Evidence checklistEU eIDAS

eIDAS checklist and evidence pack

This checklist identifies the records needed to show how an eIDAS trust-service, e-signature, certificate, or EUDI Wallet relying-party decision was made and validated.

The focus is practical evidence: actor role, qualified status, trusted-list entry, certificate and revocation status, validation result, supervisory record, and implementation control.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

An eIDAS evidence pack should show what was relied on and when: the service type, the provider or relying-party role, whether a or non-qualified service was used, the trusted-list and certificate evidence available at the decision time, and the controls used to detect later status changes. The pack supports a reproducible decision; it does not confer qualified status or determine the legal effect of a transaction.

Section 1

1. Classify the eIDAS actor and service before collecting evidence

Start by naming the actor and service because the evidence differs for a trust service provider, a provider, a signatory, a certificate issuer, a website-authentication certificate user, a wallet provider, an attestation provider, or an EUDI Wallet relying party.

For each product flow, record whether the evidence concerns electronic identification, an electronic signature or seal, a certificate, validation or preservation, registered delivery, electronic attestation of attributes, electronic archiving, an electronic ledger, or a wallet presentation.

  • Actor record: legal entity, establishment country, role under eIDAS, service owner, and whether the actor is providing, relying on, validating, or preserving a trust service.
  • Service record: exact trust-service type, qualified or non-qualified claim, countries where the service is used, and whether a public-sector or private-sector relying party is involved.
  • Wallet relying-party record: Member State of establishment, applicable national registration policy, contact details, each intended wallet use, the exact data to be requested, and the user journey that identifies the relying party and displays the request.
  • Boundary record: what is outside the eIDAS claim, such as ordinary login, non-qualified document approval, or data processing controls that belong under GDPR rather than eIDAS.
Section 2

2. Prove qualified status with trusted lists and supervisory records

Do not treat a provider's marketing page or certificate common name as proof of qualified status. For qualified trust services, keep the supervisory and trusted-list evidence that connects the provider, service type, service status, service digital identity, and relevant dates.

The evidence should make it possible for a reviewer to reproduce the qualified-status decision at the time the transaction, certificate, attestation, or signature was accepted.

  • Trusted-list snapshot: Member State trusted list or EU List of Trusted Lists source, retrieval time, list signature or seal validation result, scheme operator, service type identifier, service current status, and service digital identity.
  • Qualified-status check: whether the provider and the exact service are listed as qualified for the service being relied on, not merely present in a trust-service directory.
  • Status-history check: service status start time, prior status entries when relevant, and whether the status was granted, withdrawn, ceased, suspended, or otherwise unsuitable for the transaction.
  • Assurance record: trusted-list evidence of the grant or withdrawal of qualified status, the conformity-assessment scope and cycle where the provider makes that information available, relevant supervisory notices, and termination-plan or continuity evidence needed if the qualified service ceases.
Section 3

3. Validate signature, seal, certificate, and revocation evidence

For a qualified electronic signature, the evidence must support more than a cryptographic pass result. It must show that the supporting certificate was qualified and valid at signing time, the provider was qualified, the validation data matched the signed data, the signatory identity data was provided, any pseudonym was indicated, the signature creation device requirement was met, and the signed data remained intact.

Keep the validation policy, validation time, certificate chain, revocation data, timestamp evidence, and validation report together so the result can be reviewed after certificate expiry, revocation, or trust-list changes.

