OpenLobby.EU
Explore

Gospodarska zbornica Slovenije

GZS

Gospodarska zbornica Slovenije je največja, najmočnejša in najvplivnejša povezava gospodarstva v Sloveniji.

Lobbying Activity

Response to Sequential recording of data into qualified electronic ledgers

3 Oct 2025

On behalf of the members of the ICT Association at the Chamber of Commerce and Industry of Slovenia, we would like to comment on REQ-7.5-06. The provision defines security requirements only for cases where digital signature mechanisms are used, requiring certified secure cryptographic devices for private keys. However, no comparable requirements are set for other mechanisms. We recommend that the implementing act establish minimum security requirements for all mechanisms, to ensure consistency, reliability, and trustworthiness.
Read full response

Meeting with Jozef Síkela (Commissioner) and

2 Sept 2025 · Advancements in Hydrogen Integration

Response to Qualified preservation services for qualified electronic signatures and for qualified electronic seals

13 May 2025

Versioning of standards ETSI standards should consistently include version numbers. Currently, some are versioned while others are not. In the absence of a version, the latest valid version is assumed during implementation. However, to facilitate clearer understanding, consistent implementation, and effective communication among all participants, all standards and reference documents should include an explicit version number. Of all ETSI standards, TS 119 312 is most commonly lacking explicit version markings.
Read full response

Response to Verification of identity and attributes at qualified certificate or qualified attestation of attributes issuance

13 May 2025

Transition periods in standards implementation/Lifecycle of standards: Implementing acts enter into force 20 days after publication. Existing systems cannot adapt that quickly. Therefore, whenever a change occurs, there must be a longer transition period to allow for proper implementation.
Read full response

Response to Management of remote qualified signature creation devices as a qualified trust service

13 May 2025

Loosely defined standards for Key activation on HSMs certified under EUCC or EN 419221-5:2018 Protection profiles for Trust Service Provider cryptographic modules Part 5: Cryptographic module for Trust services Use of Private Keys Requires Authentication via HSM Mechanisms The use of private keys requires prior authentication through mechanisms provided by the Hardware Security Module (HSM). The primary standard protocol for working with HSMs is PKCS#11, which includes standard methods for authentication during key usage and supports role segregation. EN 419221-5 mandates additional activation of private keys before they can be used, but it does not define a standard method or protocol for this additional activation for example, as an extension of PKCS#11. As a result, each HSM manufacturer implements its own proprietary approach, leading to a proliferation of non-standard, vendor-specific activation methods and APIs. The same issue arises when HSMs are used as Qualified Signature/Seal Creation Devices (QSCDs), where assignment of signing keys is required. Again, the absence of a standardised protocol means reliance on proprietary implementations. This effectively nullifies the interoperability of HSMs, which would otherwise be ensured by established international standards. In practice, it also significantly increases the complexity and cost of integration for Trust Service Providers.
Read full response

Response to Qualified validation services for qualified electronic signatures and seals

13 May 2025

Versioning of standards ETSI standards should consistently include version numbers. Currently, some are versioned while others are not. In the absence of a version, the latest valid version is assumed during implementation. However, to facilitate clearer understanding, consistent implementation, and effective communication among all participants, all standards and reference documents should include an explicit version number. Of all ETSI standards, TS 119 312 is most commonly lacking explicit version markings.
Read full response

Response to Requirements for qualified electronic registered services

13 May 2025

Versioning of standards ETSI standards should consistently include version numbers. Currently, some are versioned while others are not. In the absence of a version, the latest valid version is assumed during implementation. However, to facilitate clearer understanding, consistent implementation, and effective communication among all participants, all standards and reference documents should include an explicit version number. Of all ETSI standards, TS 119 312 is most commonly lacking explicit version markings.
Read full response

Response to Validation of qualified electronic signatures and seals as well as advanced electronic signatures and seals

13 May 2025

Versioning of standards ETSI standards should consistently include version numbers. Currently, some are versioned while others are not. In the absence of a version, the latest valid version is assumed during implementation. However, to facilitate clearer understanding, consistent implementation, and effective communication among all participants, all standards and reference documents should include an explicit version number. Of all ETSI standards, TS 119 312 is most commonly lacking explicit version markings.
Read full response

Response to Qualified certificates for electronic signatures and electronic seals

13 May 2025

Versions of ETSI standards and their compliance with the eIDAS Regulation The proposals for implementing acts reference ETSI standards that are relevant to individual trust services, while also amending the provisions outlined in those reference ETSI standards. This effectively means that ETSI standards, including those versions published after the release of the eIDAS 2.0 Regulation, are not compliant with the Regulation. Based on past practice, we can expect that ETSI standards will continue to evolve as they have been doing so far. The incompatibility of current versions of ETSI standards with eIDAS raises the question of which specific versions of ETSI standards (some references are without versions) can or must TSPs use? Will the implementing acts be updated to reflect new ETSI versions? If not, who will certify the compliance of these new versions? For ETSI standards referenced without a specific version, it is stated that the latest version must be used. However, it is unclear when, or within what timeframe after a new version is published, TSPs must comply with.
Read full response

Response to Provision of qualified electronic time stamping services

13 May 2025

Transition periods in standards implementation/Lifecycle of standards: Implementing acts enter into force 20 days after publication. Existing systems cannot adapt that quickly. Therefore, whenever a change occurs, there must be a longer transition period to allow for proper implementation.
Read full response

Meeting with Marjeta Jager (Deputy Director-General Directorate-General for International Partnerships)

15 Jan 2025 · Meeting requested by GZS to discuss possibilities for collaboration and mutual support

Response to Voice call termination rates in the EU (Eurorates)

22 Sept 2020

Dear Madam or Sir, on behalf of Section of the operators of electronic Communications at the Chamber of Commerce and Industry of Slovenia, I am sending the feedback on the proposed MTR and FTR act. Best Regards, Katja Mohar Bastar
Read full response

Meeting with Violeta Bulc (Commissioner) and

8 Apr 2019 · Meeting with Presidency of the Chamber of Commerce

Meeting with Violeta Bulc (Commissioner) and

8 Apr 2019 · Meeting with transport section of Slovenian chamber of commerce