The "photographer submits via a secure form" approach detailed in the article leaves this loophole pretty open, too, unless the photographers have to go through some kinds of security clearance vetting to get access.
Not really: a paper trail and a process that requires the photographer to be knowingly and provably complicit would already create a pretty high barrier. Not an insurmountably high barrier, but no amount of vetting could.
When I got my first drivers license (Germany) the photographer actually digitally removed some moles from my face and did other editing to make the picture appear more good looking. I was a bit baffled as the picture is supposed to identify me but didn't say anything. Since then I always take ID-pictures in a photo booth. It really doesn't need a professional to take an acceptable picture.
I could imagine a photo booth outputting a digital copy of the picture with signature so it is clear to the registration office that the picture has not been meddled with.
The blackmarket is very much alive and well in Germany, allowing photographers to verify anything is silly, they can be bribed. :x
In fact when I lived in Austria, within a couple months I had access to more black market goods/services then I did after growing up in the US for 25 years. I would imagine Germany is the same.
The point isn't that they can be bribed, it's that the photographer has to attach their name to the photo and certify that it hasn't been altered or tampered with. It adds the ability to go after the photographer if they gov't ever discovers tampering has been done.
This is also where it is important to point out German culture.
Germans are extremely law abiding and rule following. People are also generally worried breaking social norms.
So while it is technically possible for photographers to digitally alter photos before upload, there will be very few who would dare to do that.
Photographers rely on the revenue from passport photos for their businesses to survive. Initially the plan was to exclude professional photographers too but the government backtracked on that after outcry.
New business model. Pop-up photoshop. Like the countless other businesses popping up, operating for a few months, washing money, closing down, owners gone, employees unknown, and so on.
Except it takes a while to start a business in Germany and there is lots of paperwork involved.
Also it sounds like licensing is required to be able to take passport photos. Chances are that licensing might apply to both the business and the individual photographer.
Alcohol and cigarettes are always on the black market close to US military bases. Prices are always cheaper for service members and their family on base.
The blackmarket is obviously bigger outside of the US where US law and enforcement will be encouraged to go after blackmarkets more strongly than another company.
Is there some sort of camera fingerprinting technology out there, then, that distinguishes between processing done on the camera vs. post-processing in software? If not, how are we even going to tell, short of having signed files coming off the chip?
I could use some CGAN scripts to make a picture of me, which - to your eyes and mine, looks like me - but nevertheless does not have my official physical metrics, and thus I could pre-dispose future AI against recognizing me.
I could. But, I won't any more, because Germany will make life a hassle for me.
We developers sometimes struggle with the distinction. The point of laws and regulations is usually not to make fraud technically impossible, but increase the cost and/or risk of getting caught. People still use locks on doors even though they are easy to pick.
