Artifact GuideEU

EU eIDAS Regulation QTSP Due Diligence Workflow

Use this workflow before relying on a qualified trust service provider for signatures, seals, timestamps, website authentication certificates, attestations, archiving, ledgers, or related qualified trust services.

The checks focus on trusted-list validation, exact qualified service scope, certificate and revocation evidence, published policies, supervision, audits, termination planning, incident posture, and records to retain.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
6

Cited legal and guidance references.

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

A QTSP is not selected only by brand name or by a marketing claim that it is eIDAS compliant. Under eIDAS, qualified status is tied to a provider, the qualified services it provides, supervisory decisions, trusted-list entries, and service-specific evidence. This workflow gives procurement, product, security, legal, and compliance teams a concrete review path before onboarding or continuing to rely on a QTSP.

Section 1

1. Confirm the provider and service in the EU trusted-list system

Start with the Member State trusted list and the Commission List Of Trusted Lists, not with a vendor certificate bundle or sales deck. eIDAS requires Member States to establish, maintain, and publish trusted lists that identify qualified trust service providers and the qualified trust services for which they are responsible.

Record the legal provider name, Member State, trusted-list location, scheme operator, service name, service type identifier, service digital identity, current service status, status start time, and relevant service history. If the service is not shown as qualified for the exact service you intend to rely on, treat the due diligence result as blocked until the provider or supervisory record explains the gap.

  • Verify that the provider is a qualified trust service provider, not only a trust service provider with a non-qualified service.
  • Match the listed service type to the planned use case, such as qualified certificates for electronic signatures, seals, website authentication, timestamps, electronic registered delivery, electronic attestations of attributes, archiving, or ledgers.
  • Check current status and historical status entries because trusted lists are designed to show whether a service is or was operating in compliance at a specific time.
  • Keep a machine-readable trusted-list extract or validation output, a human-readable screenshot if useful, and the date and time of the check.
  • Do not accept a generic EU trust mark, logo, or website claim unless it links back to the relevant trusted-list entry for the qualified service.
Section 2

2. Scope the qualified service and certificate evidence

A QTSP can provide more than one service, and only some services may be qualified. Scope the review to the exact certificate, timestamp, validation, preservation, registered delivery, attestation, archiving, ledger, or remote signing service that the product will consume.

For certificate-based services, review the certificate policy, certification practice statement, certificate profile, usage limits, revocation mechanism, validity information, and any qualified-certificate statements that indicate the applicable legal framework and certificate purpose. Qualified certificate diligence should distinguish electronic signature, electronic seal, and website authentication uses rather than treating all qualified certificates as interchangeable.

  • Collect the CP, CPS, terms and conditions, relying-party guidance, subscriber obligations, certificate type descriptions, and policy object identifiers that apply to the service.
  • For qualified certificates, verify that the certificate identity, issuer identity, qualified status, certificate purpose, key usage, extended key usage, QCStatements, and country/legal-framework indicators match the intended reliance model.
  • For QWACs, confirm that the certificate is a qualified certificate for website authentication and that the service scope in the trusted list covers that certificate service.
  • For revocation-sensitive workflows, test the published validity or revocation status mechanism and keep the result with the onboarding record.
  • For remote signing or managed devices, document whether the reviewed service includes management of a remote qualified electronic signature creation device or only certificate issuance.
Section 3

3. Review supervision, audits, security controls, and change triggers

The operational diligence should connect provider claims to supervisory and conformity-assessment evidence. eIDAS requires qualified trust service providers to be audited by a conformity assessment body at least every 24 months and to submit the resulting conformity assessment report to the supervisory body within three working days of receipt.

The monitoring plan should also cover changes in the qualified service, planned cessation, security incidents, supply-chain dependencies, and termination arrangements. If the provider changes the service, loses qualified status for the provider or affected service, changes the trusted-list status, or announces cessation, reopen the review before further reliance.

  • Ask for evidence of the latest conformity assessment cycle, the scope of services assessed, the conformity assessment body, and whether any open remediation affects the service you rely on.
  • Confirm that the provider knows which supervisory body is responsible and can explain how supervisory decisions update the trusted list.
  • Check the provider's information security policy, risk assessment approval, incident response process, monitoring and logging, business continuity controls, and post-incident review process.
  • Review the termination plan because eIDAS and ETSI requirements expect continuity of information needed to verify trust-service correctness after cessation.
  • For outsourced or cloud-supported service components, retain the provider's supply-chain control summary, relevant service-level commitments, and assurance that the QTSP remains responsible for its service.
Section 4

4. Evidence to retain for QTSP selection and ongoing monitoring

Keep the record useful for a later customer question, audit, dispute, incident, or migration. The evidence should show why the provider and exact qualified service were acceptable at onboarding and what would trigger a new review.

For ongoing monitoring, separate static onboarding evidence from time-sensitive status evidence. Trusted-list status, service scope, revocation availability, incident posture, and material provider changes can change after the initial selection.

  • Provider and service identity: legal name, country, supervisory body, trusted-list entry, service type identifier, service name, service digital identity, current status, status start time, and relevant history.
  • Certificate evidence: sample certificates, chain-validation result, policy identifiers, CP/CPS links, QCStatements review, key-usage review, QWAC or signature/seal purpose review, and revocation or validity-status test result.
  • Policy evidence: terms and conditions, relying-party obligations, subscriber obligations, permitted uses, usage limits, revocation request route, incident contact, and support or escalation terms.
  • Assurance evidence: conformity assessment scope, audit date or cycle evidence when available, remediation notes that affect the relied-on service, security and continuity summaries, supply-chain assurance, and termination-plan confirmation.
  • Monitoring triggers: trusted-list status change, certificate-policy change, service-scope change, supervisory notice, provider incident, revocation/OCSP/CRL availability failure, planned cessation, material outsourcing change, or product use-case change.
Primary sources

References and citations

enisa.europa.eu
Referenced sections
  • Supports the supervision lens for qualified trust services and the relationship between supervisory authorities, QTSPs, and conformity assessment.
"guidelines on supervision of qualified trust service providers pursuant to Art.20"
etsi.org
Referenced sections
  • Supports retaining operational assurance evidence for risk assessment, incident handling, collection of evidence, termination planning, compliance, and supplier controls.
"Collection of evidence"
etsi.org
Referenced sections
  • Supports retaining certificate policy, CPS, relying-party status-checking obligations, revocation route, audit, and trusted-list link evidence.
"Information on how to validate the certificate"
etsi.org
Referenced sections
  • Supports checking QCStatements that declare EU qualified-certificate status, certificate purpose, legal framework, and related qualified-certificate attributes.
"The qcStatements certificate extension can contain any statement by the certificate issuer"
etsi.org
Referenced sections
  • Supports retaining trusted-list status and history evidence because the list is used to determine service status at the time of reliance.
"at a given time in the past"
eur-lex.europa.eu
Referenced sections
  • Article 20 supports review of periodic audits, supervisory-body audits, remediation, withdrawal of qualified status, and trusted-list updates.
"audited at their own expense at least every 24 months"
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