Platforms would not be allowed to compel users to provide government-issued identity documents including passports or driver's licenses, nor could they demand digital identification through a government system.

This leaves a lot of room for bad acting. The data collector need not compel. They can have 3 methods available but have 2 be a hot mess of unreliability.

FacRec has unreliability baked in - increasingly so, the further from white ones skin is.