European Digital Identity framework

Bitkom welcomes the Commission’s draft, as it is another important building block for secure digital identities and trust services in the European Union. Europe’s digital sovereignty will be strengthened by establishing digital identities and allowing them to be used independently by EU citizens across the EU. Bitkom thanked for the opportunity to comment in the consultation process. Please find attached the opinion.

Filed in German · English published by the European Commission

The draft eIDAS 2 regulation has great potential and we, the CRYPTAS Group, welcome this approach. CRYPTAS operates an eIDAS Trust Service Provider, PrimeSign (Austria), since 2016 and we have an extensive experience in bringing eIDAS to industry customers (of various branches) and users.

As Vice Chair of ETSI Technical Committee on Electronic Signatures and Infrastructures, that has drafted a large part of the technical standards referenced by the EC in the OJ supporting eIDAS, I present on behalf of the committee, the attached document, in which it becomes evident that the existing standards cover much of the proposed revision to eIDAS, in SEC(2021) 228 final.

The Estonian Information Technology and Telecommunications Association (ITL) supports the amendment of the eIDAS Regulation as there is a clear need in practice. We believe that ways must be sought to facilitate and enable the uptake of digital identity in those Member States where it has not been the case so far or where the digital identity is fragmented and issued by different institutions or businesses.

Filed in Estonian · English published by the European Commission

Please find attached the preliminary positions of the European Signature Dialog (ESD) regarding EC Proposal for a Regulation of the European Parliament and of the Council, amending Regulation (EU) No 910/2014 as regards establishing a framework for a European Digital Identity. ESD represent the leading European trust service providers.

General comments Insurance Europe welcomes the opportunity to share the views of the insurance industry on the European Commission’s proposals for a European digital identity. Digital identities and the associated processes of authentication and authorisation are an essential component of the digital single market and of national and European economies, especially against the backdrop of the COVID-19 pandemic.

DEAR Ladies and Gentlemen, please find the German Banking Industry Committee’s comments on the EU Digital ID Scheme. The comments are written in German, but a convenience translation into English is included. Child regards, [name removed] (DSGV)

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* When developing the toolbox and the implementing act, the EU should not develop a new, proprietary standard but rather refer to existing standards (or standards that are about to be published), especially OpenIDConnect, SAML and ISO 18013-5. Existing standards are well-established and tested and they guarantee worldwide interoperability.

Twilio -- both a user of public-sector identification schemes and a provider of authentication tools -- has followed the European Commission’s work on a European Digital Identity scheme with great interest. Twilio previously responded to the Commission’s initial consultation on this matter.

The European DIGITAL SME Alliance thanks the European Commission for the opportunity to provide feedback on the proposal for an EU digital ID scheme for online transactions across Europe. DIGITAL SME prepared comments regarding commission adoption and its potential impact on SMEs, which you can find attached. We are expecting further comments from our experts in response to a wider consultation.

The attached document reflects the InfoCert Group contribution to the “have your say” consultation on the EC Proposal for a Regulation of the European Parliament and of the Council, amending Regulation (EU) No 910/2014 as regards establishing a framework for a European Digital Identity.

Eurosmart, the Voice of the Digital Security Industry, would like to thank the European Commission for the opportunity to comment on the proposal for a Regulation establishing a framework for a European Digital Identity. Our recommendations can be found in the attached document.

The Foundation for Internet Domain Registration in the Netherlands (SIDN) welcomes the Commission’s proposal to set up a harmonized framework for national eIDs. The European Digital Identity Wallets (EDIWs) will make it safer and easier for anyone to use online services in Europe.

Our digital and physical lives are increasingly linked to the apps, services, and devices we use on a daily basis to access a rich set of experiences. This digital transformation, accelerated by the effect of the COVID-19 pandemic and the consequent lockdowns, allows us to interact with hundreds of companies, websites, and thousands of other users in the ways that were previously unimaginable.

The proposal aims to offer a high level of security for the users. The City of Stockholm agrees with the view that users need to have enhanced control over their personal data. Today there is a great number of established services that provides the user to share and re-use login credentials, but it is often difficult for the user to assess how their personal data will be used and which conditions apply.

