REAL ID Act of 2005
Implementation:
An Interagency Security Committee Guide
2019
Interagency
Security
Committee
REAL ID Act of 2005 Implementation: i
An Interagency Security Committee Guide
Revision History
Year Changes Approver
2015 Initial issue ISC
2017 Added definitions; Updated Phase 4 implementation
guidelines; Updated the internet link to the REAL ID
information page; Deleted Appendix E: Sample Report
ISC
2019 Document updated per DHS REAL ID Program Office ISC
ii REAL ID Act of 2005 Implementation:
An Interagency Security Committee Guide
Message from the Chief, Interagency Security
Committee
One of the Department of Homeland Security’s (DHS) priorities is the protection of federal
employees and private citizens who work within and visit United States (US) Government-
owned or leased facilities. The Interagency Security Committee (ISC), chaired by DHS, consists
of federal departments and agencies and has as its mission the development of security standards
and best practices for nonmilitary federal facilities in the US.
As Chief of the ISC, I am pleased to introduce the updated ISC document titled REAL ID Act of
2005 Implementation: An Interagency Security Committee Guide. This ISC guide details the
purpose and background of the REAL ID Act of 2005 (“the Act”) and outlines the phased
implementation schedule for enforcement. The guide also contains options in accordance with
the Act for creating access control procedures, communicating those procedures, and
establishing alternate access control procedures if necessary. Lastly, the guide contains
appendices that reference information on the Act, a list of recommended acceptable forms of
identification, and a flow chart aid for developing access control decisions.
Consistent with Executive Order 12977 (October 19, 1995), which established the Interagency
Security Committee, the REAL ID Act of 2005 Implementation: An Interagency Security
Committee Guide applies to all buildings and facilities in the US occupied by federal employees
for nonmilitary activities. These include existing owned, to be purchased, or leased facilities;
standalone facilities; federal campuses; individual facilities on federal campuses; and special-use
facilities.
Daryle Hernandez
Chief, Interagency Security Committee
REAL ID Act of 2005 Implementation: iii
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REAL ID Act of 2005 Implementation: 1
An Interagency Security Committee Guide
Table of Contents
Revision History ............................................................................................................................. i
Message from the Chief, Interagency Security Committee ...................................................... ii
Table of Contents .......................................................................................................................... 1
1.0 Purpose .................................................................................................................................... 2
2.0 Background ............................................................................................................................. 2
2.1 Current Status ....................................................................................................................... 2
3.0 Applicability ............................................................................................................................ 4
4.0 Access Control ........................................................................................................................ 5
4.1 Considerations when Developing Identity Document-based Access Control Procedures ... 5
4.2 Communicating Access Control Procedures ........................................................................ 6
4.3 Alternate Access Control Options ........................................................................................ 7
5.0 References ............................................................................................................................... 8
5.1 Glossary of Ter
ms ................................................................................................................ 8
5.1.1 Glossary of REAL ID Compliance Terms ................................................................ 9
5.2 List of Acronyms/Abbreviations/Initializations ................................................................. 10
5.3 Resources............................................................................................................................ 11
6.0 ISC Working Group Participants (Initial Edition) ........................................................... 12
Table of Appendices
Appendix A: REAL ID Implementation Phases ...................................................................... 13
Appendix B: List of Acceptable Forms of Identification ........................................................ 14
Appendix C: Flow Chart for Access Control Decision ............................................................ 16
2 REAL ID Act of 2005 Implementation:
An Interagency Security Committee Guide
1.0 Purpose
This document outlines guidance for federal departments and agencies, including the Department
of Defense (DoD) and Facility Security Committees (FSCs), regarding access control
requirements of the REAL ID Act (“the Act”) and access control options for individuals who do
not have an acceptable form of identity document.
2.0 Background
The REAL ID Act of 2005 was enacted in response to a 9/11 Commission recommendation that
the federal government “set standards for the issuance […] of sources of identification, such as
driver’s licenses.”
