At Alastria, we have submitted our official feedback to the European Commission regarding the draft implementing acts for the eIDAS 2 framework. Our analysis reveals a critical «regulatory gap» that must be addressed to protect years of industrial investment.
While the current draft formally references W3C Verifiable Credentials (W3C-VC), it lacks the necessary «regulatory scaffolding»—such as encoding tables, revocation rules, and presentation profiles—that is already defined for other formats like mdoc and SD-JWT VC.
This is not a niche technical concern; it is a matter of economic and strategic sovereignty:
- Massive Investment: Over €80 million in European public funding (through projects like DC4EU, EBSI VECTOR, and ISBE) is built natively on W3C-VC.
- Wide Adoption: These initiatives involve more than 200 organizations across 20+ countries, with a potential user base of 30 million citizens.
- Industrial Leadership: From Spain’s national blockchain infrastructure (ISBE) to international health credentials and B2B anti-fraud systems, European companies are already leading with these standards.
Our Recommendations
To ensure a robust and interoperable EUDI Wallet ecosystem, Alastria endorses 8 concrete regulatory actions, including:
- Defining PID encoding tables for W3C-VCDM v2.0.
- Adopting the Bitstring Status List to support both revocation and suspension.
- Ensuring W3C-VC can achieve «qualified» status to avoid stranding legitimate public and private investments.
We encourage the Commission to leverage and build upon the successful foundations that have already been funded and validated across the EU. Supporting open, decentralized standards is the only way to prevent vendor lock-in and fulfill the European Parliament’s mandate for a truly sovereign digital infrastructure.
The technology is proven. The investment has been made. The standards have been published. What remains is the political decision to complete the regulatory framework that European industry has built on.
20260305_ALASTRIA contribution_Public Consultation_eIDAS_W3C