Idemia Identity Security France
Idemia IS
IDEMIA Identity Security France, is a leader in physical and digital identity solutions.
ID: 425708295324-44
Lobbying Activity
Response to Technical description of important and critical products with digital elements
18 Apr 2025
Please find in the attached document the feedback from Idemia Identity & Security France
Read full responseResponse to Digitalisation of travel documents and facilitation of travel
8 Jan 2025
IDEMIA Identity & Security very much welcomes this proposal of regulation. This regulation will increase facilitation for travelers when crossing borders. Likewise, it will help border control authorities by supporting advance border checks and clearance leading to higher level of security and better allocation of human resources. IDEMIA Identity & Security would like to share the following comments on the proposal (more details can be found in the attached document): Alongside verification of integrity and authenticity of storage medium of the travel document, chip data, physical travel document or Digital Travel Credential (DTC), verification of validity should also be required; The proposal makes a clear difference between creation and issuance of DTC. Yet none of those terms are defined. It seems that each wording has a different meaning, entailing some technical specificities which are not detailed in the text. Clear definitions should be added, and in particular how the creation and issuance differ should be clarified; It is key to include in the specification for the test of the EU Digital Travel application, test of provisioning and reading of DTC with all EUDI Wallets in use in each Member States. In addition, new tests should be carried out when a new EUDI Wallet is introduced, or in case of substantial changes of a Wallet; The provision of article 8.2 should indicate that eu-Lisa will be (1) a provider of electronic attestation of attributes for the provision of DTC, and (2) a relying party for the submission of DTC as defined in eIDAS, and should meet the applicable requirements; The current wording of article 12(1) first paragraph could be understood in a way whereby holder of valid travel document could request competent authorities to be issued a DTC unlike what recital 19 provides for. We suggest reviewing this wording to avoid ambiguity; We recommend to explicitly consider the security of (1) issuance and disclosure process, (2) authentication and validation and (3) revocation in article 12(2) We suggest to provide for the creation of an expert group gathering stakeholders such as industry or carriers relevant to DTC to support the European Commission and Member States in preparing these documents. This group could provide very useful inputs regarding (1) technological choices, (2) technology readiness, (3) needs stemming from possible use cases, or (4) alignment with EUDI Wallet. In article 13(2) item (a) and (c), a Member State should be allowed to require checking (1) at the border crossing point the data received against the data in the physical travel document and (2) the authenticity and integrity of the physical travel document when deemed necessary, in particular but not only - for security reasons; Article 20 provides for 12 months for the implementation of the provisions of Article 12(1). This timeframe seems too short in particular considering time needed for procurement, deployment, test and go live. We suggest setting this timeframe to 24 months; There is an ambiguity as to the content of the DTC which may be understood in a narrow manner preventing to include the same personal data as the passport or travel document based on which they are issued or created, but with an up-to-date value (e.g. recent portrait, current address). This possibility should be explicitly allowed as it will increase trust in the quality of data submitted through DTC. We recommend clarifying this aspect in a dedicated recital; This proposal seems to not cover the creation and issuance of DTC from European Residence Permits (as defined by regulation 1030/2002). Does it mean that physical European Residence Permits will still have to be presented at border? Or does the provision of article 4.1(c) also includes European Residence Permits? We recommend including these documents in the scope of that proposal (such as in article 4);
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