A report by an organisation called Caribou has indicated that digital ID systems globally have ongoingly intensified the exclusionary issues they claim to mitigate.
Caribou, [1] a research organisation specialising in AI and digital Identity has published a report [2] titled Digital Identity and Migration: Struggles for Equitable Technology Governance is based on extensive fieldwork carried out in Kenya and Germany as part of Caribou’s “Identity in the Age of Migration” project. It provides a detailed evaluation of the discriminatory and biased implementation of biometric digital ID systems, cautioning that without urgent corrective actions, the global digital identity revolution risks proceeding in an unfavorable direction.
The report said in its introduction, “Digital identity has emerged as a booming industry, and as a critical battleground in global struggles for equitable technology governance. Despite progressive rhetoric around new and decentralized models of identity management, prevailing systems remain highly centralized and concentrated in the hands of governments and private companies. The European Commission has adopted legislation [3] that mandates member governments to develop digital identity wallets, emphasizing user empowerment and data protection. But without adequate safeguards these efforts risk reproducing existing exclusions under new technological guises.”
Research conducted in Kenya and Germany reveals that documented migrants are often ensnared in bureaucratic processes that existing digital systems fail to address. In Germany, for example, an asylum seeker reported being issued an ID document that listed their nationality as “unclear,” despite having provided significant evidence of their Syrian origin. A similar situation is observed in Kenya, where refugees frequently encounter barriers to accessing the country's digital public infrastructure or DPI, including mobile money services, due to issues such as SIM card registration or exclusion from the national health database.
Kenya [4] has faced significant criticism regarding exclusion, human rights, and privacy concerns associated with its ongoing digital ID initiatives. Professor Laura Bingham and Dr. Thomas Fisher, [5] a senior researcher at [6] Privacy International, have raised concerns about the ID system, highlighting several shortcomings related to privacy, data security, and inclusion. Bingham stated that contrary to government assertions, the ID system features a centralised data repository, which could potentially serve as a surveillance mechanism to inhibit dissenting voices. The researchers also argue that the ongoing challenge of digital ID exclusion affecting migrants and other forcibly displaced individuals is primarily a political issue rather than a technological one. This assertion is supported by an examination of three distinct digital ID cases that utilize the same technology but are driven by vastly different political agendas.
They claim that the ID system may be exclusionary, particularly affecting citizens in various communities, notably those near the borders, who feel left out of the benefits the system is intended to provide. A petition questioning the fairness and legality of Maisha Namba, a digital identity system, has been filed at the Milimani Law Courts. Experts have expressed concerns that the system could further marginalize millions of undocumented citizens [7] as reported by The Eastleigh Voice.
Laura Bingham said, “The Maisha Namba system assumes that everyone can prove their Kenyan nationality. But for many communities that have historically struggled to access national IDs and birth certificates, this system will only deepen their exclusion.” Tom Fisher also said, “You can change your password, but you cannot change your biometrics.” Maisha Namba is the newly introduced digital identification system aimed at providing citizens and residents with a unique personal identifier or UPI from birth. This system is set to replace the existing National ID framework and seeks to consolidate various government services into a centralized database utilizing biometric data, which includes fingerprint, facial, and iris scans.
The report also examines [8] the EU digital ID wallet, which excludes non-EU migrants by design, as well as [9] the BritCard proposed by the UK government, which is partially positioned as a measure to combat undocumented immigration. It also addresses the Red Cross’s DIGID initiative in Kenya, a blockchain-based wallet aimed at providing services to refugees lacking official identification. Despite showing potential for inclusivity, DIGID ultimately struggled to expand beyond its pilot projects, primarily due to insufficient funding.
On page 11 of Case Study 2 the report said, “The proposed BritCard uses migration concerns as an entry point for a system that would ultimately affect all UK residents. It is an enforcement oriented rather than rights-based digital solution, explicitly targeting those deemed ‘irregular.’ By contrast, EUDI claims universal empowerment for EU citizens and residents, but creates broader systematic exclusion of all non-EU migrants regardless of legal status through its technical requirements; an EU e-ID and advanced smartphone access are prerequisites. In our research, one migrant participant suggested, ‘it’s not for people like me.’”
In a 2025 statement, Caribou urged [10] nations to prioritize the resolution of legal and institutional factors contributing to statelessness prior to considering the implementation of inclusive digital identity systems. The discussion centres on [11] the risks associated with new identification systems for individuals who are, or may be, stateless. Caribou warns about the UN Sustainable Development Goals digital ID objectives, It also contends that without targeted measures to guarantee the recognition or granting of nationality, either by the state of residence or another state, these new identification systems are likely to reproduce or exacerbate existing patterns of exclusion. “The agenda set by the UN Sustainable Development Goals does indeed imply that states should ‘provide legal identity for all, including birth registration’. Others, however, have warned of the dangers of the rapid rollout of new biometric and digital identification technologies to fulfill this target, and the risk of enabling surveillance without ensuring rights,” said the report.