1
The Act established minimum security standards for license issuance and
production and assigned responsibility for determining whether a state is meeting these standards
to the Department of Homeland Security (DHS). DHS issued the REAL ID regulation on
January 29, 2008 and began issuing compliance determinations on December 20, 2012.
The Act prohibits federal agencies from accepting for official purposes driver’s licenses and
identification cards from states not meeting the Act’s minimum standards. The official purposes
defined in the Act and regulations are as follows:
• Accessing federal facilities;
• Entering nuclear power plants; and
• Boarding federally regulated commercial aircraft.
In early 2013, the National Security Council Staff convened an Interagency Policy Committee to
develop a plan to ensure that enforcement of the Act’s prohibitions is done fairly and
responsibly. This plan, announced on December 20, 2013, defined the initial enforcement phases
and established a schedule for their implementation (see Appendix A).
The Act covers 56 jurisdictions, including the 50 US states, the District of Columbia, and the US
territories of Puerto Rico, the US Virgin Islands, Guam, American Samoa, and the
Commonwealth of the Northern Mariana Islands.
2.1 Current Status
On December 20, 2013, DHS announced a phased enforcement plan to implement the statutory
prohibition on the ability of federal agencies to accept driver’s licenses and identification cards
issued by noncompliant states by federal agencies for official purposes. The deployment of
enforcement measures is cumulative, with measures in each phase remaining in effect through
successive phases.
1
National Commission on Terrorist Attacks Upon the United States. “The 9/11 Commission Report.” January 1,
2004. Available online: http://www.9-11commission.gov/report/911Report.pdf
REAL ID Act of 2005 Implementation: 3
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Phase 1 of enforcement began on April 21, 2014 at DHS’s Nebraska Avenue Complex
headquarters in Washington, DC.
Phase 2 began on July 21, 2014. This phase applies to restricted federal facilities (or parts of a
facility), which are only accessible to federal employees, contractors, and their guests. It applies
to about 217 facilities in the custody and control of the General Services Administration
(GSA)—mostly law enforcement agencies and laboratories—as well as many agency
headquarters facilities.
Phase 3 applies to “semi-restricted” federal facilities (or parts of a facility), which are accessible
to the public but subject to ID-based access control. The start date for each facility is based on its
Facility Security Level (FSL) classification. Facilities with an FSL of 1 or 2 began on January
19, 2015 (Phase 3A). Facilities with an FSL of 3, 4, or 5, as well as military facilities, began on
October 10, 2015 (Phase 3B).
Phase 4A, enforcement for boarding federally regulated commercial aircraft, based on the
compliance status of the state/territory, began on January 22, 2018.
Phase 4B, enforcement for all official purposes, based on the compliance status of the card,
begins on October 1, 2020. For more information, please visit https://www.dhs.gov/real-id.
4 REAL ID Act of 2005 Implementation:
An Interagency Security Committee Guide
3.0 Applicability
The Act only affects access control policies where individuals are required to present an
identification document for official purposes. The Act does not require agencies to accept, or
individuals to present, identification where it is not required for access (e.g., to enter the public
areas of the Smithsonian). Nor does it prohibit an agency from accepting other forms of
identification such as a US passport or military ID card.
The Act’s prohibitions do not affect the use of state-issued driver’s licenses or identification
cards—including licenses and cards from noncompliant states—for purposes unrelated to official
purposes as defined in the Act and applicable regulations. For example, the Act’s prohibitions do
not apply to voting, registering to vote, issuing Homeland Security Presidential Directive 12
(HSPD-12) cards, or applying for or receiving federal benefits.
In the access control environment, the purpose for which the ID is required governs whether the
Act prohibits an agency from accepting a state license or identification card from a noncompliant
state without an extension. If the reason for requiring an identification document is to make an
access control decision, the Act applies and licenses or identification cards from noncompliant
states may not be accepted for official purposes in accordance with the phased enforcement
schedule. The Act would not apply for reasons unrelated to the access control decision, such as a
mechanism to assure visitor badges are returned or for the accountability of visitors in case of an
emergency.
