ICCL's position on MyGovID and state identity

Published 2026-05-31Updated 2026-05-31By MyID Editorial

The Irish Council for Civil Liberties (ICCL) is the most consistent and active civil-society critic of MyGovID-adjacent state identity infrastructure. ICCL's position is not opposition to digital identity as such — it's opposition to specific design choices and to the way the Irish stack has accumulated functions without primary legislation. This page summarises ICCL's published position, why it matters, and what they're calling for.

Who ICCL is

The Irish Council for Civil Liberties is the leading independent human-rights organisation in Ireland. Founded in 1976, it works on a wide range of civil-liberties issues. ICCL's digital rights work focuses on data protection, surveillance, online safety regulation, and the use of state ID. ICCL is one of two main civil-society voices on Irish identity-policy debates — the other is Digital Rights Ireland.

What ICCL is concerned about

The ICCL position on the MyGovID-PSC-EUDI Wallet ecosystem can be summarised in five points:

1. The Public Services Card is a de facto national identity card

Ireland is one of a small number of EU countries that does not issue a national identity card. ICCL argues that the cumulative expansion of PSC use across non-welfare services has produced, in practice, exactly what an explicit national ID would produce — without the legislative process, public debate, or constitutional scrutiny an explicit national ID would have required.

2. The 2019 DPC findings on PSC have not been substantively addressed

The Data Protection Commission's 2019 investigation found that the Department of Social Protection's processing of PSC data was unlawful in several specific contexts. ICCL holds that the Department's response was partial compliance on easier findings while leaving the harder substantive issues (lawful basis for non-welfare use, indefinite retention of identity documents) effectively unresolved. The 2026 Social Welfare and Other Matters Bill, on ICCL's reading, makes the unresolved issues more acute, not less.

3. The Social Welfare and Other Matters Bill 2026 is overreach

The Bill expands the PSC's accepted uses to include banking, utility identification and age verification. ICCL has argued that this is a substantial change to the architecture of state identity in Ireland and should require primary legislation explicitly establishing a national identity card, with the public debate and constitutional scrutiny that would entail — not an amendment to social-welfare administration.

4. The planned MyGovID-based mandatory age-assurance app is unprecedented and disproportionate

Ireland is the first country planning to require its government-issued digital identity app for age assurance on age-restricted social-media content. ICCL has argued that requiring a state-controlled application as a precondition for accessing social media is structurally different from age verification by private vendors — it centralises identity assertion in a way that creates surveillance capacities and exclusion risks not addressed by the architecture's selective-disclosure design.

5. The EUDI Wallet rollout requires safeguards Ireland has not yet committed to

The EU Digital Identity Wallet, mandatory by end of 2026 for public-sector services and end of 2027 for private-sector strong customer authentication, raises real civil-liberties questions: how is selective disclosure actually implemented, what audit logs are retained, who has legal access to wallet-presentation records, how can citizens opt out without losing access to services. ICCL has called for these safeguards to be specified in primary legislation rather than left to administrative discretion.

What ICCL is calling for

Pause the planned mandatory MyGovID-based age-assurance app pending Oireachtas scrutiny.
Subject any expansion of PSC use to primary legislation rather than departmental decision.
Implement the substance of the 2019 DPC findings on PSC retention and lawful basis.
Specify EUDI Wallet civil-liberties safeguards in primary legislation, with statutory rather than administrative redress mechanisms.
Public, ongoing consultation on the architecture of state identity infrastructure — not a one-off Bill at the end of a long administrative process.

Where ICCL's position diverges from MyGovID's defenders

The Department of Social Protection, the Government, and the technology vendors involved generally take the position that:

The current architecture is lawful as it stands, with the DPC's substantive concerns addressed in practice.
The 2026 Bill is a codification of existing practice that makes life easier for citizens.
The planned age-assurance app uses selective-disclosure architecture that mitigates the surveillance concerns.
The EUDI Wallet is EU-mandated and Ireland is implementing it as required.

The substantive disagreement is therefore not "is the Government doing this" but "what level of safeguards is required for this scale of state identity infrastructure" — and that disagreement is a real one, not a technical detail.

Why this matters for ordinary users

You don't have to agree with ICCL's position to recognise that the architecture decisions being made in 2026–2027 will shape what state identity looks like in Ireland for the next two decades. The expansions are not easily reversible. The civil-society critique exists precisely to keep the architectural questions open during the window when they're still negotiable.

How to engage with ICCL's work

Read ICCL's published submissions and reports at iccl.ie.
Respond to Coimisiún na Meán and Oireachtas committee consultations directly. ICCL's submissions are the structural critique; individual submissions add weight.
If you support the civil-liberties work, ICCL takes member subscriptions; Digital Rights Ireland the same.
Write to your TD on specific Bill stages.

Where MyID stands

MyID is an editorial site, not an advocacy organisation. We document ICCL's position because it's the leading civil-society critique and the public conversation about Irish digital identity is incomplete without it. We don't endorse or oppose ICCL's specific recommendations on this page; our role is to make sure the position is accessible to people who want to understand it.