eIDAS: Amendments to the Implementing Acts (batch 2, rev5)

This analysis and the proposed amendments are based on the second batch of implementing acts for the eIDAS regulation after their public consultation in the updated version.

We welcome the decision of the Commission to make wallet relying party registration certificates mandatory.
However, we see significant omissions in the implementing act on relying party registration and a lack of clarity in the distinction between KYC and non-KYC use cases.
Moreover, we're alarmed about the blatant overreach in the implementing act on identity matching. The Commission proposal thus contradicts the eIDAS regulation and the agreement with the European Parliament.

To better understand these proposals, we refer to our consultation response for the previous version of the implementing acts in the second batch, the open letter about them signed by 15 digital rights and consumer protection organisations and our extensive work on this file over the past three years.