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4.0 Access Control
When developing access policies, the FSC (in multi-tenant facilities) or the Designated Official
(DO) (in a single-tenant facility) should take into consideration the access needs of the facility’s
visitors and their purpose for accessing the facility. Checking identity documents is least
effective when there is no use for identity information. Unnecessary ID checks create the
appearance of security without directly furthering the needs of security. The facility access
control policy should be consistent with:
• Interagency Security Committee (ISC) standards;
2
• The facility’s current FSL, countermeasures, and security procedures;
• The current occupants, potential visitors, volume of visitors, and security staff for tenant
agencies;
• The reason for the identification or identity document;
• The facility’s Occupant Emergency Plan (OEP) for essential information about facility
visitors; and
• Pre-approval and denial access lists.
The access control policy can recommend appropriate action (see Section 4.3) to preserve access
to federal facilities for purposes unrelated to the official purposes as defined in the Act and
applicable regulations, such as:
• Safety and health or life-preserving services (including responding to an emergency and
accessing hospitals and health clinics for health services and access to benefits);
• Law enforcement (including responding to an emergency, conducting investigations, and
participating in law enforcement proceedings); and
• Participating in constitutionally protected activities (including access to court
proceedings, including access by jurors or potential jurors).
4.1 Considerations when Developing
Identity
Document-based Access Control Procedures
When developing a facility security policy for a federal facility, the FSC should match security
procedures with the threat against the tenant agencies. Checking identity documents is useful
when a tenant agency has a defined use for the resulting information, such as matching against a
security watch list or an invitation list. Checking identity documents is least effective when the
action does not tie into an overall security strategy.
A common access control use for a validated identity is to match against an inclusion or
exclusion list that establishes a visitor’s appropriateness to enter the facility. An inclusion list
identifies people who have been pre-approved for entry. An exclusion list identifies people who
2
Interagency Security Committee Standards are available on the ISC website: https://www.dhs.gov/isc
6 REAL ID Act of 2005 Implementation:
An Interagency Security Committee Guide
should be denied entry. The document check provides evidence of the visitor’s identity,
enhancing the effectiveness of inclusion or exclusion lists. Similarly, the Transportation Security
Administration (TSA) has a need to validate a traveler’s identity at an airport checkpoint by
comparing the traveler with information on their identity document and matching it with the
biographical information submitted upon purchase of the ticket.
The type of acceptable identification document depends on the level of assurance the agency
requires about the validity of the visitor’s identity. The level of assurance of an identity
document depends on the process used by the issuer of the document to authenticate the
document holder’s identity as part of its issuance. For example, in issuing a Personal Identity
Verification (PIV) card, federal agencies use a standardized process that provides the high
identity assurance appropriate to be able to access federal information systems and federally
controlled facilities.
Where additional assurance of identity is needed, an agency should consider enacting policies to
check the identity document for signs of fraud or tampering and provide the checker with
training in fraud detection techniques and/or tools (e.g., magnifying devices and black lights) to
assist in determining the validity of the documents presented.
4.2 Communicating Access Control Procedures
Agencies are encouraged to make information about access control procedures readily available
to visitors in order to avoid confusion and facilitate access by helping to ensure that visitors have
appropriate identification upon their arrival. It is a best practice to make this information
available through multiple channels in order to maximize its exposure to visitors. The contents
do not need to be all-inclusive but should include, at a minimum, the most commonly accepted
identity documents and a general statement of what the visitors should expect if they are unable
to produce an acceptable identity document.
• Standardized Language: To the extent possible, agencies should standardize the
language used about identification requirements for visitors to a federal facility. For
example:
“[AGENCY] requires visitors to present government-issued identification for access to
its facilities. For visitors presenting a state-issued driver’s license or identification card,
[AGENCY] only accepts such documents if they are issued by states that are REAL ID
compliant or have an extension from the US Department of Homeland Security. If the
state that issued your license is listed as noncompliant without an extension, please bring
an alternate form of government-issued photo ID—such as a passport, Enhanced
Driver’s License (EDL), or federal employee, military, or veteran identification card—to
facilitate access.”
