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European Signature Dialog - Associated European Trust Centers

ESD

European Signature Dialog represents leading European providers of electronic trust and signature services.

Lobbying Activity

European trust providers demand digital simplification to boost competitiveness

13 Oct 2025
Topic — The European Commission's initiative to simplify digital laws and reduce administrative burdens for businesses.
Message — The organization advocates for a single-audit framework to replace multiple overlapping inspections. They also propose delaying new legal requirements until technical standards have been finalized for three years.123
Why — Reduced administrative burdens would allow companies to focus on innovation rather than compliance management.45
Impact — Global tech giants lose their market dominance as simplified EU rules help domestic providers compete.67
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European trust providers demand longer validity for banking certificates

2 Oct 2025
Topic — The EU is setting technical standards for qualified website authentication certificates.
Message — The group calls for including specific standards to protect open banking certificates. They also demand that browsers recognize these certificates regardless of private root store programs.12
Why — This allows providers to issue long-term certificates without relying on browser company approvals.34
Impact — Web browser operators lose the authority to enforce their own security and inclusion standards.5
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Response to Sequential recording of data into qualified electronic ledgers

1 Oct 2025

Please find below the comments of the European Signature Dialogue (ESD). ESD stands as the pinnacle consortium of leading European Qualified Trust Service Providers (QTSPs). We are pleased to provide our contribution in relation to the implementing regulations of eIDAS 2 Regulation, in the spirit of supporting a clear, effective, and futureproof framework.
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Response to Qualified electronic archiving services

1 Oct 2025

Please find below the comments of the European Signature Dialogue (ESD). ESD stands as the pinnacle consortium of leading European Qualified Trust Service Providers (QTSPs). We are pleased to provide our contribution in relation to the implementing regulations of eIDAS 2 Regulation, in the spirit of supporting a clear, effective, and future-proof framework.
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Response to General requirements for qualified trust service providers

1 Oct 2025

Implementing Regulation concerning QTSP Compliance Please find below the comments of the European Signature Dialog (ESD). ESD stands as the pinnacle consortium of leading European Qualified Trust Service Providers (QTSPs). We are pleased to provide our contribution in relation to the implementing regulations of eIDAS 2 Regulation, in the spirit of supporting a clear, effective, and future-proof framework. We should carefully reflect on whether it is truly appropriate to impose such extensive additional operational burdens on QTSPs. The risk is threefold. First, compliance risks turning into pure bureaucracy rather than strengthening qualified trust services. Second, by setting requirements that are excessively numerous or practically unimplementable, we risk reaching the equivalent of the Laffer curve: beyond a certain point, more rules no longer increase trust or security but instead reduce efficiency and discourage providers from operating. Third, an excessive burden could create unintended competitive distortions, favoring only the largest players while penalizing smaller providers and limiting innovation in the ecosystem. Moreover, supervisory bodies themselves may not be structurally equipped to handle the volume and granularity of notifications and documentation required under the draft text. Against this background, we have identified a number of provisions that should be adjusted to ensure proportionality, legal certainty, and operational feasibility.
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Response to Management of remote qualified signature creation devices as a qualified trust service

12 May 2025

The European Signature Dialog (ESD) is an initiative that represents the leading European Qualified Trust Service Providers (QTSPs), that play a crucial role in enabling secure digital interactions across Europe, facilitating communication and transactions between public entities, businesses, and individuals.we appreciate the opportunity to provide our detailed comments and feedback on the proposed Commission Implementing Decisions. We believe that our insights will contribute to the effective functioning of the Digital Single Market and support the continued excellence of European market.
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Response to Notification and verification of the initiation of a qualified trust service

12 May 2025

The European Signature Dialog (ESD) is an initiative that represents the leading European Qualified Trust Service Providers (QTSPs), that play a crucial role in enabling secure digital interactions across Europe, facilitating communication and transactions between public entities, businesses, and individuals. we appreciate the opportunity to provide our detailed comments and feedback on the proposed Commission Implementing Decisions. We believe that our insights will contribute to the effective functioning of the Digital Single Market and support the continued excellence of European market.
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Response to Notification of qualified electronic signature & seal creation devices that have been certified by certification bodies

12 May 2025

The European Signature Dialog (ESD) is an initiative that represents the leading European Qualified Trust Service Providers (QTSPs), that play a crucial role in enabling secure digital interactions across Europe, facilitating communication and transactions between public entities, businesses, and individuals. We appreciate the opportunity to provide our detailed comments and feedback on the proposed Commission Implementing Decisions. We believe that our insights will contribute to the effective functioning of the Digital Single Market and support the continued excellence of European market.
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Response to Qualified preservation services for qualified electronic signatures and for qualified electronic seals

