AI RESEARCH
Position: Age Estimation Models Do Not Process Biometric Data
arXiv CS.LG
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ArXi:2605.17347v1 Announce Type: cross When a neural network estimates someone's age from a photograph, does it process biometric data? The answer depends on whether identity-discriminative representations arise within the network during inference, a question that may seem trivial to ML researchers but triggers consent requirements under GDPR, statutory damages under BIPA, or high-risk AI classification under the EU AI Act. Yet no regulatory guidance addresses it.