Eurosmart

Eurosmart, the voice of the European digital security industry, welcomes the opportunity to provide comments on the European Commissions proposal for a Digital Omnibus Regulation. Eurosmart supports the objective of improving clarity and consistency across the EU digital regulatory framework.

Eurosmart, the voice of the European digital security industry, welcomes the European Commissions initiative to introduce a Digital Omnibus on Artificial Intelligence, which proposes targeted amendments to the Artificial Intelligence Act.

While Eurosmart welcomes the Commissions work on the Digital Omnibus, we note with concern that the current Call for Evidence appears to narrow the initial ambition of this initiative. The Omnibus was originally conceived as a bold and strategic exercise to streamline Europes increasingly complex digital regulatory landscape and to remove inconsistencies between key legislative acts.

Eurosmart, the Voice of the Digital Security Industry, welcomes the Commission’s proposal for an Artificial Intelligence (AI) Act. Our association has been advocating for years for EU requirements covering AI systems.

Eurosmart welcomes the European Commissions proposal to amend Directive (EU) 2022/2555 (NIS2) through the Digital Omnibus simplification package and supports the objective of reducing unnecessary administrative burden while preserving a high level of cybersecurity across the Union.

Eurosmart welcomes the European Commissions proposal to revise the Cybersecurity Act (CSA2) and supports the objective of strengthening and scaling the European cybersecurity certification framework in response to evolving cybersecurity threats and increasing digital dependencies.

Eurosmart supports a focused revision of the EU Cybersecurity Act (CSA) to strengthen ENISAs role, preserve the integrity of the European Cybersecurity Certification Framework (ECCF), and streamline certification. The CSA remains central to the EUs cybersecurity framework, and its alignment with other regulations (e.g., CRA, NIS2, AI Act) is essential to reduce duplication and simplify compliance.

Eurosmart, the Voice of the Digital Security Industry, welcomes the Commission’s proposal for a Data Governance Act. This proposal is instrumental to develop the European research and industry in the field of AI. Ultimately, it should strengthen Europe’s AI value chain, and hence its strategic autonomy. However, Eurosmart has a few recommendations to improve the content of the proposed legislation.

Over the last decade, the European Union has been developing a solid cybersecurity regulatory approach. The overall approach is to make the European market more resilient while ensuring the digital sovereignty of the whole continent. This trend has prioritized sensitive domains that deserve strong resilience to more and more skilled attackers.

Eurosmart fully supports the CRA general objective but would recommend a scalable approach for both hardware and software products. The CRA should clearly define the type of products falling under its scope since the market access and market surveillance rules are closely bound with liability.

The NIS Directive has been instrumental in increasing the cyber-resilience of the EU. As the first piece of legislation concerning EU-wide cybersecurity, the NIS Directive is the acknowledgment that incidents in one Member State can have significant cross-border impacts, hence requiring a common level of cybersecurity throughout the EU.

The Product Liability Directive has proven its value during the past three decades to ensure the victims right to compensation, even without fault on the part of the producer (strict liability). This directive oversees significant aspects of the European Single Market; it complements the safety requirements for placing a product on the Market with the right to compensation in case a product is still defective, i.e.

The attached document compiles the feedback provided by Eurosmart on the draft Implementing Regulation concerning the technical description of the categories of important and critical products with digital elements.

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.

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).

The Digital security industry represented by Eurosmart welcomes such an initiative; Europe's standardisation approach is of utmost importance for the efficiency of the digital single market. Europe standardisation is clearly challenged by the increasing evolution and innovation pace of ICT products, services, and processes.

Eurosmart, the voice of the digital security industry supports the political commitment in strengthening reliability of radio equipment placed on the Market. The growing number of internet-connected radio-equipment and more precisely IoT devices, constitute a challenge to ensure both safety and security of products placed on the market.

Eurosmart welcomes the proposal to digitalize national identity cards, enhancing free movement within the EU/SAC Area and leveraging the EUDI Wallet introduced by the amendment to the eIDAS Regulation. However, Eurosmart identifies the following comments: 1.Security Aspects: The proposal lacks clarity on Digital Travel Credentials (DTCs) security aspects.