim to roll out moredigital services across society while users flock to themost convenient, readily-available experiences. In thiscontext, non-financial actors will soon establish
themselves in providing Digital Trust.
The financial industry faces a choice: will customers
ultimately login to their bank with a social media ID or will
they use their bank to gain access across the internet?
For Financial Institutions to address strategic challenges

Market Movements
Recent movements in theidentity market$850M Mastercard
acquired Ekata$6.5Bn Okta acquired
Auth0$4.5Bn Clear Secure Inc
IPO$1.75Bn Trulioo valuation
at Series D

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GAIN DIGITAL TRUST

and create value for actors across the ecosystem, now is the time to expand the reach of theirstrongest asset: trust.
The time for cross-border, cross-sector collaboration is here.

Get Involved
We’re building a Global Assured Identity Network by the end of 2022.
Please contact DigitalTrust@iif.com to participate.

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GAIN DIGITAL TRUST

Chapter 2: Delivering the Network
Key Points from Chapter 2
 With a modest investment of time, money, and people, Financial Institutions candeliver a functioning Global Assured Identity Network (GAIN) that addresses key
stakeholder needs by the end of 2022.
 This solution will be technically interoperable across borders and sectors of theeconomy.
 Please contact DigitalTrust@iif.com to register interest in participation.
 Appendices A-D propose value propositions, business models, details of the Trust
Framework, and the technical architecture.
As established in Chapter 1, Financial Institutions have a window of opportunity to catalyse adecentralised, globally collaborative, and technically interoperable identity network that will
benefit all parties and position them to compete. Chapter 2 provides a broad definition of the
GAIN, with greater detail in Appendices A-D. Furthermore, it elucidates how Financial
Institutions, Relying Parties, and key technology partners will come together to, with a modest
investment of money, time, and human capital, launch the GAIN by the end of 2022.
Figure 5: Relationships within the Global Assured Identity Network (GAIN)

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GAIN DIGITAL TRUSTThe GAIN delivers global reach to high-trust Identity Information Providers from any sector andenables them to act as one. It achieves this because it is flexible: it works with manyarchitectures and is designed to complement the legacy infrastructures of its “Members.”
Furthermore, it allows for different levels of assurance and enables compliance across a range
of use-case and jurisdictional requirements.

Table 1: How GAIN Delivers Value

Note: For more information, Appendices A through D provide foundations for the GAIN
proposition, multi-party business models, a Trust Framework, and technical architecture.
To ensure adoption, the GAIN user experience must be simple: designed to meet thefundamental needs of End-Users, Relying Parties, and Identity Information Providers. EndUsers need only select their Financial Institution from the list of GAIN Members and may havean option to store a preference. What follows is an experience defined by the brand and theinterface that they already use day-to-day - this may be their bank, another institution, or an
existing assured identity scheme (e.g., itsme®, BankID, Verified.Me) and could be via web or
mobile channels.

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GAIN DIGITAL TRUST

Illustrative GAIN User Experience
The GAIN does not have any direct interaction with an End-User: Relying Party and selected Identity Information Provider channelsdeliver the experience. The GAIN does, however, provide a mechanism for selecting the Identity Information Provider in the relevant
Relying Party channel.
Figure 6a: Alice is logging in to a local government service

Authentication

Authorisation

Attributes Shared

Alice receives notification to authenticate via
her mobile app

Alice approves sharing of key attributes to the
Relying Party (Local.gov)

identifier,name,assurance level,authentication level

Note: This is intended to show a government use case requiring a low Level-of-Assurance (LOA). The GAIN will support cases
requiring a higher degree of identity assurance if the local jurisdiction allows.
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GAIN DIGITAL TRUST

Figure 6b: Bob wants to buy alcohol and needs to login, prove his age, and confirm his delivery address

Authentication

Authorization

Attributes communicatedGoodwine redirects Bob to his Bank’s mobile
app based on cached preferenceBank app presents what data “Goodwine” isrequesting

pseudo identifier,Bob approves the sharing of requested
attributes to “Goodwine”

assurance level,authentication level,
over-18-flag,
address

Note: the Identity Information Provider Chooser has been omitted from this journey on the basis that “Bob” has used this service and
the Goodwine app has a locally cached preference for his preferred Identity Information Provider.

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GAIN DIGITAL TRUST

Figure 6c: Jane is setting up a new account and signing loan documents

Authentication

Authorization

Attributes communicated

The lender redirects Jane to her Bank’s
mobile app

Bank app presents the data that “Lender” isrequesting

identifier,Bob approves the sharing of requested
attributes to “Lender”

name,assurance level,authentication level,
address

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Once it launches in 2022, the experience of joining the GAIN will be similarly simple for Identity
Information Providers and Relying Parties. They will require a single contract and integration: atthat point, Identity Information Providers will begin serving the ecosystem. Relying Parties will
be able to verify any customer’s identity attributes (as long as they have a relationship with aService Provider). All participants, including Financial Institutions acting as Identity Information
Providers and/or Relying Parties, will begin realising the benefits of a globally interoperable
network as early as next year.
To achieve this bold goal, however, requires a worldwide collaborative effort involving Financial
Institutions, Identity Information Providers, Service Providers, and Relying Parties: this has
started already.
Figure 7: Milestone plan

Conclusion
The GAIN creates new tools to verify people online: are they human? Are they the person theyclaim to be? Are they entitled to this service? Are these payment details accurate? These tools
are available to individuals, industry, and further extend the options available to policy-makers.
Leaders who share this vision are invited to join the GAIN Proof-of-Concept, which brings
together Financial Institutions, Identity Information Providers, Relying Parties, and key partners.
They will co-create the GAIN product design, business models, technical architecture, and Trust
Framework (building upon and adapting the proposals in Appendices A-D). This collaboration
ensures that Identity Information Providers will secure sufficient reach to realise the benefits in
Chapter 1.
This is only the beginning: by catalysing this movement, Financial Institutions will bring about afundamental shift in the digital economy. As mentioned at the start of Chapter 1, Digital Identity
is at a critical frontier. As the GAIN ecosystem expands, it will create new sources of value for
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all actors and for society at-large. In the medium-term, this may include value-added-services
like insurance, signing, and the integration of Open Banking. Beyond this, the GAIN holds
promise for society: not only does it address flaws in the online environment that lead tomisinformation and crime, but it also expands access for millions around the globe. To deliver
these gains, however, requires diverse working groups, broad participation, and a commitment
to fundamentally inclusive outcomes.

