Artifact GuideEU

EU eIDAS QTSP Authorization and Supervision

Under eIDAS, the supervisory body grants qualified status to a trust service provider and its qualified service. The service may begin only after that status is indicated in the Member State trusted list; branding, contract language, and a certificate policy do not replace that entry.

This page helps organize initiation, recurring conformity assessment, supervisory change notifications, trusted-list checks, incident reporting, and evidence for qualified trust services.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

A provider becomes a for a specific service only after supervisory review and entry of the qualified provider-service pair in the relevant Member State . Track the full eIDAS lifecycle: the intended qualified trust service, conformity assessment report, grant or withdrawal decision, trusted-list entry, recurring audit, change and cessation notices, security breach handling, and service-specific evidence.

Section 1

What makes a trust service provider a QTSP under eIDAS?

eIDAS defines a as a trust service provider that provides one or more qualified trust services and has been granted qualified status by the . That status is service-specific: a provider may be qualified for one trust service and not for another.

For a new qualified trust service, the provider must notify the and submit a conformity assessment report from a . The supervisory body grants status and initiates the trusted-list update no later than three months after notification when it concludes that the provider and service comply. If verification is not complete in three months, it must explain the delay and expected completion period. The provider may begin the qualified service only after qualified status appears in the .

  • Identify the exact qualified trust service, such as qualified certificates, qualified time stamps, qualified registered delivery, validation, preservation, attestations of attributes, or remote qualified signature or seal creation device management.
  • Keep the conformity assessment report that supports the initiation notification.
  • Record the 's grant of qualified status for both the provider and the specific service.
  • Verify the public trusted-list entry before describing the service externally as qualified.
Section 2

Authorization and supervision records to keep together

The operating record should connect the qualified service, the conformity assessment scope, the decision, the trusted-list status, and the controls that keep the service inside the assessed scope.

eIDAS requires QTSPs to be audited at their own expense at least every 24 months by a , to notify the at least one month before each planned audit, and to submit the resulting conformity assessment report within three working days of receipt. The supervisory body may observe the planned audit, audit a QTSP itself, or request a conformity assessment at any time. Providers granted qualified status before 20 May 2024 had to submit a report proving compliance with the amended Article 24(1), (1a), and (1b) by 21 May 2026; a current review should confirm that transition record where it applies.

  • Service register: provider name, Member State, , qualified service type, service digital identity, customer-facing service name, and launch status.
  • Assessment file: , accreditation status, assessment scope, planned-audit notice sent to the at least one month before the audit, report date, report receipt date, and submission evidence to the supervisory body.
  • Supervision file: questions, remedies required, deadlines set by the supervisory body, closure evidence, and any decision to grant or withdraw status.
  • Trusted-list file: current trusted-list status, service history, LOTL or national trusted-list retrieval evidence, and validation-tool output used by relying parties.
  • Change file: notifications for planned changes, intended cessation, termination plan evidence, and supervisory responses.
Section 3

Trusted lists are the public status check

Trusted lists are the public mechanism that lets relying parties check whether a provider and service have qualified status and see status history. eIDAS requires Member States to establish, maintain, and publish trusted lists for the QTSPs they are responsible for and the qualified services those QTSPs provide.

The European Commission publishes a central List Of Trusted Lists so systems can locate Member State trusted lists. ETSI explains that trusted lists have constitutive effect for EU qualified trust services: the legal effect associated with a qualified trust service depends on the service being listed as qualified.

  • Do not rely only on a supplier statement that it is a QTSP; check the for the specific provider and service.
  • Store evidence of the trusted-list status used for onboarding, renewal, incident investigation, and signature or certificate validation.
  • For machine checks, record the LOTL or national trusted-list source, status value, service type, service digital identity, retrieval time, and validation result.
  • Treat status changes such as withdrawal as operational triggers for customer notices, relying-party validation rules, procurement blocks, and service continuity review.
Section 4

Security, incident, and change obligations that affect qualified status

QTSP authorization is not finished after the initial trusted-list entry. eIDAS Article 24 requires a QTSP to inform the before changes to qualified trust services or intended cessation, maintain appropriate risk-management measures, use trustworthy systems, keep relevant issued and received information accessible, and maintain an up-to-date termination plan.

Notify the at least one month before implementing a change to a qualified trust service and at least three months before intended cessation. The authority may request more information or a conformity assessment and may condition permission for the change. Keep the notice, requested evidence, authority response, conditions, implementation date, and trusted-list update together.

