corruption, and benefit from the tax generated by wider inclusion in the formal economy. Each government agency can separately determine the person’s eligibility for any particular status, including citizenship; but the initial identification process does not need to do so (World Bank, 2016, 2019b). The approach provides a short cut to proof of identity, seeking to sidestep – or at least delay – difficult questions around determination of eligibility for citizenship that held back the creation of a national identity card in India for many years (Sen, 2019). User satisfaction with the Aadhaar system is generally high (State of Aadhaar: A People’s Perspective, 2019) The Bank has supported a number of mass biometric enrolment efforts for adults into newly established or upgraded national population registers, rooted in the desire to enable comprehensive access to identification for the ‘stock’ of all adult residents of a country, without waiting for the ‘flow’ of birth registration to populate a register (World Bank, 2019a, p. 8), drawing on this example. In general, however, the Aadhaar approach has not been replicated. Although Nigeria and the WURI states (Côte d’Ivoire and Guinea, in the first phase) are enrolling residents and issuing identity numbers based on biometric data, the legislative foundation remains the usual national identity card model, establishing a register that records legal status as citizen or non-citizen – but without any procedure to resolve the status of those with no existing documents. This has caused some confusion: in Nigeria there has been an official denial that the national identity card was being substituted by biometric registration only (Centre for Democracy and Development, 2020); but in other fora the decoupling has been affirmed (ID4Africa, 2020). The WURI project also supports the strengthening of national legal and institutional frameworks, including new laws for data protection where none existed (World Bank, 2018f, p. 36). In Togo, one of the second phase countries for WURI, a new law was adopted in September 2020 that provided for a new biometric database of residents to be the foundation of all identification purposes, integrating provisions on data protection (Assemblée Nationale du Togo, 2020). Unlike national identity card laws, the Togolese legislation proposes no record of nationality; like them, it has no formal link to the civil registration system, but at the same time it proposes capturing some of the same data (date and place of birth, names of parents). The rest of the UN system has pushed back against delinking the SDG ‘legal identity’ target from civil registration. An inter-agency expert working group was established in 2018 to discuss the issues, leading to the adoption of an agreed definition that underlines both the significance of the concept and the difficulty of tying down what it should encompass in simple terms (UN Legal Identity Expert Group, 2019; UN Economic and Social Council, 2019): Legal identity is defined as the basic characteristics of an individual's identity. e.g. name, sex, place and date of birth conferred through registration and the issuance of a certificate by an authorized civil registration authority following the occurrence of birth. In the absence of birth registration, legal identity may be conferred by a legally-recognized identification authority. This system should be linked to the civil registration system to ensure a holistic approach to legal identity from birth to death. Legal identity is retired by the issuance of a death certificate by the civil registration authority upon registration of death. The importance of this different approach is that while civil registration, in particular birth registration, does not (usually) record nationality or legal status in a country, or guarantee that either can be secured, it does record the information on the basis of which nationality, 7