We are providing our answer in representation of IMPULSE H2020 Project (GA No. 101004459), aligned with this initiative, which aims are to: 1) validate a framework based on AI and blockchain to support secure and privacy-preserving eID management by public services 2) define actionable roadmaps for its adoption, escalation and sustainability We welcome this position and agree with the Commission’s view, but we…

The Italian Banking Association (ABI) appreciates the opportunity to provide its feedback through the "Have your say" procedure, given the importance of the topic. We welcome the concept outlined in the proposal, where each Member State shall issue a European Digital Identity Wallet (EDIW) after the entry into force of this Regulation: Identity issuance will remain a Member State responsibility, as it is currently…

EuroGeographics is an independent international not-for-profit organisation representing Europe’s National Mapping, Cadastral and Land Registration Authorities (NMCAs). We are a passionate advocate for European geospatial data from official trusted sources, in particular when it is harmonised to standard specifications.

The Austrian Social Insurance as one of the most active users of a digital identity warmly welcomes the Commission’s initiative to harmonise and fully implement a European Digital Identity (EUID). Being at the forefront of the provision of secure, trustworthy digital solutions and having the expertise sought for an efficient implementation, we fully support any steps to a safe cross-border use of a EUID in…

Filed in German · English published by the European Commission

Extract of the full document in Annex: We welcome the intention to develop an EU digital ID scheme with an ambition to ensure a much greater use of digital authentication across the member states. Particularly, we note that this is supported by broadening the scope of the eIDAS regulation to also cover services offered by private companies.

Dear European Commission, attached you can find the summarised feedback regarding the draft of the revised eIDAS regulation. This feedback was prepared within the IDunion consortia and illustrates the combined opinion of the stakeholders involved. IDunion is funded by Federal Ministry of Economics and Technology in Germany and is specialising on the implementation of self-sovereign identities.

MEDEF welcomes this initiative, which promotes the development of the digital single market by enabling citizens and businesses to identify themselves quickly and share documents more easily and under the same conditions within the EU.

Filed in French · English published by the European Commission

MAIF welcomes the opportunity to provide a feedback on the regulation presented by the Commission on June 3rd establishing a European digital identity. Since 2020, several legislative initiatives are being set and discussed to frame the data economy.

eID Easy fully supports the new regulation. It's extremely important to give all EU citizens easy access to the strong eID means and qualified electronic signatures. This will also make e-mail link clicking electronic signature funny business obsolete. We want to emphasize that its important to keep the signature certificates and private keys most importantly in the local QSCD HSM.

CSC supports the idea of creating a European Digital Identity as this would greatly facilitate cross-border access to services as well as cross-border mobility, including in the key fields of education and research.

The German insurance industry welcomes the developments at the European level, the introduction of a European identity scheme (EUid) in combination with the proposed amendments of the Regulation (EU) No 910/2014 (eIDAS) by the European Commission and supports the approach to establish an EU-wide ecosystem on digital identities in form of a European identity scheme (EUid).

Extract of full doc in Annex The European Credit Sector Associations welcome the proposal for a regulation establishing a framework for a EU Digital Identity and the high ambitions presented in the initiative as a positive development. The Commission proposal aims to provide an ecosystem of credentials leveraging a new wallet architecture of several ID solutions.

The Alternative Investment Management Association (AIMA) welcomes the opportunity to provide feedback to the European Commission’s “Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) No 910/2014 as regards establishing a framework for a European Digital Identity” (the “Proposal”).

Dear Ladies and Gentlemen, the EU Accredited Conformity Assessment Bodies support the players active around eIDAS since its taking into force. We do that with the necessary assessments, audits and certifications. And we herewith serve all EU citizens as well as the community in general with the confidence of using trustworthy, eIDAS compliant services.

Dear Sir or Madam, the Certification Body of Deutsche Telekom Security GmbH carefully read and analysed the current Draft of eIDAS 2.0 and appreciate and widely support this initiative. In particular, we would like to highlight an outstanding importance of the regulation and introduction of the European Digital Identity Wallet.

We are very happy with the proposed review of the eIDAS framework and are looking forward to its adoption. One comment we would like to make is that we believe the planned eID wallets could potentially be linked to or simply be the same as the wallets that will eventually hold the Digital Euro.

The most important change introduced by the new Regulation to address the problems of cross-border access to and use of services is the European Digital Identity. As the European Digital Identity is a fundamentally new solution and given the challenges related to the enforcement of the current Regulation, in particular with regard to eID, it is rather doubtful that the proposed digital identity ecosystem will…

Filed in Estonian · English published by the European Commission

The French Data Protection Authority (CNIL) brings the following points on digital identity to the attention of the European Commission. 1. Multiple digital identities As the digital identity is multiple and contextual, the CNIL considers it important to allow individuals to have several.

