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Trust framework

Digital economy and society

The implementing act provides the necessary provisions to ensure that the electronic notification system established by the European Commission acts as a secure and transparent communication channel between the Commission and the Member States for exchanging information.

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Public consultation

ID: 14338

Lobbying Activity

12 responses

GSMA Europe flags privacy and cost concerns for digital wallets

GSMA Europe, 9 Sept 2024

GSMA calls for advanced privacy techniques to prevent tracking and ensure data protection compliance. They also suggest using more flexible security hardware to avoid high implementation costs.
More flexible security requirements would reduce costs and complexity for mobile operators.
Citizens face privacy risks if the technical standards allow tracking of their behavior.

European banking groups demand mandatory biometrics for digital wallets

European Savings and Retail Banking Group, 9 Sept 2024

The associations demand mandatory biometrics in identification data and a standardized European notification system. They also call for strict service level agreements to ensure minimal system downtime.
Standardised rules and mandatory biometrics would lower administrative costs and reduce fraud liability.
Fraudsters lose opportunities for identity theft through stricter, biometric-based user binding requirements.

Visa Europe urges technical alignment in EU digital wallet standards

Visa Europe, 9 Sept 2024

Visa Europe requests transparency on how existing technical standards will align with new regulations. They suggest creating a review process where industry can provide input on rapid technological developments.
Consistent standards would reduce development risks and grant Visa influence over future technical requirements.
Discrepancies in standards could undermine current large-scale pilot projects already developing digital identity solutions.

DLR urges more technical detail for EU digital identity

Deutsches Zentrum für Luft- und Raumfahrt e.V., 5 Sept 2024

The DLR requests more detailed technical standards to ensure harmonized implementation across Europe. They suggest clarifying roles for security enforcement and including use cases for Self-Sovereign Identity.
Standardization would support DLR’s research in fields like autonomous driving and maritime security.
Member States could lose flexibility if more rigid technical standards are mandated early on.

epicenter.works: EU Digital Wallet Draft Lacks Human Rights Safeguards

epicenter.works - Plattform Grundrechtspolitik, 9 Sept 2024

The group urges negotiators to reject the draft and include mandatory privacy protections. They demand inclusion of a missing act to prevent over-identification.
This prevents service providers from tracking user behavior and correlating private transactions.
Users face significant risks of data leakage if revocation details are made public.

Bundesdruckerei Advocates Mandatory eIDAS Security in EU Communications

Bundesdruckerei GmbH, 6 Sept 2024

The organization requests that Annex II mandate the use of eIDAS security means. They propose that every certificate and URL must be secured using these standards.
Mandating eIDAS standards would create a captive market for the company's certified security products.
Security providers using alternative, non-eIDAS standards would be excluded from the notification system.

European Trust Providers Demand Unified EU Digital Wallet Certification

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

The group calls for a single EU-wide certification system instead of separate national schemes. They also demand explicit references to technical standards and electronic signature interfaces.
A single certification process would lower costs and simplify cross-border business operations.
National authorities would lose the ability to favor their own state-owned wallet solutions.

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…

French consumer group warns against digital wallet's exclusionary risks

Information et défense des consommateurs salariés – Confédération générale du travail, 2 Sept 2024

The organization asserts the principle of digital inclusion as fundamental to leave no one behind. They demand deep reflection with consumer associations regarding digital developments in the economic sector.
This would help the organization fulfill its mission of protecting consumers from overspending.
Low-income earners and the digitally illiterate face financial harm and social exclusion.