Please note: The algorithm descriptions in English have been automatically translated. Errors may have been introduced in this process. For the original descriptions, go to the Dutch version of the Algorithm Register.

Facial comparison for identity verification

A tool that assists counter staff in verifying a person’s identity by comparing the face of the person presenting themselves with the photograph on an identity document. Helps to prevent look-alike fraud.
Last change on 14th of July 2026, at 6:25 (CET) | Publication Standard 1.0
Publication category
Other algorithms
Impact assessment
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Status
In use

General information

Theme

Organisation and business operations

Begin date

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Contact information

datalab@emmen.nl

Responsible use

Goal and impact

The algorithm assists the counter staff member in comparing a live facial image with the photograph on an identity document. The staff member is shown an indication and, where applicable, a comparison score, on the basis of which they can assess whether the person and the document match. The aim is to prevent identity fraud (such as look-alike fraud) and to strengthen the reliability of data in the BRP.

Considerations

The algorithm is a tool that supports visual checks. It helps to ensure accurate identity verification without replacing human judgement.

Human intervention

The employee decides for themselves whether to use the facial scan and assesses the result. In case of doubt, a colleague is consulted (four-eyes principle).

Risk management

No biometric data is stored. The entire facial comparison is carried out locally within the secure municipal infrastructure; no biometric data or other data is transmitted via the internet or stored externally. The facial comparison is temporary and visible only to authorised staff. The application is standardised for all citizens and includes access controls, thereby limiting the risk of profiling or unlawful processing.

Legal basis

BRP Act, Article 2.67(4); BRP Decree, Article 35; UAVG, Article 29 – the use of biometrics is permitted where authentication is necessary.

Links to legal bases

BRP Act, Article 2.67(4); BRP Decree, Article 35; UAVG, Article 29 – the use of biometrics is permitted where authentication is necessary.: https://wetten.overheid.nl/BWBR0033715/2023-10-01#Hoofdstuk2

Operations

Data

Live image of the individual and the image from the identity document (e.g. photo on the chip or MRZ).

Technical design

The algorithm uses facial comparison based on deep learning technology. The software is integrated into the counter application and utilises underlying APIs (e.g. C++, Java, .NET, BioAPI 2.0). A comparison score is generated and no biometric data is stored. Processing takes place locally.

External provider

Oribi B.V.

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