Government services: tax, licences, permits and benefits

Tax filings, licence renewals, permits and benefit claims are errands people would gladly hand to an agent. For most of them, agent-to-agent is a poor fit today. Government services rest on strong identity proofing of the person, representative schemes built for people and firms, and sign-in terms that bar automation outright. Agents can still help around the edges: public information, appointment booking and preparing what the person will submit.

How it works today

Identity proofing in the US. NIST SP 800-63-4, finalized in July 2025 and superseding revision 3, sets three scales. Identity assurance (IAL1 to IAL3) measures how confidently an applicant is tied to a real identity; IAL3 adds a trained proofing agent in an on-site attended session and at least one biometric. Authentication assurance (AAL1 to AAL3) runs from basic confidence to phishing-resistant cryptographic authenticators with non-exportable keys. Federation assurance (FAL1 to FAL3) covers how assertions are protected. IAL1 and IAL2 may use remote unattended, remote attended or on-site proofing; IAL3 must be on-site and attended.

Login.gov, the sign-in service offered to US agencies, verifies identity with a US driver’s licence, state ID or passport, a Social Security number checked against records, and a phone or mailing address, with an in-person option at participating post offices. Its enhanced verification adds a selfie and is certified at IAL2. Its Rules of Use strictly prohibit automated access, including automated account creation, authentication and form submission, and say the service is for human interaction.

Representation in the US. The IRS has two main forms. Form 2848 appoints a representative, and only individuals eligible to practise before the IRS may be named. Form 8821 authorizes any individual, corporation, firm, organization or partnership to receive or inspect tax information, but not to act or advocate for the taxpayer. Through Tax Pro Account, a professional can request authorization and the taxpayer approves it in their own online account. The IRS says only the taxpayer should log into that account and credentials should never be shared.

Identity in Canada. The Treasury Board’s Directive on Identity Management and its Standard on Identity and Credential Assurance define four levels of identity assurance and four levels of credential assurance, from little to very high confidence. Outside government, DIACC’s Pan-Canadian Trust Framework offers certification for digital identity services.

Representation in Canada. The Canada Revenue Agency lets taxpayers authorize a representative, who “can be anyone”, through Represent a Client using a RepID, GroupID or business number. Authorization happens online, or by Form AUT-01 for offline access by phone, mail or in person. Personal-account access comes in Level 1 (information only) or Level 2 (information plus certain account changes). The CRA’s terms say sign-in details must not be shared, bar scripts, robots, spiders and screen scrapers, and allow the CRA to suspend access for using them.

The agent-to-agent version

Illustrative. The parts that fit are the ones that need no identity: public program information and appointment booking. A person’s agent asks a licensing office’s agent:

{
  "jsonrpc": "2.0",
  "id": 1,
  "method": "SendMessage",
  "params": {
    "message": {
      "role": "ROLE_USER",
      "messageId": "msg-gv-1102",
      "parts": [
        {"text": "What documents are needed to renew a passenger vehicle licence in person, and what are the next open appointments at the Main Street office?"},
        {
          "data": {
            "service": "driver-licence-renewal",
            "office": "main-street",
            "window": {"start": "2026-10-05", "end": "2026-10-16"}
          },
          "mediaType": "application/json"
        }
      ]
    }
  }
}

1. The office’s agent returns the document list and fee from its published program rules, plus open slots.
2. The person’s agent holds a slot and completes the task with a confirmation number.
3. At the office, the person proves who they are in the way the office requires. The agent is not part of that step.

Everything past that line (filing a return, applying for a benefit, signing a declaration) either needs the person’s own sign-in or an authorized human representative.

What has to be true

Identity. Remote proofing at IAL2 and above is designed around the person presenting evidence of their own identity, sometimes with a live selfie. An agent cannot be proofed as the person. For agents to act on authenticated services, an agency would need to recognize the agent as a distinct, delegated party, and no US or Canadian framework we found does so.

Authority. The existing schemes already show what scoped delegation looks like. Form 8821 grants information access without the power to act, and CRA Level 1 does the same. A future agent credential would need levels of that kind, an expiry, and a way for the person to withdraw it, and it would need the agency to define and accept it.

Record. The agency’s own record governs: filings, confirmation numbers and decisions. An agent’s log of what it prepared and when is useful to the person but carries no official weight.

Where Emissar fits

No Emissar module changes the identity rules above, and Emissar does not propose that agents sign in as people.

• Front Door (open to design partners) could serve an agency’s public information and appointment desk, where no personal identity is involved.
• Mandate (spec in progress) describes the kind of scoped, revocable authority that forms like 8821 and CRA’s Level 1 grant to people today. It only matters if agencies choose to accept such credentials.
• Handoff (in development) fits the boundary: when a request needs the person or a representative, the agent’s task goes to them with the context attached.

Open questions

• Agent representatives. Will tax and benefit agencies define a class of software representative, with limited access levels, or keep representation human-only?
• Assurance for agents. NIST’s levels describe people and their authenticators. There is no equivalent scale for how confidently an agent is bound to the person it represents.
• Accessibility and fraud. Agents could help people who struggle with forms, language or disability. The same automation could also scale benefit fraud. Current terms block both uses alike.
• Liability. If an agent prepares a filing with an error and the person submits it, who answers for the mistake: the person, or the agent’s provider?