Memo to Lawyer-Linguist Staff Reviewing Final Trilogue Version of eIDAS Recital (32) and Article 45

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QWACs Authenticate Websites — The Law Should Say So Clearly

Statements / Open Letters · December 15, 2023

Precision matters, particularly in the final stages of legislation. Following the conclusion of the eIDAS 2.0 trilogue, ESD identifies a potential inconsistency between the definition of Qualified Website Authentication Certificates (QWACs) in Article 3 and the wording of Recital 32. While Article 3 expressly recognises website authentication as a function of these certificates, the recital refers only to their role in linking a website to the person or organisation behind it. ESD proposes a targeted linguistic adjustment to ensure that the final text consistently reflects both functions and avoids uncertainty for the Commission, QTSPs, browsers and website owners.

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