• Communication Materials: DHS and TSA have electronic files for posters and
handouts available for agencies to use at access control points to inform visitors about
REAL ID Act of 2005 Implementation: 7
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REAL ID-related access control requirements. Agencies may obtain more information
about these requirements at https://www.dhs.gov/real-id and https://www.tsa.gov/real-id.
• Web-based Information: Agencies are encouraged to post access control requirements
on their public website as a reference to individuals planning to visit their facilities. For
example, TSA has a website informing travelers about the forms of identity documents
that it accepts at airport security checkpoints. This page is available at
https://www.tsa.gov/traveler-information/acceptable-ids.
4.3 Alternate Access Control Options
Alternate access control procedures may include, but are not limited to, the following (subject to
adoption by the implementing federal agency, FSC, or DO):
• The agency may choose to establish a list of identification documents that it will accept
for access control purposes, including state-issued driver’s licenses or identification
cards. (See Appendix B.)
• The visitor may be listed in an appointment book so that the guard can call the agency
point of contact for access and escort without having to present identification.
• The agency may use a form of knowledge-based authentication, where available.
See Appendix C for a flow chart to apply these policies.
8 REAL ID Act of 2005 Implementation:
An Interagency Security Committee Guide
5.0 References
5.1 Glossary of Terms
Access Control: The use of physical and procedural controls to ensure only authorized
individuals or items are given access to a facility or secure area.
3
Designated Official (DO): The highest-ranking official of the primary occupant agency of a
federal facility or a designee selected by agreement of tenant agency officials.
Enhanced Driver’s License (EDL) or Enhanced Identification Card (EIC): State-issued
driver’s license or identification card issued in accordance with the Western Hemisphere Travel
Initiative (WHTI) that denotes identity and US citizenship and that is acceptable for entry into
the US at land and sea ports of entry. States currently issuing EDLs and EICs to their residents
who are US citizens include: Michigan, Minnesota, New York, Vermont, and Washington. For
more information, please visit: https://www.dhs.gov/enhanced-drivers-licenses-what-are-they
Facility Security Committee (FSC): A committee that is responsible for addressing facility-
specific security issues and approving the implementation of security measures and practices.
The FSC consists of: representatives of all federal tenants in the facility; the security
organization; and the owning or leasing department or agency. In the case of new construction or
pending lease actions, the FSC will also include the project team and the planned tenant(s).
Facility Security Level (FSL): A categorization based on the analysis of several security-related
factors, which serves as the basis for the implementation of physical security measures specified
in ISC standards.
Extended definition: The five factors quantified to determine the FSL are mission criticality,
symbolism, facility population, facility size, and threat to tenant agencies, as well additional
intangible factors.
Federal Facility: Government leased and owned facilities in the US (inclusive of its territories)
occupied by federal employees for nonmilitary activities.
ID-Based Access Control: Policies and practices requiring the presentation, inspection, and
acceptance of a visitor’s photo identification document for accessing a federal facility.
Knowledge-Based Authentication: A method of authentication based on knowledge of personal
information associated with the asserted identity. This may involve the use of information sent to
the individual in advance as part of the access control process or use answers to questions
generated from a wider base of personal information (e.g., previous addresses) to which the
agency has access.
4
3
As defined by the ISC in Best Practices for Armed Security Officers in Federal Facilities.
4
Refer to National Institute of Standards and Technology (NIST) Special Publication (SP) 800-63-3, Digital
Identity Guidelines. Available online: https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-63-3.pdf
REAL ID Act of 2005 Implementation: 9
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Restricted Area: A federal facility (or part of a facility) only available to agency personnel,
contractors, and their guests. Also referred to as Controlled Areas, Limited Areas, or Exclusion
Areas.
Semi-Restricted Area: A federal facility (or part of a facility) available to the public but subject
to ID-based access control.
State: One of 56 jurisdictions covered by the Act, which includes the 50 US states, the District
of Columbia, and the US territories of Puerto Rico, the US Virgin Islands, Guam, American
Samoa, and the Commonwealth of the Northern Mariana Islands.