Join the GAIN Proof-of-Concept

Under the auspices of:which will be shared at the 2021 IIF
Annual Membership Meeting on 14
October in Washington, DC

Cloud Signature Consortium
Global Legal Entity Identifier Foundation
Institute of International FinanceOpen Identity Exchange
OpenID Foundation

Please contact DigitalTrust@iif.com to register interest.

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Appendices
The 150+ authors have come together in broad agreement of the following proposals for how
the GAIN ecosystem can become a reality. There will be important areas of disagreement,
discussion, and further development: this is why you are invited to join the Proof of Concept.

Contents
Appendix A Value Propositions
Appendix B Business Models for Key Actors
Appendix C Trust Framework
Appendix D Technology Architecture

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Appendix A - Value Proposition Proposal26
The purpose of this section is to articulate, in greater detail, how GAIN can deliver value to End
Users, Relying Parties, and Identity Information Providers. With Proofs-of-Concept, Working
Groups, and inclusive collaboration, they will evolve.

A.1 End-User Value Proposition
Simplify your digital life: now you can use a trusted institution that safeguards your datato access almost anything.

Value for End-Users means…

How GAIN Delivers

Customer Jobs-to-be-Done

The Core Product & Services

•
•
•
•
•
•
•
•
•

•
•
•
•
•
•
•

Prove that I am who I say I am
Access services that require information about me
Login to sites and apps across platforms
Access non-digital services requiring my information
Recover login details
Prove that I have credentials for an activity
Prove that I am entitled to a given activity
Sign - or formally agree to services*
Send and receive payments*•

Use Bank KYC data to provide evidence of identity
Share relevant data, easily, with my consent
Login to any service (feasibly) with my bank app
Use GAIN in offline venues too (i.e., QR codes)
I use my bank app to recover login details
Attributes may include certifications and entitlements
Information from the Identity Information Provider isused when signing*
Validate payment instructions & identities*

Customer Gains

Gain Creators

•
•
•
•
•
•

•
•
•
•
•
•

Data sharing subject to consent & under my control
Reduce friction across experiences
Save me time
Confidence that data about me is secure
Enable me to maintain anonymity in certain spaces
I trust the people validating my identity/credentials

I consent to each item shared
I can use my bank authentication almost anywhereFewer services require me to visit in-person
I trust my Financial Institution with my data
I need not consent to pass identifying information
Relying Parties adhere to GAIN’s Trust Framework

Customer Pains

Pain Relievers

•
•
•
•
•
•
•
•
•

•

Inconvenience
I have countless IDs/Passwords in my life
Things take too long / require too many documents
Service providers store too much personal info
Password recovery is hard
I must physically sign stuff
Are the payment details right? (sending & receiving)
Who is getting data about me, and can I trust them?
Fear of data breaches••

I can use my trusted Identity Information Provider to:oreduce the number of login credentials I needosign up to new services onlineoconsent to what data is sharedorecover passwordsosign documents*ovalidate payment information*
Relying Parties adhere to GAIN’s Trust Framework
I trust my Identity Information Provider*These items are an extension of the initial GAIN launch: they are not planned for Day 1, and are not19
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includedin the forthcoming Blueprints.

A.2 Relying Party Value Proposition
Identify and authenticate your customers - wherever they are in the world - with a simple,
high-trust experience. Increase conversion; reduce the cost and complexity in yourbusiness.

Value for Relying Parties means…

How GAIN Delivers

Jobs-to-be-Done

The Core Product & Services

•
•

•
•

•
•
•
•

Authenticate End User
Validate the identity, credentials, or entitlements of EndUsers
Onboard and serve End-Users
Prove its authenticity and entitlements to its End-Users
Allow for levels of assurance to fit different use cases
Fulfil regulatory (e.g., data protection) requirements•••

Identity Information Providers authenticate End-Users
Leverage trusted ID Provider to validate identity,
credentials, and other attributes
End-Users access services quickly
Trustworthiness assured by GAIN Trustmark
Relying Parties can assess Identity Information
Provider vs levels of assurance aligned to use cases
and local regulations*

Relying Party Gains

Gain Creators

•
•
•
•

•

Improved conversion
Efficient servicing processes
Effective account recovery
Minimal effort to integrate••

Minimal effort for End-Users to validate their identities
improves conversion and efficiency
Recovery follows the same efficient process
1 integration; interoperable Open Standards APIs

Relying Party Pains

Pain Relievers

•
•
•
•
•
•

•
•
•
•
•
•

•
•
•

Low conversion rate / high cart abandonment
Call centre calls for recovering user credentials
Costs to integrate - especially multiple systems
Costs to negotiate & manage multiple contracts
Costs to conduct full identity verification
Costs to comply with data protection regulation (when I
store data myself)
Risks associated with inaccurate identities
Major capital investment
Unclear whether to trust identity data and attributes•••

Simple UX improves conversion rates
Financial institution app recovers login credentials
Single integration with global reachContract with global reach
Leverage financial institutions’ investment in KYC
Attributes are passed to - but do not have to be storedby - Relying Parties
Insurance as a value-added-service*Transaction fee-based model reduces CAPEX
Identity Information Provider adhere to the GAIN Trust
Framework*These items are an extension of the initial GAIN launch: they are not planned for Day 1, andare not included in the forthcoming Blueprints.

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A.3 Identity Information Provider Value Proposition
Secure long-term relationships with your existing customers while transforming
investments in customer identification, data security, and digital channels into asustainable profit-centre with global reach.

Value for Financial Institutions means…

How GAIN Delivers

Jobs-to-be-Done

The Core Product & Services

•
•
•
•
•
•

•

Maintain direct relationship with my customers
Profitable growth for my shareholders
Offer valuable services to my customers
Comply with regulation & legislation in my market
Ensure the security of customer transactions
Maintain my reputation for corporate responsibility

•
•
•
•

Return on heavy investments in KYC and authentication,
revenue & deepened relationships
Offers my customers seamless access to services
Flexes to architectures that meet local requirements
Ensure my customers' consent, privacy, and security
Leadership in building Digital Trust

Financial Institution Gains

Gain Creators

•
•
•
•

•
•
•
•

Increased customer relevance
Increased returns on assets and investments
Global reach
Reduced costs and complexity - technology, legal,
vendor relationships

100+ customer interactions per year
Leverage investment in KYC and digital technology
GAIN is interoperable across borders
Connect to 1 global system rather than disparate
networks in jurisdictions around the world

Financial Institution Pains

Pain Relievers

•
•
•

•
•
•

Disintermediation
Complex operations
Inability to scale•

Ensure direct 1-to-1 relationship with customers
1 set of standards
Global identity and data standards can spur harmonizeddata regulations that facilitate scale*Connect to 1 global system rather than disparate
networks in jurisdictions around the world

Note: some of these value-drivers may not be relevant to all Identity Information Providers.

