Avinyum's response to the Draft National Code Against Age Fraud in Sports (NCAAFS) 2025

Level playing field of fairness in Indian sports

Avinyum commends the Ministry of Youth Affairs and Sports for its proactive approach in revising the National Code Against Age Fraud in Sports (NCAAFS) 2025. Addressing age fraud is critical to ensuring fairness, athlete well-being, and the credibility of Indian sports. We recognise the comprehensive framework outlined in the draft policy and appreciate the opportunity to contribute towards refining and strengthening it.

Age fraud has long been a persistent issue in Indian sports, with significant ramifications for fair play, athlete development, and international credibility. By creating a robust regulatory framework, India has the opportunity to set a new global benchmark for integrity in sports governance. However, any policy aiming to address this issue must be comprehensive, enforceable, technologically progressive, and legally sound. Our recommendations focus on enhancing policy effectiveness while ensuring that implementation is practical, athlete-friendly, and compliant with evolving global standards.

In recent years, multiple high-profile cases of age fraud have surfaced in various sporting disciplines, severely impacting the credibility of Indian sports bodies. This phenomenon not only skews competition but also leads to resource misallocation, harming genuine athletes. Given the complexities involved, it is essential that age verification mechanisms are accurate, ethically implemented, and enforceable while also considering data privacy and fairness concerns.

Age fraud also negatively impacts talent identification and development, as athletes competing in inappropriate age groups hinder the progress of genuine competitors. This leads to disillusionment among young athletes and discourages fair participation in national and international competitions. Addressing this issue holistically requires a balance between rigorous verification and safeguarding the rights and privacy of athletes. Implementing an effective mechanism will not only protect young athletes but also foster a culture of integrity and transparency in sports administration.

Key Areas of Evaluation & Recommendations 

1. Clear Definition of Goals, Problem Statement, and Accountability

The policy's goal is to prevent age fraud in sports, protect the integrity of competitions, and promote ethical practices. However, there are some gaps in defining key terms and ensuring robust accountability measures.

Recommendations: 

• Provide an explicit definition of “age fraud” in the policy. We propose: “Age fraud is the conscious falsification of date of birth, resulting in incorrect reporting of chronological age. This includes both underreporting and overreporting of age.”

• Remove references to “genuine athletes’ rights” unless a legal framework is established to define such rights.

• Expand the policy’s objectives to include: “Prevention of physical and psychological harm to athletes due to age fraud.”

• Establish clear criteria for categorizing and penalizing age fraud violations based on intent and magnitude.

• The 2010 version failed to impose punishment or maintain a central record of fraudsters (Gautam, 2021), allowing habitual fraudsters and their accomplices to escape consequences. This draft rectifies that by clearly assigning accountability across all levels—ensuring that any violation is met with consistent and transparent consequences, thereby acting as a strong deterrent. We recommend imposing stricter penalties on parents/guardians and coaches found responsible for age fraud involving minor athletes. This is especially true for coaches, as they play a central role in misleading athletes and their parents/guardians, thereby perpetuating this systemic issue.

• Establishing a clear, comprehensive, and enforceable framework will help ensure that all stakeholders share a common understanding of the issue, reducing ambiguity and strengthening legal enforcement.

 2. Strengthening Privacy and Data Protection in Age Verification

The policy mandates a multi-document approach for age verification, requiring multiple documents. While this ensures accuracy, it raises concerns regarding data privacy, security, and informed consent.

  Recommendations:

• Of the documents listed in the draft policy for age verification, we suggest only those documents that can be digitally verified be retained and the others that are amenable to manipulation be dropped from the list. The acceptable documents include:

• Birth Certificate (Form 5)  (Digitally generated and verifiable via QR code).

• Aadhaar Card/APAAR ID/Passport/PAN Card/Smart-card based Driving License  (Digitally verifiable via APIs or DigiLocker).

Suggested to be removed from the list of documents for age verification:

• Voter ID and non-smart driving licenses as they are not linked to biometric data.

• School leaving, transfer certificates, matriculation certificate, certificate from the head of school or orphanage or child care home, as they do not provide any verifiable proof.

• Implement  a DEPA-based (Data Empowerment and Protection Architecture) consent framework  to ensure secure access to athletes’ data while complying with the  Digital Personal Data Protection (DPDP) Act, 2023.

• Ensuring Digital Verification at Player Registration

At the time of player registration and generation of a player ID, the  document verification must be conducted digitally using the athlete’s fingerprint scan, rather than relying on offline document submission.

The information from the acceptable documents must be sourced directly from the issuing authorities (source systems) with full athlete consent (Consent of parent/guardian in case of minor athlete) using a secure digital process. This will eliminate manual verification errors and prevent document tampering.

There should be no requirement to store physical copies of these documents in a new database. Instead, authorized sports bodies should access the necessary verification through secure API-based data sharing, ensuring compliance with privacy-first principles.

• Mandate fingerprint-based age verification at recruitment with central government bodies

Sports is a State subject. The policy acknowledges this and, in Section 4.2, suggests that State(s)/UT(s) may adopt this policy or use it as a model to develop their own—without mandating compliance. Unfortunately, this makes enforcement at the national level weak and inconsistent.

Age fraud typically begins at the grassroots level, where athletes compete in age-based categories at the district or state level. This manipulation is often carried out to gain unfair advantages in competitions, scholarships, and future job opportunities. If not addressed at the earliest stages, age falsification becomes deeply entrenched—by the time an athlete reaches national or professional levels, the damage is already done.

