Cannot add state ID to Wallet for 12-year-old

Apple restricts the use of electronic wallets to users 13 and older. Individual states may restrict the use of electronic wallets even further. Many states limit use of e-wallets to individuals 18 and older. So while, some states permit the issuance of state ID’s to minors, they may not have revised their regulations regarding electronic wallets. Please check with your state representatives concerning use of electronic wallets for minors in your state.

I have not seen an age documented for adding a State ID or Transit Card, but you can certainly contact Apple directly to find the answer.

Contact Apple Support - Apple Support

One important difference in adding Apple Cash to a child's account is that only your information is being shared to a third party (Green Dot Bank) to add the card and no information about your child is shared.

COPPA (Children's Online Privacy Protection Act) prevents data from a child under 13 from being shared to a third party. It can be allowed with expressed consent from a parent or guardian, but as you know you do not need to be a parent or guardian to add a child's account to your Family Plan. There is no documentation required to prove you are the parent or guardian. COPPA not only applies to websites, but also apps on Mobile devices and as seen in the summary on the Wiki page, most will just restrict their service for children under 13 when there is data that will be shared. The full text of the law is also available to read:

Although children under 13 can legally give out personal information with their parents' permission, many websites—particularly social media sites, but also other sites that collect most personal info—disallow children under 13 from using their services altogether due to the cost and work involved in complying with the law.

https://en.wikipedia.org/wiki/Children%27s_Online_Privacy_Protection_Act

The type of data that is shared to a third party when adding a State ID includes:

• Photo of front and back of card (this would include DOB, Address, and full legal name of the child)
• Live Photo or Selfie
• Data read from the barcode on the back of the card
• A single-digit value, used to help prevent fraud, that’s based on your device use patterns, settings data, and information about the Apple Account

When you tap the plus button to add a card, pass, or state ID, the device is checked for eligibility and in the case of your son, his account does not qualify based on age. Would you rather have that you go through all the steps only to discover the age restricted account does not qualify? I would think that would really upset people.

Apple Cash is a separate issue and a work around to the use of a prepaid debit card (Apple Cash). Your son’s personal information is not exposed, only yours.

The documentation would vary by state. The state ID is technically property of the state and they control its use. I’m certain if you contact the state authority that issued the ID they will be familiar with restrictions for its use. If Illinois does not specifically have an age restriction, the decision to exclude those under 12 could be a corporate decision. In that case you can provide feedback directly to Apple.

Product Feedback - Apple

good question. I read many apps’ information they collect and some do access photos and other details. You are essentially putting a child’s life inside a digital device that could be accessed or potentially compromised. If any app offers the convenience of adding my ID, I would want to know who is verifying that it is me in the ID, and whether the ID is valid. If the State of wherever offers IDs for minors, they should be the ones to manage the online access to it save safeguarded with a pamphlet or resources they provide to make the ID accessible online. The wallet offers live activities for people. What does your state support? Can you look at your state resources for the method they recommend; I would like to think education would be factored into helping students with safeguarding their mobile environment.

[edited]

Answered by Jeff Donald without the speculation I had provided.