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Appendix B - Business Model Outlines27
B.1 Financial Institutions
Financial Institutions may take on up to three roles: Identity Information Provider, Service
Provider (onboarding Relying Parties), and as a Relying Party. This addresses the first two.

Value
Propositions

for End-Users (FI as Identity Information Provider): Use your trusted banking (or otherfinancial Identity Information Provider) app to access almost anything online.

for B2C and B2B
customers

for Relying Parties (FI as Service Provider): With GAIN, you can identify and authenticate
your customers - wherever they are in the world - with a simple, high-trust experience. The
UX is harmonized, similar to the global unified payment experience. This Increases
conversion, while reducing the cost and complexity for Relying Parties.

Revenue Streams

from End Users (as Identity Information Provider)●●

A proportion of each chargeable identity verification transaction will flow to the
Financial Institution as Identity Information Provider
Indirect: More frequent interactions and deeper relationships with B2C customers

from Relying Parties or GAIN (as data and service provider)

Key Partners

●
●
●
●

Fixed fees to access the network
Transaction fees
Offering secondary services, e.g., insurance
Indirect: Deeper relationships with B2B customers, brand recognition, and reputation
for trust assurance●●●

GAIN operations
Trust Networks in jurisdictions around the world
Service providers (GAIN Members, Aggregators, etc.) who support in onboarding
Relying Parties

Key Activities

Onboard and maintain GAIN connectivity and participation (Direct or via Service Providers)

Resources
RequiredEngineering capabilities to integrate the GAIN Technical Requirements
Ongoing operation of the GAIN implementation
1st, 2nd, and 3rd line process & risk management
1st line customer support (End-User)
Product Management

Cost Structure

Initial Implementation
Ongoing Costs
Membership Fees for GAIN governance and maintenance
OPEX
Potential additional costs for fulfilling additional requirements of the GAIN Service (p.ex.
collecting additional data, fulfilling reporting obligations, ensuring higher requirements thanthose arising from own regulatory obligations)

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B.2 Service Providers
Value Propositions
for Relying Parties

for Relying Parties (as Service Provider): With GAIN, you can identify and authenticate
your customers - wherever they are in the world - with a simple, high-trust experience.
Increase conversion; reduce the cost and complexity in your business.

Revenue Streams

Onboarding / Setup Fees
Processing Fees
A proportion of the revenue from each identity verification flows to Service Providers

Key Partners

GAIN (GAIN Operator and/or GAIN Board of Governors)
Relying Parties

Key Activities

Onboard and maintain (legal) GAIN connectivity and participation
Onboard Relying Parties
Identification and Authentication of Relying Parties and adherence to the GAIN Rules
Monitor Relying Parties’ adherence to the GAIN Rules and ensure enforceability of the
GAIN Rules
Billing and clearing of any fees to be paid to GAIN (or an Identity Information Provider)

Resources Required

Engineering capabilities to integrate the GAIN Technical Requirements at the Relying
Party (if this service is offered).
Ongoing monitoring of the Relying Party
1st line customer support (Relying Party)
Product Management

Cost Structure

Initial Implementation
Ongoing Costs
Monitoring system
Billing & Clearing system

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B.3 GAIN (Operator and/or Board of Governors)
Value
Propositions

for End Users - as above (refer to Appendix A)
for Relying Parties - as above (refer to Appendix A)
for Trust Networks Connect your network to a global ecosystem - dramatically increasing
your reach and, therefore, the value offered to relying parties and customers who transact
around the world.
for Financial Institutions as Identification Providers Turn a cost-center into a profit-centerby leveraging existing capital-hungry assets (KYC and authentication processes; existing
digital channels; security and privacy protections) to deliver high-trust identification solutions
to a global marketplace.

Revenue Streams

Membership subscriptions / License fee (fix or transactional) for participation
Data products and value-added services for the open market (e.g., insurance)

Key Partners

Identity Information Providers, including Trust Networks
Service Providers
Relying Parties (via Service Providers)(Qualified) Trust Services providers
OpenID Foundation
OIX

Key Activities

Build Governance structures
Build & Maintain:
●
●
●
●
●
●

Resources
Required

Trust Framework
B2B directory
Test services
Monitoring policies and processes
Enforcement policies and processes
Billing & Clearing

Capital (investors) to bridge until the GAIN break-even point
People & Consultancy Services
Outsourced services

Cost Structure

Initial Implementation●●●●

Cost of the Proofs-of-Concept
Consultancy Services
Engineering Services
Project Management

Ongoing Costs●●●

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People costs
Outsourced services
License fees to Identity Information Providers (as the case may be)Appendix C - GAIN Trust Framework
Trust Frameworks lay out legally enforceable specifications and rules that govern a multi-party
system. A GAIN Trust Framework will be established in order to ensure that:
1.
2.
3.

End-Users can trust in the safety of data about them and the legitimacy of Relying Parties.
Relying Parties can use digital identity data with confidence.
All parties realize the benefits articulated in this paper.

The proposals herein are organised according to the best practices set out in the Open Identity
Exchange’s (OIX) 2017 guide28 (see Figure C.1 below). As referenced in Figure 7 (above),working groups will convene to further develop this framework from now until early 2022.
Figure C.1 - Contents of the GAIN Trust Framework

Adapted from the OIX “Trust Frameworks for Identity Systems”

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C.1 Glossary and Key Roles
Principle GAIN Actors

Definition“GAIN Board of Governors”

the independent board that oversees the network and ensures that it
successfully delivers targeted benefits to other parties in the network“GAIN Operator”

the legal entity responsible for delivering the Core Technical Services(as defined below).

"End-User"a natural person and the data subject wishing to have the Identity
Information Provider share identity related data with a Relying Party.

“Identity”

set of attributes related to an entity[SOURCE] ISO/IEC 24760-1“Identity Information”

set of values of attributes optionally with any associated metadata in
an identity[SOURCE] ISO/IEC 24760-1“Identity Information Provider”

an entity that makes available identity information[SOURCE] ISO/IEC 24760-1“Relying Party”

organization that consumes Identity Services via the GAIN for the
purpose of providing services to an End-User.

“Service Provider”

a legal entity that assists a Relying Party in participating in the GAIN
(similar to an acquirer in a credit card scheme).