Filed in French · English published by the European Commission

EPIF welcomes the opportunity to comment on the Commission’s Inception Impact Assessment on the Revision of the eIDAS Regulation aimed at improving its effectiveness, extend its application to the private sector and promote trusted digital identities for all Europeans.

We welcome the intention of the European Commission to extend the use of digital or electronic identification (e-ID) to the private sector and to offer the possibility of private sector provision of digital identities within the framework of a revised Regulation on electronic identification and trust services for electronic transactions in the internal market (eIDAS Regulation).

Option 1: Eurosmart supports option 1 as a necessary step to consolidate the eIDAS framework. Further enhancements and extended usages of eIDs under eIDAS should be fostered. In particular, deeper harmonisation of certifications will bring more confidence and trust to stakeholders. This will also clarify the eIDAS security requirements and Levels of Assurance (LoAs).

Revision of the eIDAS regulation – European Digital Identity The eIDAS Regulation (entered into force in 2014) introduced a first cross-border framework for trusted digital identities and trust services. However, its potential remains still underexploited. Only 15 of 27 Member States offer an eID to their citizens. One of these 15 Member States is Italy.

The current legal framework has not yet reached an optimal level of harmonization in relation to e-signature. National governments interpretations of the Regulation has complicated the validity and recognition of the electronic signatures between Member States - for instance by restricting the use of electronic signatures to some categories of documents - thus impeding the consolidation of a single internal market…

Synthesis of the Thales DIS position - August 2020 The eIDAS regulation has been a valuable milestone toward a common basis for trusted digital identities and trust services. Thales DIS welcomes the assessment of the 2014 regulation and supports its objective to make easier and safer the use of online services while giving people more control over their personal data and privacy.

The eKYC and Identity Assurance Working Group (eKYC & IDA WG) of the OpenID Foundation welcomes the proposal of the Commission to extend the scope of eIDAS trust services by introducing a new trust service for identification, authentication and for the provision of attributes, credentials and attestations and allowing the provision of identification for devices (Option 2 in the EC Revision of the eIDAS Inception…

In general, the Commission’s assessment of the current situation seems adequate, especially since interoperability and extensions to digital validation are crucial for a sovereign digital market in Europe. Because of the different pace of digitalization across the EU, several Member States have already implementing digital validation on top of identification.

Insurance Europe welcomes the evaluation of the 2014 eIDAS Regulation and accompanying revision of the current legal framework. Digital identities and the associated processes of authentication and authorisation are an essential component of the digital single market and of national and European economies, especially against the backdrop of the COVID-19 pandemic.

The International Trade and Forfaiting Association (ITFA) is grateful for the opportunity to express the initial views related to the planned eIDAS review. We believe that the eIDAS review presents an excellent opportunity to consider various aspects that can help boost international trade.

Dear Sir/Madam, With regard to the commitment of the European Commission to revise the eIDAS regulation (910/2014) and the current “roadmap consultation”, the Royal Dutch Association of Civil-law Notaries (KNB) would like to inform you about its concerns and recommendations.

Alliance pour la Confiance Numérique (ACN - Alliance for Digital Trust) represents organizations (world leaders, SMEs and mid-sized enterprises) operating in France in the digital and electronic trust sector, and especially in the digital identity area.

Deutsche Telekom AG welcomes the Commission's initiative to revise and expand the eIDAS regulation. It favors a combination of the three described options. The EUid should go far beyond the current approach and enable its use in both the public and the private sector. In contrast to today's private approaches, the EUid must be available to all citizens.

The 15.000 notaries in France and their staff use, on a daily basis, the services of e-identity and qualified e-signatures, which makes the French notariat one of the main users at national level of these technologies.

Filed in French · English published by the European Commission

Thank you for the possibility to contribute in the eIDAS review process. TalTech Information Systems Group has researched and observed the developments of eIDAS for several years. During this period, we have focused on eIDAS implementation practices, analysis of different countries and cross-border use of the eIDAS regulation.

1&1 welcomes the opportunity to respond to the Commission’s consultation on the revision of the eIDAS Regulation | European Digital Identity (EUid). WEB.DE, GMX and 1&1 have been the first European companies for electronic delivery Services certified by TÜViT and the German Federal Network Agency (Bundesnetzagentur) under the eIDAS Regulation.

