ESD Contribution to the Article 49 Review of eIDAS

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Making eIDAS More Efficient, Coherent and Workable

Position Papers · September 25, 2026

In the context of the Article 49 review, ESD proposes targeted amendments to make the eIDAS framework more effective and workable in practice. Drawing on the operational experience of Europe’s trust service industry, the paper identifies legal and practical obstacles and proposes concrete solutions to strengthen legal certainty, avoid duplicative compliance and support a coherent European Digital Identity ecosystem.

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