To effectively curb this malpractice, it is imperative to act early and decisively. We strongly recommend that all recruiting agencies—especially government bodies such as the Railways, paramilitary forces, and public sector undertakings—must implement mandatory fingerprint-based age verification at the time of employment. This biometric validation will help verify the true age of the athlete using government databases, and expose any discrepancies. Introducing this step at the final stage of the athlete's career sends a clear and powerful signal to parents, coaches, and athletes, that age fraud will not go undetected and will have serious, irreversible consequences. This will discourage falsification from the very start.

• Link Central Sports Grants to Policy Adoption

Central sports grants and infrastructure investments should be conditionally linked to states formally adopting and enforcing the national age fraud policy. This creates a tangible incentive for state governments to participate in eradicating age fraud.

• Debar Athletes Guilty of Age Falsification from Government Jobs

The Ministry of Youth Affairs and Sports must work in collaboration with other central ministries to ensure that any athlete found guilty of age fraud at any point in their career is permanently debarred from all central government employment opportunities. This includes jobs in Railways, paramilitary forces, public sector undertakings, and similar institutions. Such a penalty will act as a strong disincentive for age manipulation early in an athlete’s journey.

• Learning of DEPA from the Finance Sector

The Account Aggregator (AA) framework in finance has successfully enabled DEPA based secure, user-consented data sharing across banks, insurance providers, and NBFCs while maintaining data privacy and granular control for users. A similar consent Manager-based approach can be used in sports, where a Central Sports Data Authority - Consent Manager (modelled after AA in finance) manages and governs DEPA based access to athlete data in a transparent, digitally auditable manner.

• Establish a Central Sports Data Authority - Consent Manager (under Ministry of Youth Affairs and Sports) to manage data access securely and transparently.

• Require explicit athlete (parent/guardian in case of minor athlete) consent for data access, ensuring compliance with privacy standards.

• Use API-based data sharing (similar to AA framework) to enable authorized sports bodies to access age verification data without storing or manipulating raw documents.

• Leveraging India's digital public infrastructure (e.g. DigiLocker) and incorporating robust data encryption and role-based access measures will strengthen trust and prevent misuse.

  
  

3. Improving the Medical Age Verification Process

The draft policy suggests using  Tanner-Whitehouse 3 (TW3) radiological assessments, MRIs, and AI-based tools (BoneXpert)  for age verification. While these approaches offer scientific grounding, they have significant limitations that need to be addressed.

Concerns:

• Inaccuracy of TW3 Method : The TW3 method can have an error margin of up to  four years , meaning two athletes of the same chronological age could have widely varying bone ages (Engebretsen et al., 2010). This variation makes it unreliable as the sole determinant of age. This is to do with the fact that pubertal progress in adolescents has a defining role in physical maturity and fitness. Children who reach physical maturity early may have skeletal age several years advanced from their chronological age, compared to those children where pubertal process starts late and hence they mature later.

• Limitations of MRI-based Assessments : MRI scans have shown inconsistencies in accurately estimating the ages of athletes below 14 and above 17 years (Engebretsen, 2010).These limitations can lead to unjustified disqualifications or unnecessary disputes.

• Reliance on AI-based Age Estimation : While AI tools like BoneXpert have been promising, they ultimately rely on bone-age inference, which inherits the limitations of traditional radiological methods.

• We highlight these limitations to ensure that the latest developments in these areas are closely tracked and that the advanced methods adopted by international sporting bodies are implemented in India as well.

 Recommendations:

Adopt a three-stage age verification approach :

• Stage 1:  AI-based, non-invasive screening using hand/wrist X-ray analysis (e.g., BoneXpert). If the estimated age aligns with the reported age within an accepted range (e.g., ±1 year), the athlete is cleared.

• Stage 2:  Cases where AI screening results are disputed should undergo human verification using  dental maturity indicators and anthropometric analysis  to cross-check growth patterns.

• Stage 3:  Full-scale medical examination (X-ray/MRI) should be  reserved only for contested cases  where discrepancies persist.

• Ensure Secure and Confidential Medical Data Handling: Store results within the  Ayushman Bharat Digital Mission (ABDM) system, and manage access via the  Central Sports Data Authority - Consent Manager.

• Conduct periodic independent audits  to integrate evolving best practices in sports medicine and age verification.

This phased approach minimises invasive procedures and ensures that only disputed cases undergo more rigorous and resource-intensive evaluations. Further the entire process shall be DEPA based and complaint with DPDP Act, 2023.

4. Phased Implementation Strategy

Given the large number of existing athletes requiring verification, a phased implementation plan will ensure smooth adoption and prevent system bottlenecks. We propose starting with a pilot in a single sport to refine processes before broader rollout.

Recommendations:

• Pilot Phase in a Single Sport:  Begin with one sport, starting with junior athletes and progressing to seniors. This focused pilot will help identify and address operational challenges in a controlled setting.

  
  

  •  Initial Phase: Roll out the process to grassroots and school-level athletes, within one chosen sport

  • Intermediate Phase:  Extend the implementation to state-level competitions within that sport

  • Final Phase:  Finally roll out to athletes competing at the national and international level athletes, then expand to other sports based on learnings from the pilot.The pilot rollout for one sport should be completed within six months following the launch of the policy and operational systems.

• Establish Digital Infrastructure:  Ensure online workflows and data management systems with finger print scanners are fully operational before launching the pilot.

• Regular Evaluation Checkpoints:  Conduct periodic reviews and collect stakeholder feedback to refine processes and ensure smooth scaling to additional sports.

By addressing these concerns, India can lead the way in ethical sports governance and fair play enforcement. Implementing a structured, technology-driven approach—with clear accountability measures and a carefully piloted, phased rollout—will ensure that young athletes compete on a level playing field, fostering a culture of fairness, transparency, and accountability in Indian sports.