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.
SA
Signicat AS
Company · Norway
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
3
positions filed
in the 665 files tracked
3
legislative files
of 665 tracked
0
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
Signicat AS filed 3 positions between 13 May 2025 and 30 Dec 2025, across 3 of the 665 legislative files tracked here.
What they argued
Signicat's has not had time to provide detailed feedback to this implementing act and its annex, but a look reveals the same problems as the other implementing acts in this batch. Most important: - Add a provision to update to accommodate new versions of standards - Do not overrule standards' requirements unless absolutely necessary and justified - Several proposals are highly problematic to existing providers -…
Signicat is one of Europe's leading providers of identity-related services and also provides the editor of hte referenced ETSI TS 119 461 standard. We would like to provide the following feedback on this draft implementing act. The implementing act only considers the identity proofing part of onboarding.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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