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Whether or not such exploits carry consequences because it almost certainly falls under a SSA violation, would be at Valve's discretion.
I rallied to Steam's cause when the backdoor restrictions were imposed by the payment providers but that was naive as they seem to be no different themselves. HOW DIFFICULT WOULD I(T BE TO IMPLEMENT A DIFFERENT AGE VERIFICATION METHOD FOR UK DEBIT CARD HOL:DERS. This would translate into more revenue , surely.
I'm sure I read somewhere a few weeks ago that Valve is looking into different options, so one of those crappy face/age verification services will probably end up part of the Steam app. I think a lot of platforms scrambled to hastily implement *something* AFTER they realised they might be breaking the law. Which probably explains why no verification existed for a few weeks after the Online Safety Act was enacted.
Maybe in the story you've weaved. Try this one on:
Steam already accepts credit cards, and credit cards are a valid form of age verification. Just having one attached to your account is sufficient to meet the requirements. Which means adding a single boolean flag to determine if an account is age verified. It's extremely low hanging fruit. But if that wasn't an option then all UK adults would likely be blocked from age restricted content. Just like how Germans are.
IE If credit cards weren't an option, you'd likely have zero options.
Based on what Valve has done so far for UK and German users, it kinda just seems like they're not very interested in the burdens of more elaborate age verification. And either it goes against their values, or the revenue from age restricted games isn't so much to motivate action or commit the time and effort.
Why people don't seem to entertain the idea that Valve has made informed decisions about their business and that no options for age verification is a valid implementation, well it's not beyond me, but it does seem narrow minded.