Hardware Bearer Credentials for Privacy-Preserving Age Verification at EU Scale

The European Commission's April 2026 age verification framework, built on software-based Zero-Knowledge Proofs (ZKP) atop the European Digital Identity (EUDI) Wallet, fails to achieve its stated privacy guarantees due to a structural enrollment binding problem: any ZKP scheme whose trust root is a government identity credential inherits that credential's linkability at the point of issuance. This paper proposes a replacement architecture based on hardware bearer credentials — physically issued FIDO2 tokens whose identity binding is discarded immediately after issuance — combined with an anonymous hardware-handle revocation list, offline kiosk enrollment, and a self-funding economic model. The proposal is technically feasible with current production technology, financially viable at EU procurement scale, and operationally self-sustaining through a €10 citizen co-payment at issuance plus a €30 replacement fee. A cost model for national deployment using Italy as a case study demonstrates that the system requires near-zero net public expenditure. The primary novel contribution is a game-theoretic mechanism embedded in the replacement fee structure that renders secondary market trading of credentials economically irrational without requiring any surveillance of credential holders.