eIDAS: Amendments to the Implementing Acts (batch 2, rev6)

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 are extremely alarmed that the Commission has reversed course and made wallet relying party registration certificates optional again. This leaves users critically exposed and goes against the advice of the EDPS and 15 digital rights and consumer protection NGOs. Critically, the right to use pseudonyms is also unworkable in practice. We urge EU member states to vote against the current proposals in the Comitology meeting on 9 April 2025 and propose amendments to repair the drafts.