Paper Type: Consultation Responses

ESD comments on the draft Implementing Regulation for the Digital Product Passport registry, supporting the use of established eIDAS trust services while proposing targeted improvements on cloud sovereignty, interoperability, identity proofing and secure registry logs. The aim: a DPP framework that is secure, coherent and works across global supply chains.

Connecting the AML framework with Europe’s existing digital trust infrastructure is essential for secure and reliable remote customer identification. In its response to the draft AML Regulatory Technical Standards, ESD calls for stronger recognition of eIDAS electronic identification, EUDI Wallets and qualified trust services, alongside recognised technical standards that strengthen legal certainty and supervisory convergence across Europe.

Europe’s Business Wallet should build on the trust services that already work — not replace them with a single designated solution. ESD calls for an open and interoperable QeRDS framework that preserves technological neutrality, competition and provider choice, while allowing existing systems to connect seamlessly to the emerging European Business Wallet ecosystem.

Strong supervision works best when compliance requirements are proportionate, targeted and operationally feasible. ESD proposes targeted adjustments to the eIDAS 2 implementing framework for QTSP compliance, including realistic transition periods, a focus on material changes and streamlined notification and termination requirements — strengthening effective oversight while avoiding unnecessary duplication and administrative burden.

Europe’s QWAC framework needs clear rules that combine legal recognition with the realities of today’s web infrastructure. ESD proposes targeted changes to the eIDAS implementing framework to preserve established PSD2 use cases, avoid dependence on private browser root-store decisions and introduce Certificate Transparency once the necessary European standards and infrastructure are in place.

Europe’s qualified electronic archiving framework should be built for long-term preservation and modern digital environments. ESD calls for the eIDAS 2 implementing framework to recognise current European and international archiving standards, including OAIS and CEN/TS 18170:2025, while ensuring that qualified electronic archiving clearly covers both signed and unsigned electronic documents.

A qualified electronic ledger should deliver the level of assurance that “qualified” promises. ESD proposes targeted changes to the eIDAS 2 implementing framework to ensure a technologically neutral approach to electronic ledgers, strengthen the qualified chain of trust through QES, and recognise qualified timestamps as a means of establishing reliable time within the ledger.

Europe’s electronic delivery framework should build on proven standards and services to create a truly interoperable Digital Single Market. ESD calls for the eIDAS 2 implementing framework to recognise established REM standards and preserve technologically neutral, proportionate requirements, enabling existing and future qualified electronic delivery services to connect across borders while supporting competition and innovation.

High-assurance identity verification needs rules that are secure, proportionate and workable in practice. ESD calls for a realistic transition to the new eIDAS 2 requirements, sufficient testing and certification capacity, and continued recognition of existing qualified certificates and identification processes — supporting strong security without disrupting established digital services across Europe.

Digital trust must endure beyond the technological lifetime of a signature or seal. ESD calls for a clear and workable eIDAS 2 framework for qualified preservation, ensuring that the information needed to establish the validity and technical suitability of qualified electronic signatures and seals is reliably preserved over time.