  • Certificate evidence: qualified-certificate indication, issuing provider, signatory or seal-creator data, validity period, status-service location, and certificate path used for validation.
  • Revocation and suspension evidence: Online Certificate Status Protocol (OCSP) response or certificate revocation list (CRL), response time, source endpoint, result, and proof that a revoked qualified certificate was not treated as valid after revocation took effect. If national law permits temporary suspension, record the suspension period and do not treat the certificate as valid during that period.
  • Signature validation evidence: format, signed data hash or identifier, validation time, best-signature-time where used, validation policy, validation report, and whether the final qualified-signature determination passed.
  • QSCD evidence: proof used to determine that the private key was held in a qualified signature creation device or managed by a qualified remote signature creation service when the claim depends on qualified signature status.
  • Preservation evidence: long-term validation material, timestamp records, and any evidence record added to an XML advanced electronic signature (XAdES), a Cryptographic Message Syntax advanced electronic signature (CAdES), a PDF advanced electronic signature (PAdES), or an Associated Signature Container (ASiC).
Section 4

4. Add EUDI Wallet relying-party and attestation controls

A relying party that requests wallet data should keep evidence for registration, request scope, user display, wallet authenticity checks, Person Identification Data (PID) and electronic attestation of attributes (EAA) validation, and pseudonym handling. The record should show what was registered for each intended use, what was requested from the wallet, why the service needed it, and what the user approved.

Commission Implementing Regulation (EU) 2025/848, as amended by Commission Implementing Regulation (EU) 2026/1730, supplies the harmonised national-register, access-certificate, registration-certificate, suspension, and record-keeping rules from 24 December 2026. The amended rules require automatic registration-certificate issuance without undue delay after registration. Until the applicable Member State process is operating, record the available national route and do not treat a draft application or test certificate as accepted registration.

For attestations, keep separate records for Person Identification Data, qualified electronic attestations of attributes, public-body authentic-source attestations, and non-qualified electronic attestations of attributes because the validation and legal-effect evidence is not the same.

  • Registration evidence: Member State and registrar, registration status when available, relying-party identity and contact details, service type, each intended use, the specific attestations and attributes to be requested, any intermediary association, and a change-notification log.
  • Data request evidence: attribute list shown to the user, purpose, minimum-data justification, user confirmation step, and whether pseudonymous authentication was accepted when legal identification was not required.
  • Validation evidence: wallet authenticity check, PID validation result, EAA or qualified electronic attestation of attributes (QEAA) validation result, issuer or authentic-source evidence, trust-list or certificate status, and error-handling outcome.
  • Attestation evidence: attestation type, issuer, qualified or public-body status if claimed, revocation status, certificate supporting the issuer signature or seal, and the location where that certificate can be obtained.
  • Implementation controls: API and protocol version, access-certificate validation, request signing, replay and tamper checks, incident escalation, and evidence retention. If an intermediary acts for the relying party, its logs must not retain transaction-content data.
Section 5

5. Close the evidence pack only when controls are reproducible

The checklist is complete only when another reviewer can repeat the validation with the same sources, records, and timestamps. A screenshot without the underlying trusted-list source, certificate status response, validation report, or supervisory reference is not enough for a durable eIDAS evidence pack.

Reopen the pack when a service status changes, a certificate is revoked or suspended, a wallet provider or attestation provider loses the status relied on, a relying-party registration is suspended, cancelled, or changed, validation tooling or policy changes, or the product begins relying on a new . eIDAS does not set one universal retention period for every relying-party record; document the period from the applicable transaction, sector, limitation, evidence, data-protection, and contract rules. Article 24 separately requires a QTSP to keep relevant issued and received information accessible for as long as necessary after its activities cease.

  • Store source URLs, retrieval timestamps, validation reports, trust-list files or references, certificate and revocation responses, supervisory records, approval notes, and implementation-control evidence in the same evidence package.
  • Assign owners for legal classification, trust-list monitoring, certificate validation, wallet integration, incident response, supplier management, and evidence retention.
  • Retention record: applicable rule or contract, start event, retention period, legal-hold or dispute override, archive format, integrity control, access owner, and deletion approval.
  • Block release when qualified status is asserted but the exact provider-service pair is missing from trusted-list evidence, when certificate status is unknown, or when the relying party requests data not covered by its wallet registration record.
  • Verify any penalty, deadline, or certification claim against the provision that applies to the service, actor, and jurisdiction before using it in an approval or supplier assessment.
Primary sources