VDSIC - Visible Digital Seal International Council is dedicated to the development and promotion of an intersectoral and international Visible Digital Seal bringing together current and future actors, both direct and indirect. The Association acts as a Trusted Services Operator, a trusted third party of the OTENTIK Visible Digital Seal Scheme.

European Signature Dialog would like to contribute and support the European Commission in the goal to establish trust in electronic transactions in the internal market, secure interoperability and also cybersecurity and thus enhance transparency and consumer protection. Please refer to the document attached for detailed information.

The Global Legal Entity Identifier Foundation (GLEIF) is pleased to provide comments to the Inception Impact Assessment – Revision of the eIDAS Regulation – European Digital Identity (EUid). GLEIF will focus its comments on the use of the LEI in eIDAS. Please see the attachment for GLEIF's full response.

Dear sir/madam, We like to thank the European Commission for this opportunity to provide input. From our reaction you will learn that we are enthusiastic about a more ambitious agenda for the eIDAS framework. As one of Europe’s cultural and market pillars, the City of Amsterdam is actively engaging in projects to enhance full participation of its citizens and visitors in our modern digital city.

Orange's inputs to European Commission Roadmap on eIDAS With eIDAS, the EU laid the foundations and a predictable legal framework for people, companies and public administrations to safely access services and carry out transactions online and across borders.

The Developers Alliance welcomes the opportunity to provide feedback on the European Commission’s planned revision of the eIDAS Regulation. Developers Alliance advocates on behalf of software developers and the companies invested in their success, to support the industry’s continued growth and promote innovation. Please find attached our position paper.

Feedback on eIDAS revision https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12528-European-Digital-Identity-EUid- The proposed extension of Qualified Trusted Services to include identification and authentication services as a stand-alone QTS is a very positive signal.

Filed in German · English published by the European Commission

The Center for Data Innovation is pleased to submit feedback to the European Commission’s roadmap titled “Inception Impact Assessment for Revision of the eIDAS Regulation – European Digital Identity (EUid).” In 2014, the EU adopted the eIDAS (electronic identification, authentication, and trust services) regulation to establish a cross-border framework for electronic IDs (eIDs) and “electronic trust services” (e.g.

The National Digital Council published on 15 June 2020 a report entitled Digital Identities. Core elements of digital citizenship. The report follows a letter of referral from the Secretary of State for Digital Affairs in July 2019. It contains 35 recommendations aimed at guiding the government in the development of French digital identities.

Filed in French · English published by the European Commission

Eco is the largest association of internet industries in Europe, with over 1 100 member companies. Since 1995 eco has been instrumental in shaping the internet, promoting new technologies, creating framework conditions and representing the interests of its members vis-à-vis politics and in international fora.

Filed in German · English published by the European Commission

Finance Denmark welcomes the initiative to revise the 2014 eIDAS Regulation, extending it to the private sector and promoting trusted identities, in general, across Europe. In Denmark, we have had a well-functioning public/private digital ID solution since 2010 called NemID. It is a public private partnership collaboration between the Danish banks and the public sector.

The concept of combining the three options makes a lot of sense, although it may require a longer migration period to move from the current eIDAS to the next phase. Option 1 includes identity verification for issuing qualified certificates. Identity verification should include remote identity verification solutions.

Bundesdruckerei GmbH would like to contribute to the successful creation of a future-proof legal framework to support an EU-wide, trustworthy and secure system for identities and trust services in the digital space.

General We concur with the assessments on the description of the current situation. Especially interoperability and extensions to digital validation is crucial if Europe is to have a sovereign common market in 10 years based on the pace of digitalization. There is a clear trend of entrenchment of national walled garden development in this area currently.

CLR Labs is the first European Evaluation Laboratory dedicated to the evaluation of Biometrics technologies. We bring all aspects of biometrics and mobile security expertise and we cover all Biometrics technologies and their associated products, users and ecosystems. We are based in La Ciotat – South of France.

Yubico’s feedback to the eIDAS inception impact assessment document is summarized below. As regards to Option 1, the reinforced baseline scenario, Yubico recommends the following improvements of the eIDAS EU regulation 910/2014 with respect to eID schemes: * The eIDAS regulation should specify well-defined rules for remote identity proofing * The eIDAS regulation should be harmonized with the eID scheme requirements…

Hi: thank you for great step forward. Observing various EID schemes so far which the paper categorize them as moderate success but i have to say it has a long way to go to serve its core purpose which is cross border transactions and ease of business.