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Gaps & Risks — Honest Disclosure

Consolidated view of every requirement where SABLE is Partially Compliant today, what remediation is needed, and what timeline.

Certifications & accreditations (largest gap cluster)

IDGapRemediationEffort
LV-5 / LV-6No ISO/IEC 30107-3:2023 EAL-2 (Level B) third-party PAD test report yetEngage an ILAC-accredited PAD testing laboratory; no lab arrangement in place at RFI stage3-4 months elapsed; ~AUD 60-100 k spend
SC-1Full ISM / Essential 8 compliance evidence not yet produced for SaaS shellBuild SaaS to ISM controls from day 1; engage IRAP assessor6-8 months elapsed (overlaps with SC-6)
SC-6PROTECTED-level IRAP certification not yet heldEngage IRAP assessor; remediate findings; cert at PROTECTED6-8 months elapsed; ~AUD 150-250 k spend
OP-9No NV1-cleared Australian support staff today; no subcontractor arrangement in placeSponsor founder NV1 clearance + subcontract via an Australian Security Vetting Agency–cleared support partner12+ months for direct NV1; immediate via partner once contracted

All four are standard procurement-stage activities in Australian federal identity tech — none are blockers. The RFI explicitly notes evidence is not required at this stage; we acknowledge the work is needed and commit to completing it inside any second-stage timeline.

Technical gaps with clear remediation

IDGapRemediationEffort
TV-1ICAO Doc 9303 ePassport PKI verification (with CRL checking) not in coreAdd via existing OSS libs (jMRTD wrapper, Apache Santuario for PKI); design slot exists in attestation module8-12 weeks dev
TV-3Quantitative FMR / FNMR not measured against ISO/IEC TS 19795-9 protocolRun formal benchmark against LFW / IJB-C / MS-Celeb-1M corpora; report at 90% CI4-6 weeks
IN-1Microsoft MAUI bindings not shipped (Android JNI / iOS Swift exist)Generate via cbindgen → C ABI → MAUI .NET bindings + sample app4-6 weeks
UX-3WCAG 2.1 AA audit not yet performedEngage an accredited Australian accessibility audit firm; remediate findings4-6 weeks
SC-3BLS12-381 not currently on ASD HACE catalogueEither (a) ASD HACE assessment / acceptance pathway, or (b) provide parallel ASD-approved cryptographic path (e.g. P-256 + SHA-256 classical-only mode) for environments requiring strict HACE compliance4-8 weeks for parallel path

Track-record gaps

IDGapCompensating evidence
IN-5SABLE specifically has no prior large-scale government deployments(a) Anuna’s current BARMM eGov programme — government identity, citizen services, advisory, production go-live July 2026 — is the most directly relevant delivery-capability reference (BARMM does not currently deploy SABLE; future deployment a candidate natural extension); (b) early international dialogue on the SABLE approach with Germany’s BSI; (c) adjacent: GovUK, CSIRO Data61, Microsoft, Autodesk, Suncorp, IAG, Telus, Telefónica, Kellogg, University of Wollongong — references available on request; (d) Tang et al. NDSS 2018 published methodology with academic validations; (e) offer of a paid Proof-of-Concept against ATO’s myID test cohort as the most decisive direct evidence for SABLE specifically
VISM-6No prior implementation of biometric identity systems in Australian federal government specificallyBARMM is direct government identity / eGov delivery by the same practitioner team (SABLE not yet deployed at BARMM); GovUK + CSIRO Data61 cover OECD public-sector posture; this would be Anuna’s first direct Australian federal identity engagement
OP-10First direct Australian federal government identity-system deliveryAs IN-5; BARMM (in production July 2026) provides the closest delivery-capability analogue — same practitioner team, same delivery shape; ATO would be Anuna’s first Australian federal engagement and SABLE’s first government deployment
OP-6(Re-reading Addendum 1 Q14: requirement is for organisational controls, not clinical assessment)Anuna has these — separation of duties, peer review, security-awareness training, privileged-access monitoring, incident-reporting runbooks. Now Compliant — see addenda-clarifications

Strategic risks (for ATO to weigh)

RiskMitigation
SABLE is pre-production; bugs / vulnerabilities possible(a) Open-source, fully auditable; (b) 519 tests passing with 89% coverage; (c) commitment to a security audit (e.g. Trail of Bits, Kudelski) before any production cutover; (d) phased PoC → pilot → rollout deployment model
Halo2 is a 2020-2021 cryptosystem; comparatively new compared to legacy PKIHalo2 has rigorous academic review; deployed at production scale by Zcash; transparent-setup eliminates the trusted-ceremony class of failures
BLS12-381 quantum-vulnerable by 2030-2035Post-quantum migration on the published roadmap (CRYSTALS-Dilithium signature path; hash-based commitment alternatives); ATO’s deployment timeline likely aligns with industry-wide PQ rollout
Anuna Research Cooperative is a small Australian company(a) Open-source codebase removes vendor-lock-in / business-continuity risk; (b) source-escrow agreement available; (c) partnership model with an Australian systems integrator acceptable for delivery scale if procurement warrants it (no such arrangement is in place at the RFI stage)

What this RFI is buying

The ATO is buying market intelligence and option value on innovative biometric solutions. SABLE’s distinctive value isn’t a 99 %-vs-95 % match-rate improvement — it’s privacy by construction, which the existing 2021-procured stack architecturally cannot offer. Even if the ATO ultimately proceeds with an incumbent for the SaaS reverification stack, SABLE’s on-device proof + selective-disclosure model is a strategic capability worth understanding for the next 5-10 years of Digital ID Act evolution.

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