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
Jul 24, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
8

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 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: OCSP or CRL response, 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 a XAdES, CAdES, PAdES, or ASiC object.
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, PID and 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 supplies the harmonised national-register, access-certificate, registration-certificate, suspension, and record-keeping rules, but it applies from 24 December 2026. Until the applicable Member State process is operating, record the available national route and do not claim that a draft registration pack or test certificate is an 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 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.
  • Do not add penalties, market deadlines, or certification promises unless the cited eIDAS source and cited source material directly support them.
Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Sets the harmonised wallet-relying-party register, registration information, access-certificate, optional registration-certificate, suspension, cancellation, and registrar record-keeping rules, and applies from 24 December 2026.
"It shall apply from the 24 December 2026."
etsi.org
Referenced sections
  • Supports repeatable trusted-list monitoring through service current status, status starting time, service history, and trusted-list re-issuance practices.
"checked regularly for changes"
eu-digital-identity-wallet.github.io
Referenced sections
  • Provides ecosystem and architecture context for wallet providers, relying parties, attestations, trust model, certification, and implementation specifications.
"Architecture and Reference Framework"
ec.europa.eu
Referenced sections
  • Identifies the eIDAS Dashboard and Trusted List Browser as practical tools for finding qualified trust service providers and trusted-list information.
"Trusted List Browser"
ec.europa.eu
Referenced sections
  • Explains service-provider registration, wallet data requests, user confirmation, PID and EAA validation, trust-list checks, and certification status checks.
"Not request any extra user data"
eur-lex.europa.eu
Referenced sections
  • Supports release gates tied to qualified status, certificate validity, revocation, supervisory reporting, and wallet relying-party responsibilities.
"status shall not in any circumstances be reverted"
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