INATBA’s Privacy Working Group officially submitted a position paper regarding the draft amending Implementing Regulations under the eIDAS 2.0 and European Digital Identity (EUDI) Wallet framework. The response highlights critical gaps in the current regulatory approach that could hinder privacy and interoperability for European citizens.

The core of the submission argues that while W3C Verifiable Credentials (VCs) are formally recognized in the framework, they lack the necessary “operational scaffolding”—specifically harmonized issuance and presentation profiles—to be practically usable within the EUDI Wallet ecosystem.

Key Takeaways from the Response

• Addressing Regulatory Asymmetry: The current draft creates a “de jure” inclusion but a “de facto” exclusion of W3C VCs. Without harmonized profiles for issuance and presentation, these credentials cannot function on equal terms with other formats, undermining the principle of technological neutrality.
• Protecting Privacy-Preserving Architectures: A major concern is the absence of a regulated presentation profile for JSON-LD W3C VCs using data integrity proofs. This omission removes a technically credible path for selective disclosure and future unlinkability-enhancing mechanisms, effectively narrowing the privacy design space of the EUDI Wallet.
• Preventing Market Fragmentation: Without clear, Commission-level adaptations and harmonized profiles, wallet providers and issuers face legal uncertainty. This may lead Member States to fill regulatory gaps independently, resulting in a fragmented Digital Single Market.
• Recommendations for the Commission: INATBA urges the Commission to define a harmonized issuance profile under OID4VCI, provide missing adaptations for W3C-VC attestations, and preserve regulatory optionality to allow the framework to evolve as privacy-enhancing technologies mature.
• Commitment to Open Standards: The position aligns with European goals for technological sovereignty, emphasizing that digital public infrastructure should be built on common, open standards that ensure privacy and security by default.

We would like to extend its sincere gratitude to the author Gabi Urrutia (Halborn, Privacy WG Co-chair), and the reviewers Sharmin Chougule (Philipps University Marburg, UNIDROIT, INATBA Academic Advisory Board), Ingrid Vasiliu-Feltes (EU Blockchain Observatory and Forum), and Mauricio Garita (Universidad Francisco Marroquin, Universidad de las Hespérides, INATBA Academic Advisory Board) for additional review and comments. 

We look forward to continuing our constructive dialogue with the European Commission to ensure a coherent, privacy-preserving, and interoperable EUDI Wallet ecosystem.

Read the full response here: Completing the regulatory framework for W3C Verifiable Credentials in the EUDI Wallet ecosystem