eIDAS Implementing Acts (4th batch)

Bitkom underlines the need for substantial improvements across several draft Implementing Acts under the eIDAS Regulation (EU) No. 2024/1183. Regarding the accreditation of conformity assessment bodies, Bitkom calls for clearer roles and responsibilities, consistent terminology, and proportionate, flexible procedures aligned with eIDAS and ETSI standards to avoid confusion and implementation delays. On the draft Act concerning risk management for non-qualified trust service providers, Bitkom stresses the importance of removing redundancies, clarifying provisions on user risk communication, identity verification and data retention, as well as ensuring harmonization with security standards and granting sufficient transition time. Finally, Bitkom highlights the need to extend the deadline for entry into force from six to twelve months, to give providers and supervisory bodies the necessary time to adapt without jeopardizing trust or existing infrastructures.