For security breaches or disruptions that significantly affect the trust service or personal data maintained in it, Article 24(2)(fb) requires the QTSP to notify the , identifiable affected individuals, other relevant competent bodies where applicable, and, at the supervisory body's request, the public when disclosure is in the public interest. The consolidated text requires notification without undue delay and in any event within 24 hours of the incident. Keep that eIDAS trigger and deadline separate from NIS2 and GDPR notification tests.

  • Maintain incident procedures that identify when a trust-service event is significant for eIDAS notification.
  • Keep logs, event classification, containment, eradication, recovery, notification, and post-incident review evidence.
  • Tie change management to the approved qualified service scope, including infrastructure, cryptographic controls, service access points, subcontractors, termination plans, and certificate or status services.
  • When a failure affects eIDAS, NIS2, or personal data protection requirements, record which authority channel was used and why.
Section 5

Evidence checklist for procurement, audit, and relying-party review

A relying party, auditor, or procurement reviewer should be able to determine whether a claimed qualified service is qualified, current, and within scope. The review should connect legal status, technical validation, supervisory history, and operating controls.

Keep evidence at the service level. A provider-wide certificate, a marketing page, or a generic ISO certificate does not prove that a particular eIDAS trust service currently has qualified status.

Can a provider call itself a QTSP before the is updated under eIDAS?

No for the qualified service. Under eIDAS, a provider may begin providing the qualified trust service only after qualified status is indicated in the . Internal readiness, a passed audit, or a submitted conformity assessment report is not enough by itself.

How often must an eIDAS QTSP undergo conformity assessment after authorization?

A QTSP must be audited by a at least every 24 months and submit the resulting conformity assessment report to the within three working days of receipt. It must also notify the supervisory body at least one month before a planned audit and allow the supervisory body to observe on request. The supervisory body may audit or request conformity assessment at any time.

What evidence proves that a qualified trust service is still qualified?

Use the current Member State trusted-list entry, including the service type, provider, service digital identity, status value, and status history. Pair that with the latest conformity assessment report, supervisory correspondence, and any change, incident, or cessation records that could affect the service.

  • Current trusted-list entry for the provider and service, including service type, status, status history, and service digital identity.
  • Conformity assessment report and submission evidence for initiation, recurring 24-month assessment, or ad hoc supervisory assessment.
  • decision evidence for grant, remedy, continuation, withdrawal, or delay in verification.
  • Practice statement, terms and conditions, service scope, limitation-of-use language, and public trust-mark usage records.
  • Security and continuity evidence: risk measures, incident logs, notification records, business continuity links, termination plan, revocation or validity-status service records, and post-incident reviews.
  • Change evidence: notifications sent before material qualified-service changes, cessation notices, supervisory questions, approval conditions, and implementation records.
Recommended next step

Review qualified status, trusted-list proof, and supervision evidence

Sorena can help structure QTSP evidence around the specific qualified service, trusted-list status, conformity assessment report, supervisory record, change notices, incident handling, and continuity evidence.

Primary sources

References and citations

enisa.europa.eu
Referenced sections
  • ENISA describes Article 20 supervision guidance for qualified trust services and identifies supervisory authorities, providers, and stakeholders as the intended audience.
"supervision of qualified trust services"
enisa.europa.eu
Referenced sections
  • ENISA provides security-framework guidance for trust service providers, including technical guidelines for risk and incident-related controls.
"Security framework for Trust Service Providers"
portal.etsi.org
Referenced sections
  • Explains that EU Member State trusted lists include supervised QTSPs and their qualified trust services, and that users rely on trusted lists to determine qualified status and status history.
"provider/service will be qualified only if it appears in the trusted lists"
etsi.org
Referenced sections
  • Provides operational requirements for TSP monitoring, logging, incident response, reporting procedures, event assessment, post-incident review, and evidence collection.
"Vulnerabilities and Incident management"
etsi.org
Referenced sections
  • Supports trusted-list evidence fields such as status values, service digital identity, status history, and LOTL-based discovery.
"Service current status"
eur-lex.europa.eu
Referenced sections
  • Supports the checklist items for initiation, periodic conformity assessment, trusted-list indication, change notifications, incident obligations, and withdrawal of qualified status.
"submit the resulting conformity assessment report"
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