Public-record wave by Nova. Findings concern the records and versions identified below; no outreach, paid access, publication or implementation testing. Raw PDFs were inspected in memory, not saved. Candidate graph imports are in icmec-candidate.json.
What moved
The public financial record changes the picture from a presumed well-resourced intermediary to an organisation with substantial financing dependence. It does not identify an age-policy funder. Legislative records reveal negotiated adaptation, including identifiable alternatives and an author’s response, rather than unchanged adoption of an NGO template. A separate historical record does establish payment-company funding of ICMEC policy roundtables.
Financial perimeter and funding
ICMEC’s [2024 consolidated audit](http[local research file] issued 29 January 2026, covers US ICMEC and its Singapore affiliate, not ICMEC Switzerland. It reports a $2,293,789 net-asset deficit at 31 December 2024 and $817,886 of programme-restricted assets. Its going-concern discussion identifies dependence on unrestricted fundraising; management reports signed 2026 grants/contracts. Note 2 records board-member and Swiss-affiliate borrowing. Note 9 records a US-government stop-work order dated 27 January 2025. These are historical accounts, not a September 2026 balance sheet. Locators: printed pp9,12–16; going concern p15; one-based PDF pages10,13–17. The audit says staff allocations use biweekly timesheets; underlying programme allocation records should therefore exist.
The [2024 Form 990](http[local research file] names board members Franz Humer, Sally Paul and Rick Li as interested persons in operating-fund loans, with $1,117,000 aggregate outstanding in Schedule L, Part II; explanatory Part V follows (PDF pages42–43). “Interested person” is not automatically the legal lender: the audit identifies ICMEC Switzerland for some loans. Row extraction did not justify assigning every amount to a person. Schedule C, Part II-A (PDF p28) reports $996 direct lobbying and zero grassroots lobbying in FY2024. This predates AB1043 and does not disclose its budget. The programme reporting inspected does not isolate age-policy expenditure.
ICMEC’s [supporters page](http[local research file] lists Meta among $25,000-plus general supporters as of 1 May 2023; a separate Financial Coalition section names payment/financial firms without amounts. Neither establishes a 2025 legislative earmark.
A more concrete historical route appears in [ICMEC’s APFC roundtable account](http[local research file] a PayPal grant enabled country roundtables; Microsoft and law firms supplied in-kind resources; resulting working groups included Australia, whose institutional home was the Australian Payments Network’s Fraud in Banking Forum. This establishes recipient-reported resource mobilisation and institutional follow-through. The undated page refers to activity since 2013; no grant amount, age-policy earmark or current financing arrangement is disclosed.
Drafts, decisions and operative design
| Record | New decision or boundary established |
|---|---|
| [ICMEC model legislation](http[local research file] pp2–4 | Proposes OS/device age signals, parental consent for under-16 downloads, and adult-content blocking. Title calls it an Act of 2025; the upload-directory date is not independently verified publication timing. |
| [Technical whitepaper, 7 February 2025](http[local research file] p5 | Proposes OS-provider review/approval of website API integrations and agreed use cases. This is a proposed admission function, not proof that a law or deployed API grants those powers. |
| [AB1043 APCP analysis, 22 April 2025](http[local research file] March28 version, pp1–4,16 | Lists ICMEC and Children Now as co-sponsors; the then-current design includes six age bands and parental download consent. |
| [Senate Judiciary analysis, 15 July 2025](http[local research file] May23 version, pp16–17,19 | Records stakeholder technical/scoping concerns and the author’s agreement to narrow the application definition by removing online services/products/features. It identifies speech concerns about download-consent restrictions. Only Children Now is listed as sponsor; this roster difference alone does not establish ICMEC’s withdrawal or motive. |
| [AB1043 chaptered text](http[local research file] Chapter675, 13 October 2025 | Enacted age-signal framework, operative January2027, differs from the model: four bands and account-entered age; the inspected text lacks the earlier parental-download consent and broad website scheme. It includes data minimisation and non-discrimination. The whitepaper’s per-website API approval mechanism is not established by this text. |
| [AB1856 APCP analysis, 21 April 2026](http[local research file] April6 version, pp5–6 | Identifies an MPA memo seeking a family-account carveout and an option to block minors. The author instead chooses a generally applicable clarification of conflicting age evidence. Committee discussion criticises a general minor-exclusion option. Proposed browser/website duties are explicitly described. |
| [AB1856 enrolled text](http[local research file] and [official status](http[local research file] checked 8 September 2026 | Enrolled September1, presented to Governor September4 at4pm; no signature shown. Current text contains an open-source OS exclusion and account-setup limitation. It omits the April browser/website scheme. Treat this as pending legislation, not operative law. |
The April2026 committee account is a credible counterpart to the previously failed Wicks-page capture. It supplies named requests, deliberation and an alternative actually chosen, although the MPA memorandum itself remains unacquired. The current record supports selective template diffusion and local negotiation; it does not establish donor control of drafting.
Access and ancestry
Both financial PDFs returned ordinary HTTP200 and were read using pypdf. Audit: 429,674 bytes; SHA256 277651b6bccf9ca39e565f8e515fed219a95a56cf5f3996ecfce0ceb61b6b2fc. Return: 557,097 bytes; SHA256 553fb43c3deed524f2288fa96661f756d83fa9925535a7a7de890328553ee991. Web PDF screenshot routes produced no usable financial image (cache misses on attempted audit/990 pages); no visual row alignment is claimed. The two documents provide different financial disclosures but remain records supplied by the same organisation, not independent donor confirmation.
The official AB1043 version selector was read through ordinary HTTP200. It exposes introduced February20; amendments March28, April24, May23, July23, September5; enrolled September16; chaptered October13, all2025. Direct web opens using &version=20250AB104399INT and &version=20250AB104395AMD failed with InternalError; these failures do not mean historical texts are absent. Version-specific committee PDFs and the chaptered statute were the successful substitute. Exact amendment-by-amendment attribution of every deletion remains unfinished. No repeat of the unchanged Wicks raw-capture failure was attempted.
ICMEC model and whitepaper are one organisational source family; copies elsewhere are not corroboration. Committee analyses are official accounts, but attributed stakeholder arguments are not committee findings. This bounded pass inspected public finance, organisational programme/supporter pages and official legislative routes; it was not an exhaustive donor-record search.
Consequential missing joint
The best next financial holder record is ICMEC’s 2024–26 age-assurance project ledger/cost-centre allocation, linked grant schedules and approval record. Ask ICMEC voluntarily for who paid for model/whitepaper production and legislative engagement, amounts, dates, restrictions and approval rights. The audit indicates time-allocation records exist; it does not prove a distinct age-policy cost centre exists. Unrestricted funding, earmarked drafting support and commercial deliverables imply materially different relationships.
For design lineage, seek the MPA memorandum already described by the April2026 committee and the author/committee’s amendment instructions or stakeholder submissions. Public committee holdings are the first route; otherwise request from the holders without assuming a particular legal access entitlement. The discriminating issue is who proposed the surviving and deleted provisions, not who appeared on a general supporter list. Actual OS API admission terms would distinguish a mandatory neutral signal service from discretionary commercial gatekeeping; the whitepaper alone cannot settle that implementation question.