State-Issued Identification Card: A driver’s license or non-driver identification card issued by
a state Department of Motor Vehicles or equivalent office. This does not include identification
cards issued by other state agencies, such as an employee ID, hunting license, library card, or
student ID.
5.1.1 Glossary of REAL ID Compliance Terms
Compliant States/Territories: States/territories that are compliant with the REAL ID Act.
Noncompliant States/Territories with Extension: States/territories that have been found
noncompliant with the REAL ID Act but have a current valid extension from DHS.
Grace Period States/Territories: The period following the expiration of an extension or
determination of noncompliance during which federal agencies may continue to accept licenses
and identification cards for official purposes. At the end of the grace period, federal agencies
may no longer accept licenses and identification cards from the noncompliant state or territory
without an extension.
10 REAL ID Act of 2005 Implementation:
An Interagency Security Committee Guide
5.2 List of Acronyms/Abbreviations/Initializations
Term Definition
DHS Department of Homeland Security
DO Designated Official
DoD Department of Defense
EDL Enhanced Driver’s License
EIC Enhanced Identification Card
FSC Facility Security Committee
FSL Facility Security Level
GSA General Services Administration
HSPD-12 Homeland Security Presidential Directive 12
ISC Interagency Security Committee
NAC Nebraska Avenue Complex
OEP Occupant Emergency Plan
PIV Personal Identity Verification
PIV-I Personal Identity Verification – Interoperable
TSA Transportation Security Administration
TWIC Transportation Worker Identification Credential
US United States
USCG United States Coast Guard
WHTI Western Hemisphere Travel Initiative
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5.3 Resources
• The REAL ID Act of 2005: https://www.dhs.gov/xlibrary/assets/real-id-act-text.pdf
• REAL ID Regulation (6 Code of Federal Regulations [CFR] Part 37) and amendments:
https://www.ecfr.gov/cgi-bin/text-idx?SID=daf01a89f25874673f2ebc305f63cffc&mc
=true&tpl=/ecfrbrowse/Title06/6cfr37_main_02.tpl
• REAL ID Enforcement: https://www.dhs.gov/real-id
• The Risk Management Process for Federal Facilities: An Interagency Security Committee
Standard: https://www.dhs.gov/publication/isc-risk-management-process
12 REAL ID Act of 2005 Implementation:
An Interagency Security Committee Guide
6.0 ISC Working Group Participants (Initial Edition)
Interagency Security Committee
Bernard Holt
Acting Executive Director
Working Group Chair
Ted Sobel
Office of Policy
Department of Homeland Security
Interagency Security Committee Representatives
Tony Evernham
Megan Drohan
Kyle Macken
Working Group Participants
Sue Armstrong
Federal Protective Service
Mark Hartz
Administrative Office of the U.S. Courts
Selden Biggs
Office of Policy
Department of Homeland Security
Bernie Minakowski
General Services Administration
Denis Brady
Nuclear Regulatory Commission
Elizabeth Newman
Department of Justice
Gregory Brock
National Labor Relations Board
Donna Rivera
Department of Defense
Jeff Campbell
Environmental Protection Agency
Nicholas Schnare
Department of Commerce
Maggie Dugan
General Services Administration
Paul Stevens
Federal Bureau of Investigations
Laura Forest
U.S. Citizenship and Immigration Service
Matt Weese
Federal Protective Service
REAL ID Act of 2005 Implementation: 13
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Appendix A: REAL ID Implementation Phases
The full phased enforcement plan for REAL ID and a list of compliant and noncompliant states
may be found on the DHS website at https://www.dhs.gov/real-id. As the list of states is subject
to periodic revisions, the most recent version can always be found on this website and is not
listed in this document.
Phase Enforcement Full Enforcement
Date
1 Restricted areas for DHS/Nebraska Avenue Complex (NAC) 2014-04-21
2 Restricted areas for all federal facilities and nuclear power plants 2014-07-21
3 Semi-restricted areas for all federal facilities N/A
3a FSLs 1 and 2 2015-01-19
3b FSLs 3, 4, and 5 and military facilities 2016-10-10
4a TSA airport security checkpoints (state-based enforcement) 2018-01-22
4b Card-based enforcement for all official purposes (Phases 1-4a).
