Digital Identity- CSC’s Statement on the Draft Legislation Complementing Regulation (EU) 2024/1183 on European Digital Identity
The Ministry of Finance requested statements on a draft legislative proposal to complement Regulation (EU) 2024/1183 of the European Parliament and of the Council, which amends Regulation (EU) No 910/2014 to strengthen the framework for European digital identity. While the regulation is directly applicable in member states, it also requires national legislation to implement specific obligations, such as providing a digital identity wallet by December 2026, and designating a supervisory authority and national contact point. The proposal includes launching a police-issued digital ID as the first compatible credential and introduces updates to improve the security and usability of electronic identification. Additionally, a national ecosystem description outlines the roles, tasks, and benefits related to the wallet’s deployment, aiming to ensure secure, reliable, and cross-border digital identity solutions for citizens and service providers.
In its statement, CSC emphasises how cross-border electronic identification, trust services, and the European digital identity framework are crucial for Finland’s education and research sectors, especially given the large number of international students and researchers. CSC, a state-owned non-profit expert organization, emphasizes the importance of secure and interoperable digital identity systems to support mobility, data protection, and service access. The proposed national legislation complements the EU’s eIDAS regulation and is well-structured, but concerns remain about whether sufficient resources have been allocated for implementation and ecosystem development. Reliable initial identification, especially for individuals without Finnish credentials, is a major challenge, and the adoption of the EU Digital Identity Wallet (eudi-wallet) could significantly ease this burden. CSC also highlights the need for a robust trust model, improved interoperability, and alignment with the European Interoperability Framework to ensure seamless, secure, and meaningful use of digital identities across borders, particularly in research and innovation infrastructures.
CSC emphasizes that the digital identity wallet must be user-centric and interoperable in line with the European Interoperability Framework. Reliable and flexible identification is essential for shared infrastructures such as research networks and cloud-based services, especially for individuals from outside the EU and EEA. For higher education and scientific collaboration, it is crucial to enable high-assurance registration procedures for these users to ensure secure access and smooth participation in digital services across borders.
CSC emphasizes that the national ecosystem for the EU Digital Identity Wallet (eudi-wallet) must be flexible and user-friendly to ensure widespread adoption across Europe by the 2026 deadline. While a general-purpose wallet would maximize interoperability, multiple domain-specific wallets (e.g. for education, research, or public services) could be more intuitive for users—but risk fragmentation and reduced compatibility. CSC stresses the need for a balanced trust model that avoids overly rigid registration requirements for service providers, which could hinder ecosystem growth. Drawing from decades of experience with identity federations in research networks, CSC advocates for a more adaptable trust framework, such as OpenID Federation, which better suits the dynamic needs of higher education and scientific collaboration than a strictly centralized model.
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- The whole statement (pdf) (in Finnish)
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