Amending CIRs of Article 5a(23) as regards applicable standards and technical specifications

The document argues that the current draft implementing regulations for eIDAS 2 do not provide sufficient operational support for W3C Verifiable Credentials within the EUDI Wallet, despite formally referencing them via ETSI TS 119 472-1 and upgrading to VCDM v2.0.

Reaction on behalf of EUNIS to the draft act on European Digital Identity Wallet standards and technical specifications (update) EUNIS represents the European community driving digital transformation in higher education, empowering digital leaders through collaboration, knowledge sharing, and policy advocacy to shape the future of education.

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).

The Austrian Chamber of Civil-Law Notaries, being committed to the development of reliable, legally certain digital identity solutions in the service of citizens and businesses, welcomes the amendment of the implementing regulation (EU) 2024/2977 requiring the mandatory inclusion of a portrait (facial image) of the wallet user in the European Digital Identity Wallet according to respective technical standards.

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) 2024/2979, 2982, 2977, and 2980.

Docusign welcomes the opportunity to provide input to the European Commissions consultation on the draft implementing regulation amending Implementing Regulation (EU) 2025/848 on the registration of walletrelying parties.

This initiative amends Commission Implementing Regulations (EU) 2024/2979, (EU) 2024/2982, (EU) 2024/2977 and (EU) 2024/2980 by updating references to standards and technical specifications to ensure that Member States can develop and provide European Digital Identity Wallets in an interoperable manner through transparent monitoring of citizens with personal text messages or wz.

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…

The INATBA Privacy Working Group respectfully submits this position regarding the current draft amending Implementing Regulations under the eIDAS 2.0 and EUDI Wallet framework. Our Working Groups interest is straightforward: privacy should not be treated as a secondary feature to be added after interoperability choices have already been made. In digital identity systems, architecture determines privacy outcomes.

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 Standards and Technical Specifications Amending CIR (EU) 2024/2979, 2982, 2977 and 2980 Ares(2026) 12863xxx was discussed.

Please find attached the document outlining Entrust's comments on the Draft Commission Implementing Regulation amending Implementing Regulations (EU) 2024/2977, 2024/2979, 2024/2980 and 2024/2982. We welcome the opportunity to contribute to this important phase of regulatory development and remain at your disposal for any further clarification or discussion.

From Bitkoms perspective, this initiative amending Commission Implementing Regulations (EU) 2024/2979, 2982, 2977 and 2980 should primarily ensure that highly detailed technical specifications are not statically embedded in the Annexes of the CIRs.

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.

The FIDO Alliance is pleased to see the proposed change to the technical specifications for pseudonym generation in Article 14, which would enable a user to store and generate a pseudonym by using any WebAuthn Authenticator of the user's choice.

Visible Digital Seal International Council (VDS-IC) suggests to introduce in the Architecture Reference Framework (latest published version: ARF V2.7.3) two proposals. Proposal A: We propose to include at least in the ARF, two approved and already implemented in public and public/private federative initiatives, international standards, ISO 22376 and ISO 22385, both for presentation flows and EAA issuance flows, for…

The German Federal Chamber of Notaries (Bundesnotarkammer) welcomes simple, fast and digital solutions at the service of citizens - solutions such as the European Digital Identity Wallet (EUDI Wallet). At the same time, notaries ensure that, in deploying these solutions, the highest standards are maintained with respect to preventive administration of justice, data protection, and the quality of legal advice…

The Groningen Declaration Network (GDN) https://groningendeclaration.org/ takes this opportunity to have our say about Draft implementing regulation - Ares(2026)1286304 Who we are The GDN Network is an international, non-profit federated trust located in the Netherlands. It represents a voluntary network of like-minded organizations and individuals that seek to make digital student data portability happen.

Europe and the world's AI leaders agree on one thing: governance and innovation must go hand in hand. What no one has yet built is the technical layer that makes governance possible at machine speed. This paper identifies that gap, names it, and proposes a proven architecture to fill it.

CONSULTATION RESPONSE Signatu AS (KROG Wallets) Ref. Ares(2026)1286304 PLAN/2025/2856 Article 5a(23) Signatu AS develops KROG Wallets a governance operating system for Personal, Business, and Government Wallets. We welcome the draft amendments and offer four observations. 1.

1) Agent-mediated / machine-to-machine interaction Technical specifications and interoperability testing should explicitly include agent-mediated (machine-to-machine) issuance and presentation flows, provided that: - requests are authenticated via relying party access certificates or equivalent; - wallet instance attestations are validated for wallet-to-wallet interactions; - user approval, disclosure policies…

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