State-issued license or ID card must be REAL ID-compliant.
2020-10-01
14 REAL ID Act of 2005 Implementation:
An Interagency Security Committee Guide
Appendix B: List of Acceptable Forms of Identification
Each agency may determine which identification documents it will accept for the purpose of
accessing its facilities based on the facility’s risk profile. The Act only applies to the
circumstances when an agency may accept a state-issued driver’s license or identification card.
The ISC recommends that agencies accept a federal or foreign government-issued passport
containing a photograph, first and last name, expiration date, and any additional elements the
agency uses in its verification processes. The ISC does not recommend accepting a document if
it has visible signs of tampering. The ISC recommends that preference be given to documents
that have not expired, particularly for facilities at greater risk, such as facilities designated at FSL
3 or greater.
In the interest of promoting consistent policies across the federal government, the ISC provides
the following list of possible forms
5
of identification to assist agencies in setting their facility’s
access control policies. This list is neither authoritative nor exhaustive.
1. Federally Issued Identification
a. US Passport
b. US Passport Card
c. PIV or federally issued Personal Identification Verification – Interoperable (PIV-I)
Card
d. Driver’s License issued by the US Department of State
e. Border Crossing Card (Form DSP-150)
f. DHS “Trusted Traveler” Card (Global Entry, NEXUS, SENTRI, FAST)
g. US Military ID (All members of the US Armed Forces, including retirees and
dependent ID card holders, and veterans. Visit the DoD’s Common Access Card
website for more information: https://www.cac.mil)
h. Veteran Health Identification Card issued by the US Department of Veterans Affairs
i. US Permanent Resident Card (Form I-551)
j. US Certificate of Naturalization or Certificate of Citizenship (Form N-550)
5
This list is intended to provide options for consideration regarding acceptable forms of identification. Ultimately,
the FSC and/or security organization should determine which of these would be acceptable at the facility based on
the facility’s purpose, department/agency mission, FSL, and required level of protection.
REAL ID Act of 2005 Implementation: 15
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k. Employment Authorization Document issued by DHS (Form I-766)
l. US Refugee Travel Document or other travel document or evidence of immigration
status issued by DHS and containing a photograph (Permit to Reenter Form I-327 and
Refugee Travel Document Form I-571)
m. Transportation Worker Identification Credential (TWIC)
n. Merchant Mariner Card issued by DHS/US Coast Guard (USCG)
2. State-Issued Identification
o. A driver’s license or identification card issued by a REAL ID-compliant state or a
noncompliant state that has been granted an extension. Beginning October 1, 2020,
only REAL ID-compliant cards issued by a compliant state will be accepted.
p. State-issued EDL: https://www.dhs.gov/enhanced-drivers-licenses-what-are-they
q. State prisoner identification card
3. Other
r. Federally Registered Native American Tribal Photo ID
s. Foreign government-issued passport
t. PIV-I card issued by non-federal government entities
Facilities may also consider the following higher-risk identity documents, which may be
appropriate for facilities with a low risk profile or that have a relationship with the issuing body
that mitigates the risk of fraud.
u. Identification card issued by local government (including county or city) and
containing a photograph, name, and expiration date
v. University, library, or school card containing a photograph, name, and expiration date
w. Any identification that is not state-issued, but is deemed acceptable by the FSC or DO
16 REAL ID Act of 2005 Implementation:
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Appendix C: Flow Chart for Access Control Decision
Allow
Entry
Does Visitor Have
Other Acceptable
ID?
(Ref: Appendix B)
No
No
Are Alt. Access
Control Procedures
Available and met?
(Ref: Section 4.3)
No
No
Yes
No
No
Consult
State Status
Deny
Entry
Yes
Yes
Yes
Yes
Does Visitor Present a
State-issued
Driver’s License /
Identification Card?
Is State REAL ID
Compliant or Has
an Extension?
(Ref: Appendix A)
Is ID Required for
Access Decision?
Yes
Does the facility
Ask Visitors to
Present an ID?
(Ref: Sec. 3)
