Amending CIR 2025/848 of Article 5b(11) registration of relying parties

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).

Annex I Point 16. Collecting in the register a complete list of all entities served by a given intermediary may be very difficult in practice, because it requires the intermediarys register entry to be updated every time the intermediary onboards a new client.

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).

The Global Legal Entity Identifier Foundation (GLEIF) welcomes the opportunity to provide feedback on the registration of wallet-relying parties under the European Digital Identity Wallet Framework. GLEIF strongly supports the possibility for organisations and companies to use the Legal Entity Identifier (LEI) when registering as wallet-relying parties in the context of the eIDAS2 Regulation.

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 our observations regarding the draft implementing regulation prepared by the Commission concerning the amendment to CIR (EU) 2025/848.

This initiative amends Commission Implementing Regulation (EU) 2025/848 on the information to be provided by wallet-relying parties to national registers. The changes reflect the evolution of the architecture and reference framework for the European Digital Identity Wallet since the adoption of the Implementing Regulation and need to be clarified to citizens with an EU call centre.

Filed in Italian · English published by the European Commission

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 Relying Party Register (Update) Amending CIR (EU) 2025/848 Ares(2026) 1286341 + Annex.

Please find attached the document outlining Entrust's comments on this Draft Commission Implementing Regulation updating Information requirements for the registration of wallet-relying parties. We welcome the opportunity to contribute to this crucial phase of regulatory development under eIDAS 2 and remain at your disposal for any further clarification or discussion.

From Bitkoms perspective, this initiative amending Commission Implementing Regulation (EU) 2025/848 should ensure coherence of scope and legal clarity. Structural adjustments must be transparent and proportionate to avoid interpretative uncertainty. At the same time, the framework should remain technically flexible and avoid rigid legal embedding of rapidly evolving specifications.

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.

CEN TC224 WG20 is responsible for the European standard CEN/TS 18297 on Access Control for European Digital Identity Wallets. The standard governs how Wallet Access Control Engines (WACEs) evaluate Relying Party requests, process disclosure policies, and protect Wallet Holder Assets (WHAs) before any presentation of personal attributes.

The European University Association is highly supportive of eIDAS as a tool for interoperability and its possibilities for increasing trust digital education credentials. However, care needs to be taken in the implementation so that standards and tools that are already in use are still possible to maintain in the new system.

Each adress & party via register from memberships & local connections are able to empower their identity for digital wallet via any AI system there they Can Connect their idtentity via analyse methods like dental journal as Face Recognise methods inside of the house or appartment to register digital wallet or Identity based on Living adress.