“GAIN Member”

any Identity Information Provider, Service provider or Relying Party
that participates in GAIN.

“Trust Network”

An existing network or scheme, such as BankID Norway, BankID
Sweden, Finnish Trust Network, iDIN, itsme®, NemID, yes®, etc.,that connects an Identity Information Provider to the GAIN or acts as
an Identity Information Provider itself. Such networks are also
required to comply with the GAIN rules.

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Note that a Relying Party is legally connected to GAIN via a Service Provider. In particular, theService Provider signs up to GAIN and ensures, through suitable contractual arrangements, that
the Relying Party (i) receives all relevant information for participating in the GAIN, and(ii) agrees to comply with the GAIN Rules. It is responsible for the Identification (as defined
below) of the Relying Party in accordance with applicable regulatory requirements, which mayvary depending on use case, region, etc. It will further ensure that the Relying Party fulfils theparticipation criteria (see “GAIN Rules”) for the duration of its participation in the GAIN.
If a GAIN Member outsources technical services to a third party (such as a technical service
provider), such third party shall act under the responsibility of the GAIN Member, e.g.,
outsourcing partner, data processor, etc. It will (in such a role) not have any contractual
relationship with GAIN.

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C.2 Governance, Principles, and Trustmark
To deliver the Trust Framework requires the oversight and management of a governing body.
This paper proposes a “GAIN Board of Governors” responsible for maintaining and evolving theTrust Framework as required. This will include the definition of appropriate ‘checks andbalances’ governing the system, including the governors themselves.
Table C.2: Proposed Principles Underlying the GAIN Trust Framework
Proposed Principle

GAIN Requirements

End-User
Convenience

Adoption (by both End-Users and Relying Parties) will depend upon End-User convenience.
The GAIN ecosystem ensures that End-Users interact with trusted Identity Information
Providers, a familiar interface, and a simple process that connects them to services acrossthe internet.

End-User Control
and Choice

End-Users have control of their data. They may choose who they are shared with and how
long for (purpose limitation). They also choose the Identity Information Provider involved.
GAIN transactions are always initiated by End-Users.

Minimal Disclosurein view of Use Case
& Recipients

Identity Information Providers share data directly with Relying Parties: Neither the GAIN nor
any third party have access to End-User Data. Furthermore, Relying Parties can choose torequest only the minimum required for their use case. End-Users will have control overwhether to share each attribute.

Interoperability

Technological Interoperability: The GAIN is designed to integrate with a variety of legacy
infrastructures and identity solutions. See Appendix D for a deeper dive into technicalinteroperability.
Legal Interoperability: The GAIN Rules will be codified in contracts that provide sufficientlegal certainty as to participants’ duties and obligations and ensure enforceability. They will
also facilitate liability risk allocations and assessments as needed. To ensure cross-borderharmonization, these rules will be designed so as to minimize the applicability of certain
existing legal and regulatory obligations in some jurisdictions.

Trust

A key to trust is the assurance that the relevant other parties are real, identifiable, and canbe held accountable for their actions in the context of the GAIN. As such, authentication andidentification are always required when interacting via GAIN - for any GAIN Member and
End-User.

Ecosystem

GAIN sets the basis for an ecosystem by defining the “trust framework” or general “rules of
the game” incl. standardized and harmonized legal (incl. Data Protection) and technicalrequirements (e.g., API standards). Within this trust framework, GAIN allows its participants
to bring opportunities to the financial world, to work with new organizations and to provide toconsumers new and innovative solutions. New compliance and governance measures are
created to ensure that organizations can protect End User’s privacy and support End Users
to get the value out of their data.

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C.3 Trustmark & User Experience
A recognizable button or brand identifier (the GAIN brand is to be determined) will let End-Users
know that they can initiate a transaction via a trusted environment where the GAIN Rules apply.
This button will be positioned on the Relying Party’s website, mobile application or other entry
points.
The End-User will then choose their Identity Information Provider and authenticate via that
Identity Information Providers’ digital channel. If the End-User chooses a Trust Network, they
will be directed accordingly, and any further steps will be defined by the standards of that
Network.
The End-User will have an active role in any transaction and the process will take place within
their trusted Identity Information Provider’s environment. They request that the Identity
Information Provider share relevant data with the Relying Party and the Identity Information
Provider does so in execution of their contractual obligations (see also below under ‘Data
Protection’).
Note that GAIN establishes the link between the Identity Information Provider and the Relying
Party based on the End-User’s choice. However, End-User data is passed directly between
Identity Information Provider and the Relying Party without passing through any GAIN
components.

C.4 Identity Service
The following data should be available via the Identity Service:●

End-User Authentication level & methods, such as: Provider Login 1FA; Provider Login 2FA withphishing resistance based on EBA RTS on SCA29.

●

Digital Identity Data, such as: Email; Phone; Address; Given Name; Family Name; Place of Birth;
Date of Birth; Nationalities.

●

Verification and/or Validation Data and Attributes such as: Evidence used; date/time of data
verification and validation; expression of various standardized LOA scoring; etc.

An Identity Information Provider must enable other GAIN Members, in particular Service
Providers and Relying Parties, to rely on the result of the authentication procedures provided in
the context of a GAIN Service. They must provide an End-User authentication method thatcomplies with the applicable local legal and regulatory requirements. It will provide a Strong
End-User Authentication if and to the extent required by law or the Relying Party. It must haveappropriate security measures in place to protect the confidentiality and integrity of the personal
data of the End-User.

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The Identity Service (including End-User data) is exchanged directly between GAIN Members
without the GAIN Operator or the GAIN Board of Governors coming into possession of the EndUser data. Neither the service of transmission of data nor the data themselves originate fromGAIN (or any GAIN entity) and therefore cannot be checked by GAIN (or any GAIN entity) for
their legality, correctness and/or completeness.
A Relying Party that consumes the Identity Service, shall be obliged to use the obtained EndUser data only for the intended purpose in accordance with the GAIN Rules and, in particular,
shall not transfer the rights to such data to third parties unless such transfer takes place inaccordance with the applicable statutory provisions (e.g., on order or with consent of therelevant beneficiary, generally the End User).

C.5 Member Services
When on-boarding, GAIN Members will need to provide various details, and these will need tobe verified to ensure that they are the entity they claim to be and that they fulfil the requirements
to become a member of the network in whichever roles they request. Once this has been
completed, they are able to begin transacting and are able to use Core Technical Services (seebelow under Core Technical Services) to ensure that they are interacting with other authorized
GAIN Members.
Member Services will also allow on-going management of the service by GAIN Members,
whether that is maintaining up-to-date information about the entity, managing fees, orwithdrawing from the service.

