The attached document comprises the analysis of, and the amendments proposed by European Digital Rights (EDRi), to the three simultaneous but separate consultations (drafts Implementing Acts for 5b relying parties, 5a electronic attestation of attributes and 5a standards and technical specifications).
EU consultation
Amending CIR 2025/1569 of Articles 45d-45f as regards applicable standards and specifications
11 submissions from 10 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 25 submissions on this file. Shown here: the 11 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
7 submissions from industry — companies and their trade associations — against 4 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 1.8 industry submissions for every one from civil society.
Industry 7Civil society 4Public authorities, academia, other 0
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
The file, right now
The consultation closed on 5 Mar 2026 — it ran from 5 Feb 2026.
- Policy area
- Digital & tech (DG CNECT)
- Where it stands
- Awaiting adoption
- Adoption expected
- 31 Mar 2026
How it got here
- Draft implementing regulation5 Mar 2026
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Implementing regulation.
11 positions
The European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group - ECSAs) are supportive of the ambition to establish a coherent Europe-wide framework for digital identity (eIDAS 2.0).
This statement is submitted by the Association of German Banks, which represents 171 banks and 21 fintech companies. These include not only major international banks but also regional and foreign banks. We would like to share observations regarding the draft implementing regulation prepared by the Commission concerning the Amendment to CIR (EU) 2025/1569.
SI
SK ID Solutions AS
· · filed 5 Mar 2026 · source
SK ID Solutions AS is a qualified trust service provider delivering secure digital identity, authentication, and electronic signing solutions used by millions of users and organisations across Europe. Our company confirms that we support and align with the position submitted by European Telecommunications Standards Institute (ETSI) in document ESI(26)000153r2 Consolidated comments on the draft update of the…
At the ESI#89 plenary meeting of TC ESI (Electronic Signatures and Trust Infrastructures) the draft act on Draft Act on European Digital Identity Wallet Electronic Attestation of Attributes (Update) amending CIR (EU) 2025/ 1569 was discussed.
At the ESI#89 plenary meeting of TC ESI (Electronic Signatures and Trust Infrastructures) the draft act on Draft Act on European Digital Identity Wallet Electronic Attestation of Attributes (Update) amending CIR (EU) 2025/ 1569 was discussed.
From Bitkoms perspective, the draft Implementing Act amending Commission Implementing Regulation (EU) 2025/1569 requires further clarification to ensure legal certainty, interoperability and consistent implementation across Member States.
The European Pirate Party (PPEU) is a pan-European political party representing Pirate Parties across EU Member States. Our movement is rooted in the defence of digital rights, civil liberties, and democratic participation. We view the internet and digital infrastructure as common goods and public utilities that must serve all citizens.
Please find our analysis and amendments to this fourth batch of implementing acts from a privacy and consumer online and attached perspective: https://epicenter.works/content/eidas-amendments-to-the-implementing-acts-batch-4-rev8 The currents drafts fail to address critical outstanding privacy concerns in the EUDI Wallet and eIDAS ecosystem. In several respects, the situation would even deteriorate.
SA
SLASHLIFE AI, UNIPESSOAL LDA
· · filed 20 Feb 2026 · source
Current specifications define credential formats and verification mechanisms for electronic attestations of attributes, but assume attributes that can be validated through static checks (validity, issuer, revocation status).
TG
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· · filed 5 Feb 2026 · source
To be able to Secure Our identity online for digital contracts & income via Banks & Services, there no simple method tó recommend here. I Can immagine the possibility to manage connection to platforms in social media to Omnbibus & Revolut & Swedbank services plus Moodys Tax & Global Insurance via Rome & any Connection that makes our digital identity recognised by a modern system to be developed as Secure Way in…
Take the dataCSV — all 11 submissionsJSONFull text, not the excerpt. Free to cite.Search every submission →
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.