Paper Type: Position Papers

As eIDAS 2.0 enters trilogue, ESD proposes a pragmatic transition from Level of Assurance “substantial” to “high”. Rather than discontinuing widely used identification methods immediately, ESD calls for “substantial” to remain available until the EUDI Wallet at LoA “high” reaches a defined level of uptake. This would safeguard uninterrupted access to qualified trust services while enabling a gradual transition to the new framework.

Reliable electronic attestations of attributes depend on reliable sources of information. As the eIDAS 2.0 proposal enters trilogue, ESD calls for greater clarity around the concept of “authentic sources”, which provide the underlying information for attributes used in the European Digital Identity ecosystem. ESD advocates transparent and harmonised rules for identifying authentic sources, appropriate national supervision, and secure mutual authentication between authentic sources and providers of electronic attestations of attributes. Common European requirements can strengthen trust in wallet attributes while supporting interoperability and a functioning Digital Single Market.

As eIDAS 2.0 moves towards trilogue, ESD calls for the deletion of the requirement to provide qualified electronic signatures free of charge to all EUDI Wallet users. While supporting wider access to qualified signatures, ESD warns that extending free services to legal persons could shift costs to taxpayers and undermine Europe’s competitive trust services market. A sustainable framework should promote wallet adoption while preserving competition, innovation and Europe’s existing trust infrastructure.

As eIDAS 2.0 moves towards trilogue, ESD calls for the deletion of the newly introduced Recital 31a. ESD warns that encouraging Member States to develop different approaches to the use of advanced and qualified electronic signatures risks creating national fragmentation where eIDAS is designed to provide European harmonisation. A coherent EU framework for electronic signatures is essential for cross-border interoperability, legal certainty and a functioning Digital Single Market.

Can users reliably tell whether a website is genuine or fake? ESD demonstrates why the user-friendly identity interface required by Article 45.2 matters for consumer protection and online security. Using practical examples of look-alike websites, the paper shows how QWACs can provide users with verified information about the entity behind a website. ESD calls on MEPs to support a simple, consistent and recognisable identity interface across browsers, helping citizens make informed decisions when interacting online.

Trust online starts with knowing who is behind a website. ESD presents five reasons why the new eIDAS Article 45 on Qualified Website Authentication Certificates (QWACs) should be adopted. The paper highlights how Article 45 can strengthen verified website identity, consumer protection and Europe’s digital sovereignty, while ensuring that trust decisions affecting EU-regulated services are governed by a transparent European framework rather than proprietary browser policies alone.

As the eIDAS negotiations enter a decisive phase, ESD responds to claims that Article 45.2 and Qualified Website Authentication Certificates (QWACs) would weaken internet security. The paper addresses these claims point by point and explains how QWACs combine secure encryption with verified website identity and additional European audit and supervision requirements. ESD argues that Article 45.2 can strengthen consumer protection while ensuring that trust decisions affecting EU-regulated services are governed within Europe’s regulatory framework.

During the legislative process for the revision of eIDAS, ESD highlights the findings of the German Bundeskartellamt concerning browser practices around website identity information and the recognition of Qualified Trust Service Providers. The German authority examined Google’s practices and concluded that key issues concerning the display of certificate information and withdrawal of trust are better addressed through European legislation. ESD therefore calls on Members of the European Parliament to support the Commission’s proposed Article 45 as an EU-wide solution — strengthening the recognition of QWACs, ensuring that citizens can identify who is behind a website, and preventing unilateral browser policies from determining trust within the European trust space.