Qualified electronic archiving services

We welcome the Commissions initiative to establish common standards and specifications for Qualified Electronic Archiving Services (QEAS) under Article 45j(2) of eIDAS 2. As the European Union elevates electronic archiving to the level of a trust service, users legitimately understand thatregardless of the providerthis service will keep all their documents and files secure for the entire retention period.

Please find attached the position of the eFutura professional association. eFutura actively participated in standardisation work on French (AFNOR), European (ETSI and CEN) and international (ISO) standards in our fields of Electronic Archiving, Cyber ​ ​ Security, Electronic Invoicing, Document Management, Artificial Intelligence, Digitisation, etc.

Filed in French · English published by the European Commission

Siav S.p.A. Società Benefit is a software house specialized in document management softwares and digital processes. Founded in 1990, with more than 20% market share, Siav is today a leading Italian company in the Enterprise Content Management industry, offering software, cloud solutions and outsourcing services for Document Management, Workflow Management, Electronic Invoicing and Digital Preservation.

Lassociation of the French archivists felt it was important to take account of the recent work of TS 18170, which reached consensus at European level and responded to the current challenges. She therefore disagreed with the draft in this version and stressed the importance of working to limit the coexistence of standards in order to form the most coherent body of rules possible at European level.

Filed in French · English published by the European Commission

AssoCertificatori is the Association of Italian Qualified Trust Service Providers and Certified Service Providers. Assocertificatori is a non-profit organization that brings together the vast majority of providers pursuant to EU Regulation 910/2014 eIDAS such as digital signatures, digital identities, electronic delivery, electronic timestamps and digital preservation of documents.

By virtue of the arguments presented in the attached file, we recommend a thorough review of the draft Implementing Regulation, incorporating the following amendments: 1. Remove the reference to ISO 14641, as it is obsolete and formally withdrawn by bodies such as UNE. 2. Incorporate CEN/TS 18170:2025 as the main reference for functional requirements of electronic archiving services.

TeamSystem is a leading technology company for the development of business management solutions for SMEs and professionals. The Group supports its customers in the digital transformation of the entire supply chain through a comprehensive and integrated offering of innovative technologies based on AI, SaaS, and cloud designed to manage and optimize internal processes and strengthen collaboration with their reference…

Bitkom stresses that qualified electronic archiving must be clearly defined in line with eIDAS, with archiving and preservation treated as distinct but complementary services. Moreover, a future-proof framework should build on modern, widely accepted standards that support cross-border recognition and provide clarity for providers and users alike.

The La Poste group, through its subsidiary Docaposte, a major player in digital trust in France, welcomes the introduction of the trust service qualified as electronic archiving under the eIDAS 2.0 Regulation. This regulatory advance is a strategic opportunity to enhance the security, interoperability and mutual recognition of digital documents within the European Union.

Filed in French · English published by the European Commission

The CFONB, an association representing French banks, prepares the French banking community for the technical and organizational impacts arising from new French, European, and international initiatives or regulations.

On behalf of the eArchiving Initiative, a sub forum of the DLM Forum, we agree with the position put forward by Associazione Nazionale Archivistica Italiana (https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14751-Qualified-electronic-archiving-services/F33069918_en).

The German Banking Industry Committee (GBIC) fully supports the attached comments of the European Credit Sector Associations (European Association of Co-operative Banks, European Banking Federation, and European Savings and Retail Banking Group ECSAs) on the draft implementing regulation concerning the reference standards and specifications for qualified electronic archiving services in the context of European…

Recital 66 of Regulation (EU) 2024/1183 expressly recognises the application of qualified electronic archiving services to both digital native documents and paper documents that are digitised. However, we note that the text does not specify the criteria, technical requirements or minimum procedures for the conversion, scanning or digitization of documents in paper format for their subsequent safekeeping with a…

The development of trusted electronic archiving services in the European Union under the eIDAS regulation requires a clear alignment with regulatory objectives, technical interoperability, and long-term sustainability.

