OpenLobby.EU
Explore

Functionalities and integrity of European Digital Identity Wallets

Digital economy and society

The implementing act provides the necessary provisions to ensure that Member States set-up of European Digital Identity Wallets that are interoperable and that successfully enable the use of the European Digital Identity Wallets for all their intended purposes. These include secure online cross-border identification for a wide range of public and private services, as well as functionalities to enable the sharing of various electronic documents and the issuance of electronic signatures.

Links

Public consultation

ID: 14341

Lobbying Activity

17 responses

Amazon urges EU Digital Identity Wallets to support passkeys

Amazon Europe Core SARL, 9 Sept 2024

Amazon recommends that digital wallets support passkeys for authentication. They suggest wallet providers act as passkey providers or use existing credential managers. This ensures platforms are not forced to use less secure options.
Amazon would benefit from standardized security while avoiding integration with less secure authentication systems.
Providers of legacy authentication technologies lose market share to standardized passkey systems.

GSMA warns EU digital wallet rules threaten privacy and adoption

GSMA Europe, 9 Sept 2024

The GSMA calls for better privacy protections and more flexible hardware requirements. They request that data portability be offered at cost-covering rates to ensure business sustainability.
This would lower hardware deployment costs and protect the industry's profit margins.
Users face privacy risks because current standards allow issuers to track their activities.

European banking group urges more detail on digital wallet rules

European Savings and Retail Banking Group, 9 Sept 2024

The group believes the draft regulation requires more detail and clarity on core functions. They suggest making the possibility for users to add biometrics to the identity mandatory. They also recommend that transaction logs include details of the mutual authentication protocol.
Automated onboarding would help banks lower operational costs and improve their customer satisfaction.
Consumers could lose access to services if banks reject identification during wallet system outages.

Visa Europe urges technical alignment for EU digital identity wallets

Visa Europe, 9 Sept 2024

Visa requests transparency on how new rules will align with previous technical frameworks to avoid discrepancies. They suggest a regular review process involving industry to react to rapid market developments. The Commission should ensure a level playing field between wallet providers and hardware manufacturers.
This prevents mobile device manufacturers from using hardware control to gain an unfair competitive advantage.
Dominant tech giants may lose the ability to restrict competitors from accessing essential smartphone hardware.

Epicenter.works warns EU digital wallet lacks critical privacy protections

epicenter.works - Plattform Grundrechtspolitik, 9 Sept 2024

The organization calls for the draft proposal to be rejected and renegotiated to include human rights and privacy safeguards. They demand the inclusion of missing rules to prevent over-identification and the implementation of technical features that ensure user anonymity.
Strengthening these protections would ensure the wallet complies with European law and maintains public trust.
Citizens face serious risks of being tracked and having their sensitive personal data exposed.

Bundesdruckerei Urges Technical Alignment for European Digital Wallets

Bundesdruckerei GmbH, 6 Sept 2024

They request aligning regulation wording with existing frameworks to avoid misunderstandings. They seek clear legal definitions for signature applications. They also suggest adding the SD JWT data format.
Uniform technical standards provide the company with legal certainty for development.
Implementation becomes difficult for developers when regulatory requirements are contradictory and misleading.

United Internet warns high security hurdles hinder Digital Wallet adoption

United Internet AG, 5 Sept 2024

United Internet warns that requiring rigorous authentication upfront for all applications creates an unnecessary hurdle. They suggest authentication should instead be performed at a level appropriate to each specific use case.
Lower security barriers help the company integrate the wallet into its consumer web services.
American tech giants face increased competition from a more user-friendly European identity alternative.

German Banking Industry urges clearer standards for EU Digital Wallets

Die Deutsche Kreditwirtschaft, 9 Sept 2024

The group demands specific requirements to ensure technical and legal interoperability across Europe. They propose incorporating established technical definitions and allowing flexible transaction logging for users.
Uniform standards would eliminate the need for costly intermediaries and prevent national over-regulation.
Technical intermediaries lose revenue if the EU eliminates the need for cross-border converters.

Czech Chamber urges wallet blocking and continuity procedures

Hospodářská komora České republiky, 3 Sept 2024

The chamber asks for functions allowing providers to temporarily block wallets and set unblocking conditions. They also highlight the need for procedures when a provider terminates its operations.
Clear protocols for blocking and business exit would reduce operational risks for providers.
Digital identity users suffer if service operation ceases without a clear handover plan.

European trust centers call for unified digital wallet certification

European Signature Dialog - Associated European Trust Centers, 9 Sept 2024

The European Signature Dialog requests a single EU-wide certification system and explicit references to technical standards. They argue for using qualified trust service providers to issue access certificates to ensure cross-border interoperability.
A unified certification process reduces the burden of maintaining separate approvals in every member state.
State-owned organizations could lose unfair competitive advantages gained through early access to national schemes.

Consultation response

Koninklijke Notariële Beroepsorganisatie, 9 Sept 2024

Remarks by the Royal Dutch Association of Civil-law Notaries (KNB) with regard to the Commission Implementing Regulations Laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and the Council. As the professional organization for notaries in The…

Consultation response

Institut Mines-Telecom, 9 Sept 2024

The attached document contains our analysis of all five draft implementing acts for the European Digital Identity Wallet.

Consultation response

IDEMIA France, 9 Sept 2024

IDEMIA very much welcomes these five draft Implementing Regulations of the eIDAS regulation. They will be instrumental for the large deployment and successful uptake of the digital identity wallet throughout Europe. IDEMIA would like however to share some comments on these five draft Implementing…

Consultation response

InfoCert SpA, 9 Sept 2024

InfoCert SpA, part of the Tinexta Group, is the biggest QTSP in Europe, operating in more than 60 Countries worldwide and aiming at building the European Digital Champion of Trust with solid institutional roots. Our main shareholders are, in fact, the main Italian Chambers of Commerce and we play…

Consultation response

Eurosmart, 9 Sept 2024

Privacy-by-design and Users control should prevail in the respect of the EU fundamental rights Eurosmart has listed several privacy concerns that deserve clarification in the implementing act integrity and core functionalities. These concerns are echoing Eurosmarts comments on the certification…

Consultation response

The Fast Identity Online (FIDO) Alliance, 9 Sept 2024

The Fast Identity Online (FIDO) Alliance appreciates the opportunity to submit comments to the European Commission (EC) on the Draft Implementing Act for European Digital Identity Wallets Integrity and Core Functionalities. As background, the FIDO Alliance is a multi-stakeholder, public-private,…

Consultation response

LCubed AB, 7 Sept 2024

Our comments from iGrant.io (Sweden) are in a separate attachment, as they exceed the 4000-character limit.