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login.gov meets IAL2 since it NIST SP 800-63-3 "allows for remote or in-person identity proofing" (800-63A page 8). Likewise, TOTP is explicitly mentioned as an allowed multi-factor OTP authenticator (800-63B pages 20-21). I'm not aware of changes in SP 800-63-4 that would affect login.gov's current implementation, but it's been a minute since I last read the -4 draft and could be wrong.



Login.gov permits me if the IRS could do identity proofing.

The IRS can't do identity proofing (hence the need for ID.me, which is implementing "remote or in-person identity proofing"), and login.gov doesn't do it for the agency. Login.gov can only record whether the identity was created at IAL-1 or IAL-2.

Use of login.gov is orthogonal to the question of ID.me.




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