C.6 GAIN Rules
The “GAIN Rules” are governed by the GAIN Board of Governors. The GAIN Rules are thegeneral terms and conditions, applicable for any role, business and use case within GAIN.
Being agreed on contractually, the GAIN Rules shall be applicable independently of thejurisdiction and applicable law of the GAIN Member. The GAIN rules may reflect statutory
requirements for certain so-called “Regions”, such as Europe Region, United States Region,
Middle East Region, Africa Region, Asia Region, etc.

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Figure C.6: The GAIN Rules

C.7 Participation Fundamentals
In order to participate in the GAIN, each GAIN Member must be identified and authenticate itself(the "Identification"). The level of identification depends on the GAIN Services provided or
consumed. The consummation of certain GAIN Services may require the verification andvalidation of the business identity of the GAIN Member in accordance with applicable regulatory
requirements, such as AML, eIDAS or other regulatory requirements.
The GAIN will be organized as a license model (similar to a credit card scheme), i.e., a
GAIN Member receives from the GAIN Board of Governors a license to participate in the GAIN
and to provide or procure GAIN Services. Further, licenses may be granted, e.g., to use certain
components provided by the GAIN, which enable a GAIN Member to establish a connection toother GAIN Members for the exchange of GAIN Services, incl. service configurations,directories etc., to implement APIs according to the technical requirements of the GAIN or touse relevant IP, trademarks etc. necessary for the participation in GAIN.
Potential GAIN Members may onboard via a standardized onboarding process where they
accept the GAIN Rules and identify according to the requirements of the role they take within
the network and/or the relevant GAIN Services they intend to offer or consume.

C.8 Technical Fundamentals
The GAIN will provide a sandbox for testing purposes. Any technical integration, includingchanges to an existing integration or additions to a new integration (e.g., in the case of new
GAIN Services) shall be tested in such sandbox before activation.
Core Technology Services are the subject of Appendix D.

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C.9 Monitoring and Compliance Fundamentals
To maintain trust, compliance with the GAIN Rules will be monitored. Defined evidence ofcompliance and controls should be presented on a periodic basis and on request. Wherever
possible, monitoring will be automated, this will be appropriate for verifying conformance totechnical specifications and delivery of performance and availability requirements. Verification ofcompliance with other GAIN policies will be monitored through the use of periodic audits with
reporting of status in a structured fashion. Key data points derived from the monitoring regimen
will be made available to all members of the network.
If a GAIN Member does not comply with the GAIN Rules, it is the role of GAIN to take actions
and, as the case may be, sanction such a GAIN Member. Such sanction measures may be:
●
●
●
●
●
●

warning of the GAIN Member;
restriction of the GAIN Member's rights under the GAIN Rules;
revocation of the GAIN Member's special status (e.g., as Identity Information Provider or Relying Party);
temporary blocking of the GAIN Member;partial or even complete withdrawal of the GAIN Member’s rights under these GAIN Rules;
definite blocking of the GAIN Member.

C.10 Salient Legal Aspects
C.10.1

Liability

Liability risk is a key concern for all participants in GAIN, regardless of their role (Identity
Information Provider, Relying Party, GAIN Operator, GAIN Board of Governors, etc.), although
the extent of such risk will vary by role. Generally, a participant in GAIN can be liable (i.e.,
legally responsible for paying damages to compensate others, including nonparticipants)
whenever that participant is in some way “at fault” or “responsible” for a loss suffered bysomeone else. This occurs whenever a participant breaches a legal duty it owes to someone
else to act (or to refrain from acting) in a certain way, thereby causing the loss.
Those legal duties, that can be used to form the basis of a participant’s liability, come from threesources:1.
2.

3.

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Existing general law in each applicable country with jurisdiction over the transaction (e.g., contract law,
privacy/data protection law, tort law, antitrust/competition law, tax law, banking law, etc.);
New/developing identity system law, if any, enacted in each applicable jurisdiction to specifically govern
identity systems generally (e.g., the Virginia Identity Management Act, the draft UNCITRAL identity
management rules, etc.); andContract-based system rules developed to govern the participants in an operation of GAIN (e.g., often
referred to as a trust framework, scheme rules, operating rules, governing rules, etc.).

The first two sources of these legal duties are statutory or regulatory, will likely vary from one
country to another, and are largely outside the control of GAIN. Laws governing privacy/dataprotection, consumer protection, and limitations on certain damages (e.g., that you cannot
disclaim damages involving personal injury) typically fall into this category. Thus, participants in
GAIN will be subject to whatever liability risks are imposed by these two sources of legal duties.
However, in many cases, other legal duties imposed by law or regulation can be modified or
supplemented by the third source of legal duties – i.e., by contract-based system rules to which
all participants agree to be bound. The GAIN Rules will be that contract-based set of system
rules that will govern GAIN, will be unique to GAIN, will seek to clearly define theduties/obligations of each participant in GAIN, and will allocate the liability risk between andamong them.
Because the GAIN Rules govern the operation of the network, they provide a vehicle tostructure the network in a manner designed to minimize the applicability of some existing law(e.g., by avoiding activities subject to regulation). At the same time, by defining the legal duties
imposed on each participant role (which, of course, will be a key source of liability if breached),
the GAIN Rules will provide a fair degree of legal certainty as to the duties imposed on eachparticipant role, and facilitate liability risk allocations and assessments as needed. Further, inthe event a legal duty is breached by a participant, the GAIN Rules can be used to allocate
liability among the participants involved (e.g., through exclusions or limitations on liability, if
appropriate) in a manner that works best for that network.
Of course, all participants in the network would prefer a total exclusion of all of their liability risk.
But as a practical matter, liability is a zero-sum game. That is, if someone suffers a loss, if theliability of the participant whose breach of duty caused the loss is excluded or limited, that
doesn’t eliminate the loss, it merely shifts the loss on to someone else. Thus, the GAIN Rules
will be the vehicle by which liability risk is allocated and equitably shared among the relevant
participants.

