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Concept note · 24 September 2026

Luminal: a trust layer for public services

Is this a real person, and if it is an AI agent, whose is it and what may it do?

Concept note by Maggie Hall. Not yet built.

Summary

Luminal is a public-interest trust layer that answers two questions at the door of public services: is this a real person, and if it is an AI agent, whose is it and what may it do?

It combines an open Agent Disclosure Standard with privacy-preserving human presence verification. It is stewarded by a not-for-profit so that no AI company controls the rules its own agents must follow.

The problem

On 18 June 2026 an OpenAI agent accessed public and non-public files on the Medicare Statistics Reporting Service portal, run by Services Australia (ABC News).

DateEvent
24 Sep 2026Australian public told
10 Sep 2026OpenAI emails a Services Australia public inbox
Aug 2026OpenAI becomes aware during an internal review
18 Jun 2026Agent accesses the portal

The agent was not told to break in. It was running an internal evaluation, looking up Australian statistics, and went beyond its instructions (SBS News). Three other sites may be affected: AIHW, NSW BOCSAR and the Victorian Department of Health.

Three gaps made this possible:

The Agent Disclosure Standard

Before an AI agent touches a participating public site, it must declare who operates it and why it is there. The site then applies its own published rules.

  1. An AI agent arrives and declares its operator, purpose and contact.
  2. The site checks the declaration against its published rules.
  3. If allowed: read-only access, logged. If not: refused, and the operator is notified.
  4. An agent with no declaration is treated as unknown and blocked or limited.

Each agent declaration carries four things:

  1. Operator: the company or person responsible, verifiable by signature.

  2. Purpose: a short statement of the task, such as research or form submission.

  3. Contact: a monitored address for incidents, not a general inbox.

  4. Scope requested: what it wants to read or do.

Each site publishes a simple rules file, for example:

Under this standard, the Medicare agent would have been refused at the non-public files, and the site would have had a log naming OpenAI on day one.

Human presence verification

Luminal proves a real person is present without anyone holding their biometric data. The check happens on the person's own device and only a yes-or-no proof leaves it.

This is the key difference from big-tech approaches such as World's iris scanning, which rely on a company-run registry. After this incident, "we never hold your data" is the stronger promise.

Governance and structure

The standard is owned by a not-for-profit steward; the technology is licensed commercially. That split is what big tech cannot offer: neutral rules not written by the companies being regulated.

EntityRoleIncome
Project Humanity (planned not-for-profit)Owns and maintains the Agent Disclosure Standard; policy submissions; public register of agent operatorsGrants, government funding, membership
Co-Synthesist Pty LtdBuilds and licenses the verification technology and site integrationsLicences, integration contracts

The founder's background as a former Member of the Migration and Refugee Review Tribunals brings experience in fair process, evidence and accountability to the steward role.

Pilot and next steps

Start with one small public-facing site, not Services Australia. A working local deployment is the proof that opens larger doors.

Possible pilot partners: a Newcastle-area council, a community health service, or a social housing tenant portal.

Sources