Statement on the updates to the eIDAS 2.0 regulations

The Association of German Banks (BdB) has issued a statement on the planned updates to various secondary legal acts of the eIDAS 2.0 Regulation. These concern the concrete implementation of the European Digital Identity Wallet (EUDIW) and specify how digital identities are to function across Europe in the future. The BdB emphasizes that many of the proposed rules are unnecessarily technical in their wording and recommends instead relying on easily adaptable European standards. It also advocates avoiding unclear terms, leaving technical details to expert committees, and welcomes the planned inclusion of a photo in the digital ID card. The indication of nationality should also take into account cases such as statelessness or protected status.

Furthermore, the BdB points out that new rules for companies using the wallet are too technical or insufficiently justified and that the focus should be more on a transparent registration process. With regard to digital evidence such as driver's licenses or certificates, the association calls for clearer justifications for deletions, better allocation of individual requirements to appropriate legal areas, and restraint in introducing new technical terms. Overall, the BdB supports the objectives of the digital identity wallet—ease of use, high security, and Europe-wide applicability—provided that the regulations remain clearly structured, comprehensible, and easy to maintain in the long term.