AGS Records Management is a major player in document management in France and worldwide. Optimising document management and preservation is the very foundation of our work as a physical and digital archiving service provider. The Group’s physical and digital archiving activities are operational in more than 50 countries, spread across the European, Asian and African continents.

Filed in French · English published by the European Commission

On behalf of the members of the ICT Association at the Chamber of Commerce and Industry of Slovenia, we fully endorse the comment submitted by Associazione Nazionale Archivistica Italiana and express our strong support for their position (https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14751-Qualified-electronic-archiving-services/F33069918_en)

Attached is a document produced by the Digital B2b Observatory of the Politecnico di Milano School of Management. The Digital B2b Observatory, founded in 2002, serves as a key reference point for the digital transformation of business processes in Italy, both internal and across supply chains. Its mission is to promote a more conscious and widespread digitization among companies and public institutions.

Please find below the comments of the European Signature Dialogue (ESD). ESD stands as the pinnacle consortium of leading European Qualified Trust Service Providers (QTSPs). We are pleased to provide our contribution in relation to the implementing regulations of eIDAS 2 Regulation, in the spirit of supporting a clear, effective, and future-proof framework.

For 15 years, Silae has been developing innovative digital solutions for payroll and human resources management in France and Spain. Our mission is to simplify regulatory and administrative complexity for French and Spanish companies, ensuring legal compliance and reliable processes. We generate almost 9 million payslips each month and serve more than one million businesses in these two Member States.

Filed in French · English published by the European Commission

La Fédération des Tiers de Confiance du numérique (FnTC), qui regroupe plus de 160 acteurs de la digitalisation prestataires de services numériques, professions réglementées, experts, utilisateurs et start-up remercie la Commission européenne de lopportunité offerte de contribuer à la consultation publique sur le règlement d'exécution concernant le Service qualifié d'archivage électronique.

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).

IDC - Indicom Document Care SpA is a company that has been operating in document management for more than 20 years and in electronic archiving since 2006. We have followed Italian regulatory developments and have gradually adapted our systems and our skills, aware of the importance of preserving archives and their content.

Namirial S.p.A. is a leading provider of secure digital transaction management services and solutions. Established in 2000 in Italy, the company is now a multinational company that provides software solutions and Digital Trust Services for the digitalization of businesses and public administration entities.

Signicat finds it strange that CEN/TS 18170 is not referred from the Annex to the implementing regulation. This is a European standard specifically on archive as a trust service, and the standard is listed in the implementing regulation on accreditation of CABs for archive. Please add this standard to the Annex.

Assoconservatori Assintel is an Italian association that brings together many companies, providing electronic archiving services in compliance with national regulations. We are pleased to contribute to the Qualified electronic Archiving Services Implementing Act and thank you for this opportunity.

ClubPSCo welcomes the Commission's proposal to ensure the standardisation and security of electronic archiving services. However, ClubPSCo hopes that the new standard CEN/TS 18170:2025 will be referenced in this act, replacing all the other standards mentioned in the proposed implementing act. See detailed feedback attached.

Reply of the public limited company Cecurity.com (FR17434330338) to the consultation on the proposal for an implementing regulation on the qualified electronic archiving service. Cecurity.com, editor of dematerialisation, digital safe and electronic archiving solutions, thanked the European Commission for this public consultation.

Filed in French · English published by the European Commission

The Italian Association of Italian Archivists disagree with the draft proposed by the EC for the following reason: CEN TC 468/WG1 has already published specific and very detailed Technical specifications (TS 18170) These specifications defined with many European experts are consistent with all the member States legislation in the sector, compliant with all the European relevant standards and recommendations.

CEN TC 468/WG1 has published TS 18170. This TS cover the regulation as explained by the CEN TS 468 to the EC. This TS has been constructed by EU experts coming from different EU countries in a consensual approach. More the 120 hours was spent by those experts. IMHO, this TS should be in the EA and should replace the old ISO 14641. Disagree on actual draft for this reason.