WorkflowEU

eIDAS trust service role scoping workflow

This workflow helps classify whether an organization is acting as a , , signature or seal validator, EUDI , general , 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
Jul 24, 2026
Overview

Classify each legal person separately for each service it provides or relies on. The role belongs to the legal person responsible for providing the trust service, not automatically to its customer or software supplier. Buying QTSP services does not make the customer a QTSP, and using validation software internally does not by itself make the user a validation-service provider. A single organisation can still hold several roles across different products or transaction steps. This workflow uses the activity, counterparty, contractual responsibility, output, and trusted-list status to separate those roles.

Section 1

Start with what the organization does in the transaction

Classify the role by the activity performed and the legal person responsible for it. Under eIDAS, a trust service is an electronic service normally provided for remuneration and includes issuing certificates, creating or validating electronic signatures or seals, preserving signatures, seals, or related certificates, managing remote creation devices, issuing or validating electronic attestations of attributes, creating or validating timestamps, registered delivery and related validation, electronic archiving, and recording data in an electronic ledger.

A is a natural or legal person that relies on electronic identification, an EUDI Wallet, another electronic identification means, or a trust service. A bank, platform, employer, public body, or marketplace can be the relying party; an internal team may operate the process, but the role belongs to the relevant natural or legal person.

  • Classify as a when the organization is responsible for providing one or more eIDAS trust services to another party, whether qualified or non-qualified. Supplying generic software or using a trust function only inside the same legal person does not automatically satisfy that test.
  • Classify as a general 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 but does not itself provide the qualified trust service to others.
  • Escalate mixed cases: a platform can be a for customer onboarding and also a 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 is the actor that provides one or more trust services. A 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 can describe different activities. The organization may provide a , provide a non-qualified validation service, supply software that a customer operates under its own responsibility, or validate a signature or seal only for its own reliance. Classify the service provider from who performs and is responsible for the validation, not from whose software library is present.

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 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- when the organization itself provides validation of signatures or seals as a service but does not hold qualified status for that service. For certificate, timestamp, attestation, or registered-delivery validation, confirm that the activity falls within the amended Article 3 trust-service list before assigning the role.
  • Classify as a 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 , and the reason the activity is internal reliance or customer-facing service provision.
Section 4

Classify EUDI Wallet relying-party activity separately

A is a that intends to use wallet units to provide public or private services by digital interaction. Article 5b requires registration in the Member State of establishment and disclosure of authentication information, contact details, and intended wallet use, including the data to be requested.

Commission Implementing Regulation (EU) 2025/848 adds the harmonised national-register, entitlement, access-certificate, registration-certificate, suspension, and cancellation rules. It is in force but applies from 24 December 2026. Commission Implementing Regulation (EU) 2026/1730, adopted on 15 July 2026 and entering into force on 11 August 2026, amends those rules to require Member States to authorise at least one registration-certificate authority and require automated issuance without undue delay after registration. Until 24 December 2026, distinguish preparation under Article 5b from completion of a registration under the applicable national process.

This role is separate from QTSP status. A 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 , 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

Review 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, , , validator, or QTSP customer without reading internal project history.

  • Activity: the exact service, API, workflow, or transaction step being classified.
  • Counterparty: user, customer, , QTSP, wallet provider, attestation provider, PID provider, supervisory body, or internal business unit.
  • Role finding: TSP, QTSP, provider, non-qualified validation provider, general , , 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

portal.etsi.org3 citations
Referenced sections
  • Explains trusted lists, QTSP status evidence, conformity-assessment context, and trust-service provider categories under eIDAS.
  • Explains that EU trusted lists identify qualified trust service providers and their qualified trust services, and that users rely on trusted-list status for qualified-service legal effect.
  • Supports the evidence requirement to check trusted lists and service status rather than relying only on provider claims.
"Trusted Lists"
More quoted passages
"qualified status"
eur-lex.europa.eu3 citations
Referenced sections
  • Defines trust service provider and qualified trust service provider, and sets the qualified-status and trusted-list mechanics.
  • Sets requirements for validating qualified electronic signatures and for qualified validation services.
  • Supports the role distinctions between relying party, trust service provider, qualified trust service provider, trusted-list status, and validation services.
"qualified trust service provider"
More quoted passages
"validation of qualified electronic signatures"
"trust service provider"
eur-lex.europa.eu3 citations
Referenced sections
  • Defines relying party, trust service, trust service provider, qualified trust service provider, qualified-status mechanics, wallets, trusted lists, and validation requirements.
  • Article 3 defines relying party, trust service, trust service provider, qualified trust service, and qualified trust service provider, including the wallet and eIDAS 2.0 trust-service additions.
  • Article 5b sets the wallet relying-party registration, request-scope, identification, validation, pseudonym, change-notification, and intermediary rules.
"trust service provider"
More quoted passages
"normally provided for remuneration"
"Where a relying party intends to rely upon European Digital Identity Wallets"
eur-lex.europa.eu2 citations
Referenced sections
  • Binding wallet-relying-party registration rules, including national registers, entitlements, access certificates, registration certificates, suspension, and cancellation; applicable from 24 December 2026.
  • Sets the wallet-relying-party registration mechanics and applies from 24 December 2026.
"It shall apply from the 24 December 2026."
eur-lex.europa.eu2 citations
Referenced sections
  • Adopted amendment requiring registration-certificate authorities and automated issuance; it enters into force on 11 August 2026, before Regulation (EU) 2025/848 applies.
  • Amends the future 2025/848 rules to require registration-certificate authorities and automated issuance; it enters into force on 11 August 2026.
"issue wallet-relying party registration certificates in an automated manner and without undue delay after the registration"
More quoted passages
"Member States shall authorise at least one certificate authority to issue wallet relying party registration certificates."
etsi.org2 citations
Referenced sections
  • Supports the validation evidence guidance for using trusted-list information in certificate path and signature validation.
  • Describes how trusted-list information can be used as trust-anchor input in certificate path and signature validation.
"Trusted Lists"
eu-digital-identity-wallet.github.io2 citations
Referenced sections
  • Provides wallet ecosystem role definitions and technical context for relying parties, relying-party instances, attribute requests, and linkability risk.
  • Describes EUDI Wallet ecosystem roles, relying-party registration certificates, attribute-request checks, and privacy risks such as relying-party linkability.
"Relying Party"
ec.europa.eu2 citations
Referenced sections
  • Explains how organizations request data from wallet users and the registration and operational obligations for wallet service providers.
  • 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"

eIDAS 2 deadlines and compliance calendar for EUDI Wallet and trust services

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eIDAS 2.0 vs eIDAS: EUDI Wallet and trust-service changes

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