12 May 2025

The European Signature Dialog (ESD) is an initiative that represents the leading European Qualified Trust Service Providers (QTSPs), that play a crucial role in enabling secure digital interactions across Europe, facilitating communication and transactions between public entities, businesses, and individuals. We appreciate the opportunity to provide our detailed comments and feedback on the proposed Commission Implementing Decisions. We believe that our insights will contribute to the effective functioning of the Digital Single Market and support the continued excellence of European market.
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Response to Verification of identity and attributes at qualified certificate or qualified attestation of attributes issuance

12 May 2025

The European Signature Dialog (ESD) is an initiative that represents the leading European Qualified Trust Service Providers (QTSPs), that play a crucial role in enabling secure digital interactions across Europe, facilitating communication and transactions between public entities, businesses, and individuals. We appreciate the opportunity to provide our detailed comments and feedback on the proposed Commission Implementing Decisions. We believe that our insights will contribute to the effective functioning of the Digital Single Market and support the continued excellence of European market.
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Response to Requirements for qualified electronic registered services

12 May 2025

The European Signature Dialog (ESD) is an initiative that represents the leading European Qualified Trust Service Providers (QTSPs), that play a crucial role in enabling secure digital interactions across Europe, facilitating communication and transactions between public entities, businesses, and individuals. We appreciate the opportunity to provide our detailed comments and feedback on the proposed Commission Implementing Decisions. We believe that our insights will contribute to the effective functioning of the Digital Single Market and support the continued excellence of European market.
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Meeting with Alexandra Geese (Member of the European Parliament)

29 Apr 2025 · Event: Digital Future Dialogue

Response to Technical description of important and critical products with digital elements

16 Apr 2025

The European Signature Dialog (ESD) stands as the pinnacle consortium of leading European Qualified Trust Service Providers (QTSPs), facilitating secure digital interactions across Europe every day. ESD has successfully collaborated with all institutions leading up to the adoption of eIDAS 2. We would like to take the opportunity to comment on the draft of the implementing act based on the Cyber Resilience Act (CRA). We welcome the European Union's efforts to strengthen the cybersecurity of digital products. However, we would like to point out a potential overlap and inconsistency that could arise from the application of the CRA to Qualified Trust Service Providers whose services and associated software components are already subject to comprehensive regulatory requirements and conformity assessments.
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Response to Qualified electronic attestation of attributes under the EDIF

31 Dec 2024

The European Signature Dialog (ESD) stands as the pinnacle consortium of leading European Qualified Trust Service Providers (QTSPs), facilitating secure digital interactions across Europe every day. ESD members are European Qualified Trust Service Providers (QTSPs) with extensive expertise in the trust services market. We welcome the release of the second set of draft proposals of Implementing Acts (IAs) as an essential foundation for the implementation of the EUDIW. However, ESD believes that the points outlined attached can lead to significant improvements, a more consistent implementation, and, as a result, better interoperability and overall acceptance of the Wallet.
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European Signature Dialog Urges Use of Qualified Trust Services

31 Dec 2024
Topic — Rules for the registration and authentication of relying parties using European Digital Identity Wallets.
Message — The organization recommends leveraging existing trust services and qualified certificates issued by established providers. They propose adopting the successful banking sector model for identifying and authenticating parties. They also request that only listed providers be permitted to issue wallet access certificates.123
Why — These proposals would secure the market dominance of established European trust service providers.456
Impact — Non-qualified providers and tech startups face exclusion from the wallet security infrastructure.7
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Response to Cross-border identity matching under the European Digital Identity Framework

31 Dec 2024

The European Signature Dialog (ESD) stands as the pinnacle consortium of leading European Qualified Trust Service Providers (QTSPs), facilitating secure digital interactions across Europe every day. ESD members are European Qualified Trust Service Providers (QTSPs) with extensive expertise in the trust services market. We welcome the release of the second set of draft proposals of Implementing Acts (IAs) as an essential foundation for the implementation of the EUDIW. However, ESD believes that the points outlined attached can lead to significant improvements, a more consistent implementation, and, as a result, better interoperability and overall acceptance of the Wallet.
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Response to Security breaches of European Digital Identity Wallets

