European Digital Identity Framework – validation of qualified/advanced electronic signatures and seals

European Commission · Have your Say · Initiative 16072

Implementing Regulation (EU) 2025/1945 on the validation of qualified and advanced electronic signatures and seals · Statement of October 28, 2026

Core statement: A signature is only worth as much as its validation. GISAD welcomes the harmonisation of validation through open reference standards and decentralised trust lists – it is the right infrastructure for trust. But validation must not become identification: validating a signature confirms its validity and the eligibility it certifies, not the exposure of the person using it. Whoever conflates the two is not building a trust infrastructure, but a surveillance infrastructure.

What the regulation provides

Implementing Regulation (EU) 2025/1945 of 29 September 2025, published in the Official Journal on 30 September 2025 and applicable since 20 October 2025, sets out the reference standards for the validation of qualified electronic signatures and seals (Annex I) and of advanced electronic signatures and seals based on qualified certificates (Annex II): ETSI TS 119 172-4 (validation policy for European qualified signatures and seals using trusted lists) and ETSI TS 119 102-2 (signature validation report), each with specified adaptations. The act is based on Articles 32(3), 32a(3), 40 and 40a of the eIDAS Regulation (EU) No 910/2014. A companion act, Implementing Regulation (EU) 2025/1942, governs the qualified validation services themselves.

Recognition: testing by open rules is structure, not arbitrariness

GISAD expressly acknowledges two design decisions. First: the reference standards are open, documented and comprehensible to everyone – validation becomes a measurable check instead of a black-box verdict. This corresponds to the principle of measurement outside the manipulable area: the validation report (ETSI TS 119 102-2) makes the check itself reviewable. Second: the trust anchors lie in the trusted lists of the Member States – distributed decentrally, not in one central register that could become a single point of failure or a central point of access.

Criticism 1: validation confirms the signature, not the person

The regulation governs the technical validity check. The danger lies in the practice that follows: when recipients automatically turn every validated signature into an identification event, and validation processes are logged, a movement profile emerges – when, where and with which system a signature was checked and used. The signature confirms eligibility; it does not have to identify the person. The EU-D-S separates precisely this with its border rule upon entering Trusted WEB 4.0: identity only where identity is needed. The signed instance number issued by the Truststation is the model – it confirms eligibility without identifying the user, and transaction numbers can only be assigned internally. Pseudonymous qualified certificates, which eIDAS provides for, must be fully supported in validation policies as a normal case, not treated as an exception.

Criticism 2: the validator must not become the gatekeeper

Validation must remain possible everywhere and by anyone who applies the open standards – not de facto only through qualified validation services and vendor-specific verification tools. If checking is tied to a few service providers, a new gatekeeper level emerges: whoever checks decides what counts. The chain must not read: trust is generated by the signature, the signature is checked by the service provider, the service provider decides the benefit. Trust must lie with the structure – open standards, comprehensible reports, decentralised trust anchors.

GISAD’s recommendations

1. Validation policies must strictly separate signature validity from signer identity; pseudonymous qualified certificates as an equivalent normal case, not as an exception.
2. Keep validation logs data-minimal: no central retention of checking processes that create movement profiles; assignment only internal, following the transaction number model of the EU-D-S.
3. Guarantee independent validation by anyone using open standards – the validation report (ETSI TS 119 102-2) as the standard of comprehensibility; no de facto dependence on individual service providers or verification tools.
4. Keep trust anchors decentralised in the trusted lists of the Member States – no central EU trust register as a single point of failure.
5. Adopt the border rule of the EU-D-S as validation practice: the check confirms eligibility (signed by the Truststation) without identifying the user – WAN anonymity up to the point where identity is legally required.