The Identity Assurance page, while containing valuable guidance, is not applicable to systems or to interoperability. For example:

• There are SHALLs that govern human processes (e.g. review photo ID).
• There are SHALLs to collect demographics and assess IAL levels, but no way to test to prove any of this has been done (no evidence of IAL in any interoperability spec, no requirements to persist or to make available in any way).

Consider: moving this guidance to a whitepaper, relaxing SHALLs to SHOULDs, tying requirements to APIs when possible, explicitly identifying these requirements as not testable, etc.