Memo
The Danish Government’s response to the public consultation on
the eIDAS review
The Danish Government welcomes the public consultation on the eIDAS review
and agrees with the Commission’s assessment that the existing eIDAS framework
needs to be revised to achieve the policy objectives of the Regulation.
General remarks
24 September 2020
The Danish Government considers the Regulation of Electronic Identities and
Trust Services (eIDAS) as a prerequisite for the digital transformation and for the
strengthening of the EU’s digital single market. The COVID-19 pandemic has un-
derlined the importance of citizens and businesses having the ability to perform
their daily tasks digitally. It is paramount that the continued European digitisation
serves the interests of society in a safe, trustworthy and predictable way while con-
tributing to the green economy as well.
Thus, the Danish Government believes that quality, safety and predictability should
be guiding principles in the forthcoming revision of the eIDAS Regulation. These
principles should be adhered to:
Increased focus on the interdependencies between the eIDAS Regulation and
other relevant legislation,
Clearer rules and assessment parameters, maintaining the Regulation’s technol-
ogy-neutral and framework-setting nature for electronic identities and trust ser-
vices, and
A focus on future-proofing the Regulation.
The Danish Government calls on the Commission to adopt a holistic view across
relevant EU legislation. Although the eIDAS Regulation is the primary regulation
for electronic identities and trust services, other pieces of EU legislation are closely
related, e.g. the GDPR, NIS, PSD2 and the EIF. Moreover, Denmark calls on the
Commission to take into account the current considerations of a European Social
Security Number (ESSN) in this regard. Additionally, the revision must be regarded
in the context of the implementation of the Single Digital Gateway. Denmark en-
courages the Commission to work to reuse language, definitions and align associ-
ated guidelines and instructions in these packages of legislation. For instance, the
time limit for safety notifications is 24 hours according to the eIDAS regulation but
72 hours according to the GDPR.