EU consultation
24 submissions from 21 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 35 submissions on this file. Shown here: the 24 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
21 submissions from industry and none from civil society organizations; 3 from public authorities, academia and others.
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 3 Oct 2025 — it ran from 5 Sept 2025.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned, Implementing regulation.
24 positions
· · filed 3 Oct 2025 · source
The draft Implementing Act requires that qualified electronic ledgers ensure chronological ordering, immutability, finality, origin authentication, and clear governance. These functional requirements can be satisfied by non-blockchain distributed ledger models as defined in the Annex, provided they meet the mechanisms for ordering, integrity and consensus/finality.
· · filed 3 Oct 2025 · source
We are ELA Blockchain Services a.s., established in the Czech Republic. Our company specialises in the development and operation of Consortium Blockchain solutions, and from this technical point of view, we make the following comments on the draft eIDAS2 implementing acts, namely the area of qualified e-books.
Filed in Czech · English published by the European Commission
· · filed 3 Oct 2025 · source
We are ELA Blockchain Services a.s., established in the Czech Republic. Our company specialises in the development and operation of Consortium Blockchain solutions, and from this technical point of view, we make the following comments on the draft eIDAS2 implementing acts, namely the area of qualified e-books.
Filed in Czech · English published by the European Commission
· · filed 3 Oct 2025 · source
We are ELA Blockchain Services a.s., established in the Czech Republic. Our company specialises in the development and operation of Consortium Blockchain solutions, and from this technical point of view, we make the following comments on the draft eIDAS2 implementing acts, namely the area of qualified e-books.
Filed in Czech · English published by the European Commission
· · filed 3 Oct 2025 · source
We are ELA Blockchain Services a.s., established in the Czech Republic. Our company specialises in the development and operation of Consortium Blockchain solutions, and from this technical point of view, we make the following comments on the draft eIDAS2 implementing acts, namely the area of qualified e-books. 1.
Filed in Czech · English published by the European Commission
EADTrust is a Qualified Trust Service Provider (QTSP) accredited under eIDAS Regulation (EU) No. 910/2014, registered on the European Trust List and regulated by the Spanish Ministry for Digital Transformation and Public Function. It aims to provide secure and compliant digital solutions for businesses and administrations, facilitating reliable electronic transactions in the EU.
ALASTRIA encourages the Commission to explicitly include in the Implementing Regulation (or in further guidance) the possibility for providers to use functionally equivalent secured cryptographic mechanisms, provided they undergo independent evaluation and can demonstrate compliance with the assurance objectives defined in REQ-7.5-06.
Filed in Spanish · English published by the European Commission
· · filed 3 Oct 2025 · source
On behalf of the members of the ICT Association at the Chamber of Commerce and Industry of Slovenia, we would like to comment on REQ-7.5-06. The provision defines security requirements only for cases where digital signature mechanisms are used, requiring certified secure cryptographic devices for private keys. However, no comparable requirements are set for other mechanisms.
The complete response is available in the attached document. --- Executive Summary: EUCI Response on Qualified Electronic Ledgers under eIDAS 2 The European Commissions draft implementing regulation on qualified electronic ledgers risks excluding public, permissionless blockchains by anchoring compliance to a centralised trust-service-provider model.
ASEPEC is the Association of Spanish Trust Service Providers. ASEPEC is a non-profit organization. The Association has 37 QTSPs. ASEPEC also include the Spanish CABs and other interesrted parties as well. ASEPEC welcomes the release of the draft proposal for the Implementing Acts and appreciates the opportunity to provide feedback about them.
ABLE TECH SPA is an Italian trust electronic archiving services provider, qualified at the AgID marketplace. For our Company it is important to give a contribute to the Public Consultation on Art 45j e-Archiving ANNEX. We are a Company with extensive experience in digital solutions and compliance solutions, so we recognize the strategic importance of defining a process oriented for the long preservation.
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…
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.
Bitkom highlights the need for greater precision and practicality in the draft Implementing Act on qualified electronic ledgers. Clear and consistent terminology, differentiated definitions, and the correction of technical inaccuracies are essental to avoid ambiguity. At the same time, requirements for supervision must remain workable in practice, particularly in situation where urgent security updates are needed.
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 ledgers in the context of European Digital Identity…
· · filed 2 Oct 2025 · source
To ensure the integrity and accuracy of the chronological order of electronic data, this initiative establishes a list of reference standards for the requirements for qualified electronic ledgers. These rules and reference specifications will ensure that data entered in an electronic register are ordered in chronological order, while remaining immutable, consistent and reliable.
Filed in Italian · English published by the European Commission
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 futureproof framework.
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).
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.
· · filed 29 Sept 2025 · source
Reference for ETSI activity on Smart Contracts that profile EN 319 401 should be to ETSI TS 119 541, ETSI TS 119 542 and should also reference to the foundation Technical Report ETSI TR 119 540. It is also noted that ETSI will continue to support work on assurance of the chronological integrity of records in Qualified Electronic Ledgers in the activity of ETSI Technical Committee (TC) DATA.
· · filed 29 Sept 2025 · source
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 dexécution concernant les registres électroniques qualifiés.
Our feedback on the draft Implementing Regulation for Qualified Electronic Ledgers aims to future-proof the legal framework by embedding essential functionalitiessuch as metadata lifecycle management, exclusive control, and harmonised certificationthat ensure interoperability and legal validity across all electronic documents.
· · filed 18 Sept 2025 · source
The CEN/CLC JTC 19 WG1 have worked on a Technical Specification defining the Policy, Functional and Security Requirements on (qualified) trust services for Electronic Ledger. This TS is actually under approval with the reference "FprCEN/TS 18264". It could be interesting to add this reference when approved in the Execution Act. Thank you.
The Only thing we miss in digital era is how regulations give the limitation to be supported for a global innovation & empwer the applications there Registration of efforts should be connected to real deal information about the income that is created from the act of Generative AI or any supply chain connected to social media.
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.