This document is an analysis of the five draft implementing acts for the eIDAS European Digital Identity (EUDI) Wallet from a human rights and data protection perspective. We are building on our extensive work on this dossier over the past three years and our most recent analysis of the ARF 1.4.

We found an alarming lack of important privacy safeguards in the implementing acts, despite such safeguards being required by the underlying eIDAS Regulation. It almost appears as if the implementing acts reflect the original proposal from the European Commission from June 2021, while turning a blind eye to safeguards added by the European Parliament and Council.