C.10.2

Data Protection & Policy

The End User shall always stay in control over personal data about them. To achieve this, anytransfer of the aforementioned data shall only be initiated by its explicit choice, i.e., on order ofthe End User itself. Due to this, the necessity of consents and the complications which arise
from them - e.g., by terms of the GDPR - could be omitted. Instead, any transfer of data is
performed as an action for performance of contractual obligations without the need of any dataprotection consent.
Neither the GAIN Board of Governors nor the GAIN Operator will process or persist any
personal data of End Users at all. Instead, any personal data transfer will take place directly
between the GAIN Members. By doing this, on one hand it is possible for each GAIN Member toact on their own responsibility in terms of data protection, i.e., each GAIN Member is individually

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responsible for fulfilling its own data protection related regulatory requirements towards the End
User, such as properly informing the End User on its privacy policy.
Further, the need for data processing agreements and pitfalls like shared or undefined
responsibilities will be avoided. On the other hand, it helps to keep the End User in full control of
its personal data, as such data is only shared between the relevant parties without involving
third parties in the data transfer.
Finally, it also avoids the risk of the GAIN Board of Governors or the GAIN Operator posing athreat to the GAIN Members, e.g., by collecting End User data enabling them, at some point, toprovide the Identity Service itself.
Due to the fact that each GAIN Member acts on its own responsibility in terms of data protection
and is regulated by different supervisory agencies, it is crucial that GAIN establishes aframework, which enables GAIN Members to choose in which regions or countries they decideto act and which level of data protection they intent to provide or consume (e.g., GDPR, LGPD,etc.). For example, an Identity Information Provider or Relying Party submitted to the GDPR
wants to exclude all regions and countries from interaction which are not under jurisdiction of
the GDPR or are not determined by the European Commission to ensure an adequate level ofprotection by reason of their domestic law or of the international commitments they haveentered into. In consequence, a foundation for the differentiable international usage of personal
data and corresponding services could be built on a regulatory sound basis, including
requirements for a high protection level for personal data. This is necessary as GAIN is a trust
network which cannot afford to lose the trust of any of its involved parties due to an insufficient
protection of personal End User data.

C.10.3

Regulatory Framework(s) & Requirements

For GAIN to operate globally, it is crucial that GAIN itself avoids providing any regulated
services. While GAIN Members may provide to the End User regulated services within their preexisting licenses, the GAIN cannot provide any of such services – otherwise, GAIN would lose
its flexibility in operating globally.
Since GAIN plans to operate outside the scope of the current regulatory landscape, it isimportant to design its services in such a way that the regulatory scope of national andinternational laws is not applicable. Money remittance businesses, payment initiation services(PIS) and account information services (AIS) are typically subject to banking, financial or
payment services regulation requiring such license. GAIN will therefore avoid providing theseregulated services.
Stepping outside of regulations, GAIN needs to clearly define its role within the ecosystem. As
already mentioned throughout this Whitepaper, GAIN will to take the position of rule/standard
setting entity without involvement (other than, as the case may be, enablement of technicaltransmission) in the services provided by GAIN Members.
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C.10.3.1 Regulation of billing and clearing
It is important that GAIN Members can be remunerated for their services without the GAIN being
required to obtain a license or be subject to additional regulations. Billing and clearing of theclaims between the GAIN Members needs to be implemented within the GAIN Rules. Money
remittance businesses, however, are a regulated activity in many jurisdictions (e.g., as payment
service under European PSD2 or with regard to AML/CTF law in Australia).
Typically, the regulatory frameworks on money remittance regulate a transfer of funds asintermediary. In many jurisdictions, it is not required that a bank account is maintained but theregulation captures traditional money transfer companies as well as modern platformbusinesses taking care of the payment process.
GAIN will be organized as a license model (see also above under GAIN Rules). This will interalia allow GAIN to stay in the payment flow and at the same time avoid any regulation in relation
to the transfer of funds (i.e., money remittance business).

C.10.3.2 Regulated services of GAIN Members
GAIN Members holding sufficient licenses or regulatory approval can provide their regulated
services to the End User. In those cases, it must be clear that the GAIN Member is responsible
for obtaining and maintaining such license and that the GAIN Member is the only one
responsible for complying with any regulatory obligation. There must be a provision in the
GAIN Rules that the GAIN Members are not allowed to provide regulated services via thescheme if not holding relevant licenses.
If GAIN wants to implement certain services via its scheme by assigning certain roles, it should
limit its involvement to technical services as a maximum. Banks and other regulated entities
may wish to provide various services (e.g., account information services and payment initiation
services) using GAIN. While it might be possible to communicate such capabilities via the GAIN,
it will only be enabled in a way that does not result in additional regulation or requirement forlicensing for GAIN itself.

C.10.4

Interoperability Requirements

The intention of GAIN is that it provides interoperability across jurisdictions and industry
verticals and relying parties will be able to use the digital identity data to enhance their user
propositions. Interoperability is one of the primary enablers that GAIN will deliver. It allows
parties from across the network to easily connect with one another and understand the context
within which the data is provided.

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There are three pertinent domains of interoperability that are all needed within GAIN for the full
benefit to be realised and for members to readily use the data available:

C.10.4.1 Policy and Procedure
When relying upon digital identity data it is necessary to have an understanding of the context
within which it was collected, maintained and provided. The policies and procedures that are
applied by a provider are of interest to a relying party because they allow the relying party to be
assured that the digital identity data is of a level that is (or is not) adequate for their purposes
and whether it fits within the local regulatory requirements. Aligning and being able tocommunicate the policies that were applied adds important context to the digital identity data
provided. Examples of this might be details of the legal requirements that were used whencollecting identity data or how identity verification is performed by a specific provider and thelevel of assurance score that was assigned to the digital identity by the provider (e.g., a digital
identity may be proofed under NIST SP 800-63A).

C.10.4.2 Data and Metadata
When data and metadata are exchanged between parties it is important that they are properly
understood by the relying party and that they are consistent across providers. Attribute names
and meanings need to be standardized in order that relying parties can integrate provided
attributes with their use cases.

C.10.4.3 Protocol
Interoperability at a protocol layer is required to deliver a service that is easily and cheaply
integrated for relying parties resulting in greater appetite for the use of GAIN and a quicker time
to value for all parties involved. The details of the protocol interoperability will be discussed
further in the Architecture blueprint.
As part of the GAIN rules providers will be expected to meet standards for interoperability,
performance and availability in order that an effective interoperable network is maintained. Aspart of GAIN membership there will be a requirement for monitoring of conformance to thosestandards. The required monitoring will use automated mechanisms wherever possible and will
be delivered as one of the GAIN core technical services. Where automated monitoring is notpossible periodic audits will be required.

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C.11

Core Technical Services

GAIN provides each GAIN Member with various components that enable the GAIN Member toestablish a secure connection via GAIN (collectively, the “Core Technical Services”; cf. also therelevant Technical Requirements). Further details of these services are expressed inAppendix D.

