eIDAS: Amendments to the Implementing Acts (batch 2, rev4)

The proposed analysis and amendments are based on the second batch of implementing acts that are currently in public consultation. 

We are alarmed about the decision of the Commission to make wallet relying party registration certificates optional. Thereby, a core pillar of the safeguards regime of the eIDAS ecosystem is rendered meaningless. Furthermore, the relying party registry lacks important components to become a viable tool for independent academic and civil society oversight. Without further specifying the functionalities and data objects available to researchers, it would be hard to see this instrument being used in practice.

To better understand these proposals, we refer to our extensive, in-depth analysis of the five implementing acts, our reaction of the comitology meeting on 22 October and our previous work on this file over the past three years.