31 Dec 2024

The European Signature Dialog (ESD) stands as the pinnacle consortium of leading European Qualified Trust Service Providers (QTSPs), facilitating secure digital interactions across Europe every day. ESD members are European Qualified Trust Service Providers (QTSPs) with extensive expertise in the trust services market. We welcome the release of the second set of draft proposals of Implementing Acts (IAs) as an essential foundation for the implementation of the EUDIW. However, ESD believes that the points outlined attached can lead to significant improvements, a more consistent implementation, and, as a result, better interoperability and overall acceptance of the Wallet.
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European trust centers call for unified digital wallet certification

9 Sept 2024
Topic — Consultation on implementing acts for the European Digital Identity Wallets and eIDAS2 framework.
Message — 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.123
Why — A unified certification process reduces the burden of maintaining separate approvals in every member state.4
Impact — State-owned organizations could lose unfair competitive advantages gained through early access to national schemes.5
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European Trust Providers Demand Unified EU Digital Wallet Certification

9 Sept 2024
Topic — Technical regulations establishing the trust framework for the European Digital Identity Wallet.
Message — 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.12
Why — A single certification process would lower costs and simplify cross-border business operations.3
Impact — National authorities would lose the ability to favor their own state-owned wallet solutions.4
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European Signature Dialog seeks unified EU-wide digital wallet certification

9 Sept 2024
Topic — Technical standards for managing personal identification data and attributes within European identity wallets.
Message — 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.12
Why — Unified certification would prevent overwhelming costs associated with maintaining separate approvals in every country.3
Impact — Private companies lose if state-owned organizations gain unfair advantages through early national schemes.4
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European Signature Dialog Urges EU-Wide Digital Wallet Certification

9 Sept 2024
Topic — Implementing rules for the protocols and interfaces supporting European Digital Identity Wallets.
Message — The group demands a single EU-wide certification system to prevent fragmented national schemes. They urge the inclusion of technical standards and restrict access to qualified providers.123
Why — A unified certification process reduces administrative burdens and prevents national barriers to market access.45
Impact — State actors lose competitive advantages gained from developing architectures alongside national certification schemes.6
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Response to Rules specifying the obligations laid down in Articles 21(5) and 23(11) of the NIS 2 Directive

23 Jul 2024

We are pleased to share our Comments of the European Signature Dialog (ESD) on the Draft of NIS2 Implementing Regulation. ESD stands as the pinnacle consortium of leading European Qualified Trust Service Providers (QTSPs), facilitating secure digital interactions across Europe every day. ESD experts possess decades of practical experience and have effectively collaborated with the European Institutions in the adoption of key digital legislation such as NIS2 and eIDAS 2. This document focuses on our insights into the Draft NIS2 implementing Regulation.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

1 Jun 2023 · e-identity

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur)

22 May 2023 · European Digital Identity Framework (eID)

Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

12 May 2023 · European Digital Identity

Response to European Digital Identity (EUid)

2 Sept 2021

Please find attached the preliminary positions of the European Signature Dialog (ESD) regarding EC Proposal for a Regulation of the European Parliament and of the Council, amending Regulation (EU) No 910/2014 as regards establishing a framework for a European Digital Identity. ESD represent the leading European trust service providers. We highly welcome the actual Proposal for the eIDAS regulation from the European Commission. It's very ambitious and it is an important step forward to harmonize the European Digital Single Market. But although the current version has already cleared up many ambiguities regarding the original regulation, we also want to stress critical amendments to be made. We would be happy to provide more information and further elaborate on the topics expressed in our attached contribution, and we remain at your complete disposition.
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Response to European Digital Identity (EUid)

1 Sept 2020

European Signature Dialog would like to contribute and support the European Commission in the goal to establish trust in electronic transactions in the internal market, secure interoperability and also cybersecurity and thus enhance transparency and consumer protection. Please refer to the document attached for detailed information. Accordingly, with reference to the three options set out in the EU Commission's inception impact assessment, ESD members strongly encourage to further specify the regulation through THREE CRITICAL IMPROVEMENT PROGRAMS: 1. OPERATIVE PROGRAM: Increase safety, efficiency and trustworthiness of cross-border interactions 2. HARMONISATION PROGRAM: Enforce harmonisation and standardisation across member states 3. SUPPORT PROGRAM: Establish an advisory/administrative body to support the industry by implementing eIDAS Please refer to the document attached for detailed information regarding these three programs.
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Meeting with Juhan Lepassaar (Cabinet of Vice-President Andrus Ansip), Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip), Vivian Loonela (Cabinet of Vice-President Andrus Ansip)

5 Apr 2019 · eIDAS Regulation, cybersecurity, cross-border trust services