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Appendix D - Draft Technical Architecture
D.1 Overview
This Appendix describes the draft technical architecture of the GAIN and comprises of●●●

Stakeholders List;
Stakeholder concerns and its mapping to architecture views; andArchitecture views.

“Stakeholder concerns” are the drivers of value that the architecture should address for different
actors in the ecosystem. An Architecture View expresses the Architecture of the GAIN from theperspective of one or more Stakeholders to address specific concerns. They are addressed byat least one architecture view (Table D.1).

D.2 Stakeholder Concerns of the GAINIn GAIN, there are five principal stakeholders:
1.
2.
3.
4.
5.

End-User,
Relying Party,
Identity Information Provider,
Service Provider, andGAIN Entity.

In addition to those principal stakeholders, GAIN
recognize the following as important stakeholders:●●●

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Civil Society
Regulators
Investigators and Prosecutors

Table D.1 outlines the stakeholder concerns derived from the source of the benefits articulated
in this document. The remainder of Appendix D will provide ‘views’ in which those concerns are
addressed. Note: as working groups and proofs-of-concept continue, more requirements andnuances will be identified.
Table D.1: Projected Concerns of the Principal Stakeholder
Stakeholder
End-User

Stakeholder Concerns

Corresponding Views

Secure way to share data

Data Flow View

Simple, convenient experience

End-User Experience View

Selective control over what data is shared

End-User Experience View & Data
Flow View

Trust in the legitimacy of Relying Parties

Operations View & Data Flow View
Relying
Parties

Securely access End-User identity data and services

Data Flow View

Ability to evaluate the level-of-trust for any given
attribute

Data Flow View
Operations View & Data Flow View

Broad reach of End-Users without requiring acontract with individual Identity Information Providers

Identity
information
Providers

GAIN

Simple, uniform End-User experience to optimise
conversion and servicing efficiency

End-User Experience View

Better service to its customers providing assured
space to transact

End-User Experience View

Flexibility to implement a solution that aligns withgoals and local context

Data Flow View

Transparent information about

Data Flow View

● when and how Relying Parties were on-boarded● when Relying Party keys were registered andretired● when the attribute Provider keys were registeredand retired
Controlled onboarding of Relying Parties
Provide Identity Information Provider Chooser
Service
Providers

Streamlined integration
Customer support
Flexibility to implement a solution that aligns withgoals and local context

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End-User Experience View

Data Flow View

D.3 Architecture Views
D.3.1 Overview
This section explains various aspects of the GAIN architecture through the following views:●●●●

End-User Experience View
Data Flow View
Operations View
Privacy View

Each view addresses some of the concerns expressed in the Table D.1. It should also be notedthat each concern may be addressed by multiple views.

D.3.2 End-User Experience View
End-Users in GAIN will enjoy the use of the Identity Information Provider of their choice in GAIN
rather than being forced to create accounts at each Relying Party. Using their chosen Identity
Information Provider, the End-User will be able to share attributes selectively, present assured
attributes, and monitor where their data is shared to and for what purposes.

D.3.2.1 Identity Information Provider Chooser
Leveraging the Identity Information Provider Metadata Directory, Relying Parties can provide auser interface from which the End-User can choose their desired Identity Information Provider.

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Figure D.2: The Identity Information Provider Chooser allows an End-User to search and picktheir Identity Information Provider at the Relying Party

The Relying Party will remember which Identity Information
Provider the user has selected so that subsequent visits by the
End-User can skip the Identity Information Provider filtering andcan directly choose the preferred Identity Information Provider.

D.3.2.2 Selective Data Sharing
In the GAIN, Relying Parties are expected to adhere to theprinciple of collection limitation and purpose limitation. RPs will
utilize the fine-grained attribute request capability of OpenID
Connect to only collect the attributes needed for the purpose. The
purpose will be presented to the End-User as recommended by
ISO/IEC 29184 Online notice and consent (2020) using a layered
approach.
Figure D.3: Selective attribute sharing
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D.3.2.3 Privacy Dashboard
Participating Identity Information Provider in GAIN will provide a dashboard from which the EndUsers can find out easily where and which data has and is being shared for what purpose andhow. End-Users can review where data has been shared and stop any persistent sharing fromwithin the Identity Information Provider Dashboard.

D.3.3 Data Flow View
Data Flow View provides how the Information including user and administrator direction flows
and stored among the roles to be implemented in GAIN.
Figure D.4: Data Flow in the GAIN
Decentralised Provider
Metadata Directory
National registries
IdP Metatdata for‘chooser’ and IdP
communications

Registration with Regulated Entity
check by the scheme

Attests
attributes that it
is authoritativefor.

Attribute
Provider

s
ut e

Data
Request /Responset es ntrarib u
At t ring gsha

Identity
Information
ProviderEnd User

Data
Request /Response

Service
ProviderAttribute Provider
may be operated by
Identity Information
ProviderRP metadata

Decentralised Relying Partynt
ras
te g gb u int ri ss
At oc eprib
at t randt ion tcunodra
Int r ring g
sha

Similar toacquirer incard payment
networkProv
On id esAb oa
rd in t t est at iogRelying
Party

n fo

r

Service Resource Admin

A Relying Party
can serve other
Relying Parties
as TPP

Registration with Service provider
Attestation to achieve ‘registeronce’ for RP and ‘only trusted RPs
in the network’ for End Users

National registries

Metadata Directory

Note: RP Onboarding requirements may differ from jurisdiction to jurisdiction and it probably
requires multiple levels of identity proofing and verification.
●●

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End-User: End-User is a role primarily performed by individuals and is the central role in the GAIN. They
are authenticated by User-AuthN and control how and where their data is being shared and used.
Service Provider: It is a role that performs initial authentication (identity proofing) of the Relying Party andprovides standardized attestation which Relying Parties can take and provide to the Relying Party Metadata
Directory. This role is typically played by a regulated entity that has a requirement for identity proofing of the
Relying Parties as their customer. It○ implements the management system to achieve the assurance level expressed in the attestation;○ support mapping of the Relying Party to a Legal Entity Identifier (LEI)30 and a verifiable LEI (vLEI)31
in partnership with the Global Legal Entity Identifier Foundation (GLEIF)32; and○ support issuing the attestation in the standard format adopted by GAIN that include the information
above.

