WorkflowEU

eIDAS trust service role scoping workflow

Use this workflow to classify whether an organization is acting as a trust service provider, qualified trust service provider, signature or seal validator, EUDI Wallet relying party, general relying party, or customer of a QTSP.

The workflow starts with the service actually provided, checks whether qualified status is claimed or listed, and separates organizations that rely on a trust service from those that provide one.

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

eIDAS role scoping is easy to get wrong because the same product journey can include several actors: a QTSP issuing a qualified certificate, a software product validating a signature, a business relying on the result, and a customer buying the service. This workflow classifies the role from observable evidence instead of job titles or vendor labels.

Section 1

Start with what the organization does in the transaction

Classify the role by the activity performed for another party. Under eIDAS, a trust service includes services such as issuing or validating certificates, creating or validating electronic signatures or seals, preserving signatures or seals, managing remote signature or seal creation devices, issuing or validating electronic attestations of attributes, timestamping, registered delivery, electronic archiving, and electronic ledgers.

A relying party is different: it relies on electronic identification, an EUDI Wallet, another electronic identification means, or a trust service. A relying party may be a bank, platform, employer, public body, marketplace, or internal business unit that consumes identity, attestation, certificate, signature, seal, or validation results.

  • Classify as a trust service provider when the organization provides one or more trust services as a service, whether qualified or non-qualified.
  • Classify as a general relying party when the organization consumes an eID, wallet presentation, certificate, signature, seal, attestation, timestamp, delivery proof, or validation result to make a business or legal decision.
  • Classify as a QTSP customer when the organization contracts with a qualified trust service provider but does not itself provide the qualified trust service to others.
  • Escalate mixed cases: a platform can be a relying party for customer onboarding and also a trust service provider if it separately offers validation, timestamping, certificate, seal, preservation, or registered delivery services to customers.
Section 2

Decide whether the organization is a TSP or QTSP

A trust service provider is the actor that provides one or more trust services. A qualified trust service provider is narrower: it provides one or more qualified trust services and has been granted qualified status by the supervisory body.

Do not treat marketing language, a procurement checklist, or use of a QTSP supplier as proof of qualified status. eIDAS ties qualified status to supervisory verification and trusted-list indication. A provider may begin providing the qualified trust service only after qualified status is indicated in the trusted lists.

  • TSP evidence: service description, customer terms, APIs, certificates, validation outputs, timestamping outputs, registered delivery proofs, preservation records, attestation issuance, or other trust-service outputs provided to another party.
  • QTSP evidence: supervisory-body grant of qualified status, the specific qualified service listed in the relevant trusted list, and website use of the EU trust mark with a link to the relevant trusted list when the mark is used.
  • Not enough for QTSP status: using a QTSP as a vendor, reselling a QTSP-backed workflow without providing the qualified trust service, or validating a document only for internal reliance.
  • Reopen the classification when the organization adds a new trust-service feature, changes from internal validation to customer-facing validation, claims qualified status, changes QTSP supplier, or changes the listed service type.
Section 3

Separate validation service, validation software, and relying-party validation

Signature or seal validation is not one role. The organization may provide a qualified validation service, provide non-qualified validation software or API services, or only validate a signature or seal for its own reliance.

For qualified electronic signatures, eIDAS validation checks include whether the supporting certificate was qualified and issued by a QTSP, whether it was valid at signing time, whether signature validation data corresponds to the relying-party data, whether the signatory data and any pseudonym indication are correctly provided, whether the signature was created by a qualified creation device, and whether signed-data integrity is intact.

  • Classify as a qualified validation service provider only when the validation service is provided by a QTSP and returns validation results in the manner required for qualified validation services.
  • Classify as a non-qualified trust service provider when the organization offers validation of signatures, seals, certificates, timestamps, attestations, or delivery evidence as a service but does not hold qualified status for that service.
  • Classify as a relying party when the organization only checks a signature, seal, certificate, attestation, or validation report to decide whether to accept a transaction.
  • Keep evidence of the validation policy, the certificate path and trust-list checks used, the validation result delivered to the relying party, and the reason the activity is internal reliance or customer-facing service provision.
Section 4

Classify EUDI Wallet relying-party activity separately

A wallet relying party is an organization that intends to rely on EUDI Wallets to provide public or private services by digital interaction. eIDAS Article 5b requires that relying party to register in the Member State where it is established and provide registration information, contact details, and the intended wallet use including the data it will request from users.

This role is separate from QTSP status. A wallet relying party requests or verifies wallet-presented data; it is not automatically a QTSP, a wallet provider, a PID provider, or an attestation provider.

  • Wallet relying-party evidence: service journey uses an EUDI Wallet, the organization requests wallet data from users, and the requested attributes are tied to the stated use case.
  • Registration evidence: Member State of establishment, official name or registration number, contact details, intended wallet use, and data requested from users.
  • Operational evidence: user-facing identification of the relying party, authentication and validation procedures for PID or EAA data, and controls preventing requests for data beyond the registered purpose.
  • Privacy and risk evidence: how the organization limits requested attributes, handles pseudonyms where identification is not legally required, and discards unique attestation elements when no longer needed for the relying-party purpose.
Section 5

Use this output record before assigning obligations

The workflow output should be a role-scoping record that separates each transaction role before assigning controls, contracts, or regulatory owners. One legal entity can have more than one row if it performs different activities in different products or countries.

Keep the record specific enough that a reviewer can see why the organization is a provider, qualified provider, relying party, wallet relying party, validator, or QTSP customer without reading internal project history.

  • Activity: the exact service, API, workflow, or transaction step being classified.
  • Counterparty: user, customer, relying party, QTSP, wallet provider, attestation provider, PID provider, supervisory body, or internal business unit.
  • Role finding: TSP, QTSP, qualified validation service provider, non-qualified validation provider, general relying party, wallet relying party, or QTSP customer.
  • Evidence: trusted-list entry, supervisory status, contract with QTSP, validation report, wallet registration information, service terms, user journey, certificate or attestation type, and validation policy.
  • Boundary note: why adjacent roles do not apply, such as using a QTSP supplier without providing the qualified service, or validating internally without offering validation as a service.
  • Reassessment trigger: new customer-facing trust-service feature, qualified-status claim, trusted-list status change, wallet data request change, new country of establishment, or supplier change affecting the trust-service chain.
Recommended next step

Turn the role finding into an evidence-backed eIDAS work record

Sorena can help turn this role-scoping workflow into a sourced record that separates provider, QTSP, validator, relying-party, wallet relying-party, and QTSP-customer obligations for a specific product or supplier chain.

Primary sources

References and citations

etsi.org
Referenced sections
  • Describes how trusted-list information can be used as trust-anchor input in certificate path and signature validation.
"Trusted Lists"
ec.europa.eu
Referenced sections
  • Explains service-provider wallet use, registration information, wallet data requests, and operational obligations for requesting data from wallet users.
"request data from an EU Digital Identity Wallet"
eur-lex.europa.eu
Referenced sections
  • Supports the role distinctions between relying party, trust service provider, qualified trust service provider, trusted-list status, and validation services.
"trust service provider"
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