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Person identification data and electronic attestations of attributes issued to European Digital Identity Wallets

Digital economy and society

The implementing act provides guidelines to ensure the smooth lifecycle management of both personal identification data and electronic attestations of attributes, covering issuance, verification, revocation, or suspension. It guarantees that users' personal identification data and electronic attestation of attributes are issued to the wallet and can be disclosed to relying parties.

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Public consultation

ID: 14340

Lobbying Activity

17 responses

Amazon seeks clarity and user control for EU digital wallets

Amazon Europe Core SARL, 9 Sept 2024

Amazon wants clear definitions for legal entities and requests that users have the power to delete their own identity data. They also suggest adding contact details like emails as mandatory attributes to make account creation easier.
Making contact data mandatory would streamline customer registration for Amazon’s various online services.
Identity data providers lose the ability to restrict which wallet solutions they support.

GSMA warns EU digital identity rules risk privacy and usability

GSMA Europe, 9 Sept 2024

GSMA requests including state-of-the-art privacy features like Zero-Knowledge Proof to ensure full GDPR compliance. They suggest using hardware security modules to avoid high costs of specific smartphone chips. The group also proposes mandatory five-minute revocation windows and batch revocation to improve system efficiency.
Flexible hardware requirements would lower costs and simplify the deployment of identity services.
Citizens risk privacy gaps and poor user experiences under the currently proposed technical standards.

European banking group urges mandatory biometrics for digital wallets

European Savings and Retail Banking Group, 9 Sept 2024

The group requests a mandatory set of data including biometrics and addresses. They also recommend a structured format for personal birth details.
Banks would lower costs and prevent fraud using passport-grade digital verification.
Privacy-conscious users face higher risks if sensitive biometric data is compromised.

Visa Europe Urges Technical Consistency for EU Digital Wallets

Visa Europe, 9 Sept 2024

Visa Europe calls for alignment between the draft rules and existing technical frameworks. They also propose making user notifications for revoked credentials a best-effort requirement.
Alignment protects investments by ensuring new rules match systems developed during pilot programs.
Wallet users may not receive vital updates if notification requirements become optional.

epicenter.works Warns EU Digital Identity Wallet Lacks Privacy Safeguards

epicenter.works - Plattform Grundrechtspolitik, 9 Sept 2024

The organization demands the inclusion of robust human rights and privacy protections mandated by the eIDAS Regulation. They request mandatory support for pseudonyms and technical measures to prevent user tracking across different interactions.
These changes would ensure the wallet respects fundamental rights and maintains public trust in digital identity systems.
Users face significant risks of over-identification, behavioral tracking, and the public leakage of sensitive personal information.

Bundesdruckerei urges stricter identity standards for EU wallets

Bundesdruckerei GmbH, 6 Sept 2024

Bundesdruckerei requests that only qualified trust service providers issue access certificates. They also suggest adding address data and age verification to ensure unique identification.
This would protect their market position by excluding non-qualified trust service competitors.
Non-qualified service providers would be excluded from issuing wallet access certificates.

German banking industry urges standardized EU digital wallet data

Die Deutsche Kreditwirtschaft, 9 Sept 2024

The group demands uniform technical standards to prevent countries from imposing stricter national rules. They call for mandatory data sets to ensure secure EU-wide customer identification.
Standardization would allow banks to perform identity checks without using expensive intermediaries.
Intermediary firms would lose revenue if cross-border data conversion services are no longer required.

Czech Chamber of Commerce demands clearer technical standards for EU Wallet

Hospodářská komora České republiky, 3 Sept 2024

The organization requests more detailed technical specifications rather than general descriptions. They propose creating a working group to define standards and incorporating advanced technologies like post-quantum cryptography.
Clearer technical standards would prevent costly legal disputes between different national certification authorities.
Users could face inconsistent security standards across different countries, undermining overall trust.

German tax consultants urge including business representation in EU wallets

Bundessteuerberaterkammer, 2 Sept 2024

The organization highlights the need to regulate how individuals act on behalf of companies. They request a simple way to exchange data connecting natural and legal persons. Missing rules could lead to isolated, non-interoperable solutions across different member states.
Including business identities would reduce costs and support digital transformation for tax professionals.
The digital single market loses if countries implement fragmented, non-interoperable identity solutions.

European Signature Dialog seeks unified EU-wide digital wallet certification

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

The group advocates for a single EU-wide certification system to enhance cross-border trust. They call for explicit technical standards to prevent fragmented national implementations of wallet solutions.
Unified certification would prevent overwhelming costs associated with maintaining separate approvals in every country.
Private companies lose if state-owned organizations gain unfair advantages through early 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

European Digital Identity Wallets Person Identification data and Electronic Attestations of Attributes: Principle of Data Minimisation Definitions: The different implementing acts should clearly state that critical assets should be protected (PID attestations etc.) in integrity, authenticity and…

Consultation response

LCubed AB, 7 Sept 2024

The comments provided earlier (F3491039 and F3492347) also apply to this IA. Following is the additional feedback: Article 3 - Issuance of Person Identification Data to Wallet Units: Article 3(3): The IETF SD-JWT seems missing, and schema definitions for Legal Person Identification Data need to be…

Consultation response

Instytut na rzecz Kultury Prawnej Ordo Iuris, 6 Sept 2024

Proponuje się następujące poprawki: Poprawka 1.: W artykule 3, w ust. 4, po słowach Państwa członkowskie zapewniają, aby zestaw danych identyfikujących osobę, powiązanych z danym portfelem, był unikatowy należy dodać oraz, w wypadku osób fizycznych, zgodny z danymi ujawnionymi w rejestrach aktów…