●

●

●

●

●

Identity Information Provider: This role authenticates the End-User, enables End-User to selectively share
their data with the Relying Party along with the End-User Authentication result. The data shared may belocally sourced or collected from external Attribute Providers. This role is sometimes called “Consent
Manager”. This role
○ supports Secure Customer Authentication;○ provides information about level of assurance and the trust framework used;○ provides data in the form Aggregated or Distributed Claims or as a verifiable presentation;○ Communicates information via either ID Token or UserInfo endpoint (in the first standard interface)○ supports Grant Management to allow Relying Parties to manage individual grants; and○ provides a dashboard on where and what data was shared to End Users.
Attribute Provider: It is a role that provides attested End User attributes at a certain level of assurance.
This role could be played by an Identity Information Provider or an independent party. The attestation○ supports proof that enables the receiving party to verify the provenance and assurance level of thecontained data as well as whether the attestation was tampered or not. Format envisioned to be
used in this respect is JWT as in OpenID Connect and W3C Verifiable Credentials.
Relying Party: Is a role that relies on the End-User authentication result (Authenticated Identity, e.g., ID
Token) and other data provided by the Identity Information Provider and Attributes provider roles. It typicallyserves End-User by utilizing the data but it can serve other entities and might not have direct interactions
with End-Users. Relying Parties○ implement Dynamic Client Registration to register to the Relying Party Metadata Directory using
Attestations provided by its Service Provider;○ implement OpenID Connect for Identity Assurance to receive Authenticated Identity to receive data;and○ Implement OAuth Grant Management to request fine grained authorization.
Service Resource Admin: It is a role that manages the access to the resource at the corresponding
Relying Party. Its decision depends on multiple factors including but not limited to the payment status by the
End User.
○ Provider Metadata Directory: It manages the metadata such as keys and endpoints of Identity
Information Providers, Attribute Providers, and Service Providers in GAIN. It will also maintainwhen the Provider keys were registered and retired. It will maintain the historical data as well. The
data contained in it will be used for Identity Information Provider Discovery and Chooser.
Relying Party Metadata Directory: It manages the metadata such as keys and endpoints of Relying
Parties in GAIN. It supports Dynamic Client Registration coupled with Attestation from the RP-AuthN role. It
will provide○ when and how Relying Parties were on-boarded and○ when Relying Party keys were registered and retired as well.
The data is used for RP Discovery and makes it possible for an RP to register only once to the network andbe identified by all the Identity Information Provider in GAIN.

D.3.4 Operation View
GAIN will complement the existing and future financial services as needed, e.g., it will provide
trust management, Registration, Discovery, Trust Management, Support, and (optionally) Billing(optional), and as well as Analytics Support.
●

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Registration: the GAIN provides new members a single registration interface with one or more processes
for establishing the validity of the applicant organization. Options that will be elaborated in the design will
include using attestation from the organization’s banking provider and, in partnership with the Global Legal
Identifier Foundation (GLEIF)33 use of the Legal Entity Identifier (LEI)34 and the emerging verifiable LEI(vLEI)35. By registering just once with a strongly assured organizational identity the registration service will

●

●

●

●
●
●

●

●

●

enable access to every Identity Information Provider in GAIN. The same applies to the client (RP)registration, this time with its own attestation.
Discovery: the GAIN provides bank selection and discovery functions for technical details (e.g., endpoints).
Authorization and access to APIs is performed directly between the recipient and the respective service
provider. The user will see a Identity Information Provider selector dialog, when engaging in an identity
transaction, as depicted in the screens in chapter 2. It is also planned that RPs will be able to request afiltered list of Identity Information Provider based on some conditions such as geography, jurisdiction, or
capability.
Trust Management: the GAIN provides the necessary functions to enable participants to establish secureconnections by way of provisioning of technical details to the scheme participants, e.g., recipients areprovided with the endpoints of the Identity Information Provider and all registered enterprises are provided
with the technical details required to identify, authenticate and authorize each other. This is supported by aprocess of verifying and monitoring the status of GAIN members to ensure their on-going compliance with
network rules and responsibilities.
Monitoring and testing: Interoperability among the different deployments in the scheme is achieved via
effective delivery of standardized APIs and protocols. Conformity to the respective standard will be tested
periodically. Availability and performance will also be monitored to ensure the agreed thresholds are met
and that effectiveness of the network is not compromised.
Risk information sharing and coordination: The scheme provides a uniform interface to share attack andcompromise information in real-time.
Support: The scheme defined the support model for end-users, relying parties and Identity Information
Providers.
Dispute resolution: In the case of dispute, the concerned party may invoke a dispute resolution process via
GAIN. This may include re-identification of the party that was anonymous or pseudonymous to theconcerned party or some liability being taken by the provider
Billing: Optionally the service providers can utilize the scheme as a billing engine by providing records
about provided data and successfully performing service requests to the scheme as a basis for invoicing andsettlement.
Analytics: improving the performance of the scheme requires deep understanding or usage patterns acrossall participants of a certain use case. Optionally the scheme could collect and distribute analytical data
among the scheme participants in order to facilitate this process.
Integration: For existing deployments, there is the option to build an adaptation layer to bridge existing
service implementations to the common technical interface. Building an adaptor for a specific deployment
allows for flexibility that takes into account the design and capabilities of the respective deployment.

D.3.5 Privacy View
End-User privacy is protected through multiple layers of measures in GAIN. In this document,
we will just point out some notable features.

D.3.5.1 Partial Anonymity and Pseudonymity
Although all the End-Users have been through some level of identity verification, creating anassured identity, it does not mean that End-Users must always be broadly identifiable. In day-today transactions, the principle of minimum disclosure will be followed and End-Users canremain anonymous or use pseudonymous with the Relying Parties and Services if the use caseallows.

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However, in the GAIN, when there is a dispute or evidence of criminal activity, there will be aprocess to link the anonymous or pseudonymous transactions to the End-User by a special
entity called ‘Designated Opener.’ The concept is defined in ISO/IEC 29191 Requirements forpartially anonymous, partially unlink-able authentication.
Figure D.5: De-anonymisation in GAIN

Identifeir : UID.x2351aover18: True
Passport Valid: True
TxnReference: 2396312

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Accesses a service

Name : Mary-Jane
DOB: 1970-07-18
Passport Expires: 2026-03-22
Place of birth: Dublin

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Disclaimer
This paper represents a collaborative effort among professionals within the identity space toauthor a White Paper highlighting the unique opportunity the global financial services sector canplay in catalysing a collaborative solution to society’s digital trust challenges However,statements made in this paper do not necessarily reflect the personal view of each contributor orthat of their respective employer and/or client(s).

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