References and citations

eur-lex.europa.eu6 citations
Referenced sections
  • Primary legal source for eIDAS actor definitions, trust-service categories, qualified status, signature validation, wallet relying-party duties, attestations, and supervisory tasks.
  • Defines relying parties, qualified electronic signatures, trust services, qualified trust services, wallet functions, and electronic attestations of attributes.
  • Requires supervisory bodies to grant and withdraw qualified status, analyse conformity assessment reports, and inform trusted-list bodies of status decisions.
Show 3 more
  • Sets the validation conditions for qualified electronic signatures and the certificate revocation and suspension consequences.
  • Defines wallet functions, relying-party validation responsibility, pseudonym treatment, qualified attestations of attributes, and authentic-source attestations.
  • Supports release gates tied to qualified status, certificate validity, revocation, supervisory reporting, and wallet relying-party responsibilities.
"electronic identification and trust services"
More quoted passages
"relying party"
"grant qualified status"
"validation of a qualified electronic signature"
"validate person identification data"
"status shall not in any circumstances be reverted"
etsi.org4 citations
Referenced sections
  • Technical specification for trusted-list format, TSP and service information, service digital identity, service status, status history, and trusted-list use in validation.
  • Specifies trusted-list structure, including scheme information, TSP information, service type, service digital identity, current status, and status history.
  • Supports using trusted-list service digital identities and service status as trust anchors in certificate path and signature validation.
Show 1 more
  • Supports repeatable trusted-list monitoring through service current status, status starting time, service history, and trusted-list re-issuance practices.
"Trusted Lists"
More quoted passages
"certificate path validation"
"checked regularly for changes"
ec.europa.eu3 citations
Referenced sections
  • Practical Commission guidance for relying parties that request data from EUDI Wallet users, including registration, data requests, validation, pseudonym, certification, and trust-list considerations.
  • Grounds the relying-party checklist: registration, requested data, user-facing identification, validation of PID and EAA data, and pseudonym handling.
  • Explains service-provider registration, wallet data requests, user confirmation, PID and EAA validation, trust-list checks, and certification status checks.
"EU Digital Identity Wallets for service providers"
More quoted passages
"request data from an EU Digital Identity Wallet"
"Not request any extra user data"
enisa.europa.eu2 citations
Referenced sections
  • Supervision-focused source for qualified trust service provider oversight and supervisory evidence context.
  • Provides supervisory context for qualified trust service oversight and Article 20 supervision practices.
"supervision of qualified trust services"
More quoted passages
"supervision of qualified trust service providers"
eu-digital-identity-wallet.github.io2 citations
Referenced sections
  • Architecture and ecosystem source for EUDI Wallet roles, relying-party interactions, attestations, trust model, certification, and implementation specifications.
  • Provides ecosystem and architecture context for wallet providers, relying parties, attestations, trust model, certification, and implementation specifications.
"Architecture and Reference Framework"
ec.europa.eu2 citations
Referenced sections
  • Technical documentation for signature and certificate validation, revocation data, trusted-list use, qualification determination, and evidence records.
  • Documents practical DSS validation outputs, trusted-list interpretation, revocation data, best-signature-time handling, and evidence-record support.
"Digital Signature Service"
More quoted passages
"signature can be determined as qualified"
ec.europa.eu2 citations
Referenced sections
  • Commission building-block page identifying eSignature resources, DSS, the eIDAS Dashboard, the Trusted List Browser, and validation tests.
  • Identifies the eIDAS Dashboard and Trusted List Browser as practical tools for finding qualified trust service providers and trusted-list information.
"Trusted List Browser"
eur-lex.europa.eu
Referenced sections
  • Sets the harmonised relying-party registration, certificate, suspension, cancellation and registrar record-keeping rules from 24 December 2026. Its original optional registration-certificate provision is replaced by the mandatory automated-issuance rule in Regulation (EU) 2026/1730.
"It shall apply from the 24 December 2026."
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