EUU, Alm.del - 2024-25 - Bilag 597: Notat samt høringssvar vedr. europæisk virksomhedstegnebog

Europaudvalget 2024-25
EUU Alm.del Bilag 597
Offentligt

The

Danish Government’s

response to the Commission's call for evi-

dence for an impact assessment on the European Business Wallet

Denmark welcomes the Commission’s initiative and shares

its ambition to reduce

administrative burdens, enhance competitiveness, simplify regulatory processes,

and advance the digital transition across the EU. These objectives are closely

aligned with Danish digital policy priorities. With extensive experience in digital iden-

tity systems and broader digital transformation efforts across both the public and

private sectors, Denmark sees the European Business Wallet (EBW) as a potentially

transformative instrument

–

provided it is implemented with flexibility, caution, and in

alignment with existing national and European digital infrastructures.

Denmark encourage the Commission to introduce a “wallet-by-default”-principle

ensure that the wallet-infrastructure is used in all relevant use-cases where there is

value-added and demand.

To ensure the EBW delivers real value without unintended negative consequences,

Denmark recommends the following:

Address existing infrastructure gaps first:

Rather than introducing new

requirements prematurely, existing challenges should be resolved. In this

context, Denmark recommends removing legal persons from the eIDAS2

regulation, as these should instead be addressed comprehensively within

the EBW initiative, which is better suited to accommodate the needs.

Minimise mandatory implementation burdens:

Requirements for Mem-

ber States should be clearly defined, gradual and limited. Obligations should

not be imposed on all public sector entities, but targeted on use-cases where

the added value is clearly demonstrated.

Build on existing frameworks:

Leverage the eIDAS2 building blocks to

create synergies, reduce duplication, and support coherent development

across Member States, and ensure interoperability with other European dig-

ital infrastructures.

A strategic enabler for simplification and competitiveness

Denmark sees the EBW as a potential horizontal enabler of the Commission’s simplifi-

cation agenda

–

supporting businesses in managing national and cross-border compli-

ance, reporting, and notification requirements through a single digital interface. We

share the Commission’s objectives of rationalising and simplifying

the regulatory envi-

ronment, with the aim of reducing administrative burdens by 25%, and acknowledges

the fact that the EWB has potential to contribute significantly towards this aim.

We strongly believe that strengthening the EU’s digital competitiveness requires a more

integrated Single Market, fewer regulatory hurdles, increased investment, and im-

proved conditions for innovation. If implemented correctly, the EBW can contribute

meaningfully to this agenda.

1 July 2025

EUU, Alm.del - 2024-25 - Bilag 597: Notat samt høringssvar vedr. europæisk virksomhedstegnebog

With this in mind, Denmark reiterates its

call for a “wallet-by-default”-principle,

ensuring

that both the EUDI Wallet and Business Wallets are widely used for authentication pur-

poses in EU legislation. This principle should also be a key element in the upcoming

Digital Package.

Fundamental principles for a successful EBW

Denmark fully supports the overarching objective of reducing administrative burdens.

In this regard we would like to raise some concerns regarding the process, scope, and

the potential for overlap with existing initiatives. In particular, it is important to avoid

introducing new administrative obligations

–

whether for businesses or Member States

–

as this would contradict

the initiative’s aim.

Compliance requirements should be kept

as light as possible.

Rather than prescribing fixed implementation models, the EBW should primarily provide

a flexible framework for technical standards, specifications, and governance that sup-

ports innovation and voluntary uptake.

We also believe the EBW should be both use case-driven and responsive to actual

demand. To this end, the Commission is encouraged to develop a dedicated use case

strategy for the Business Wallet that highlights and promotes applications with strong

potential to reduce administrative burdens for businesses. This strategy should take

into account the time needed to establish the necessary infrastructure and technical

specifications and technical foundations, and explore how the Business Wallet can help

streamline compliance with selected EU reporting obligations and other regulatory re-

quirements.

The importance of national flexibility and compatibility

It is crucial that the initiative delivers tangible, practical benefits for both businesses and

public authorities. A

one-size-fits-all

approach risks undermining well-functioning na-

tional solutions and introducing new burdens that outweigh potential benefits. Flexibility

must be a guiding principle, ensuring compatibility with national best practices, and ex-

isting national infrastructures, allowing for diverse implementation models.

For example, in Denmark, all businesses and associations with a CVR number use

Digital Post to receive official communications from public authorities. Moreover, MitID

Erhverv (the Danish eID solution for businesses) serves over 326,000 connected user

organizations and has more than 1.3 million active users. Among these users, 88%

express trust in the solution, and 89% find it secure to use. This demonstrates a high

level of adoption and confidence in such digital solutions in Denmark, which must be

preserved and respected.

In this context, Denmark stresses that harmonisation at the EU level must not come at

the expense of effective national solutions. As a country with a long-standing tradition

in digital government and regulatory simplification, we strongly advocate for maintaining

flexibility and recognising existing best practices that have proven successful.

Respecting varying levels of digital maturity

The EBW must reflect the diverse levels of digital maturity across Member States. In

many cases, a small number of digital self-service solutions handle the vast majority of

business interactions and offer the greatest value from further digitisation.

EUU, Alm.del - 2024-25 - Bilag 597: Notat samt høringssvar vedr. europæisk virksomhedstegnebog

It would be disproportionate to mandate that Member States must accept all data for-

mats compatible with the EBW or require them to communicate solely through the wal-

let infrastructure

–

without assessing feasibility and added value.

The success of the EBW relies on a strong digital infrastructure. While digital authenti-

cation and document exchange are important components, they are not sufficient on

their own. For the EBW to deliver real value, Member States must first digitise their

underlying registries, databases, and administrative processes. Without this foundation,

the EBW will lack the essential services and relevant digital data needed for effective

exchange. Consequently, the goal of achieving a truly paperless business administra-

tion will remain out of reach.

Leverage existing initiatives to maximise impact and minimise redundancy

To ensure the EBW complements, not duplicates, existing initiatives, Denmark recom-

mends a fit/gap analysis of the EUDI Wallet framework. This analysis should identify

reusable components, pinpoint where business-specific adaptations are necessary,

and consider transferring relevant elements from the eIDAS2 regulation to the EBW

(inspired by omnibus packages).

With the EBW, we question whether there is still a need for the Once-Only Technical

System (OOTS) under the Single Digital Gateway. We urge the Commission to exam-

ine whether use cases and interactions currently covered by the OOTS could be more

effectively supported through the EWB framework, which may ultimately render parts

of the OOTS redundant or obsolete.

Moreover, Denmark supports integrating a unique cross-European business identifier

and harmonised Power of Attorney solutions within the EBW regulation. These ele-

ments are aligned with the eIDAS2 framework and has the potential to improve cross-

border business operations significantly.

The EBW must not delay or complicate the implementation of eIDAS2, which is already

a major undertaking for Member States. Denmark emphasises the importance of en-

suring sufficient implementation capacity to implement eIDAS2 effectively and to avoid

regulatory overload.

The EBW should establish a flexible framework based on common technical standards

that enables and encourages voluntary, market-driven, and innovative EBW solutions

developed by the private sector. These solutions could support, for example, cross-

border payments or secure exchange of business documents such as eInvoices within

trusted data ecosystems.

Any future requirements should take into account the maturity and uptake of such so-

lutions.

It should therefore be made clear that Member States will not be responsible for provid-

ing Business Wallets. Their development should instead be led by market dynamics,

allowing private actors to innovate, compete, and adapt to the evolving needs of busi-

nesses. This approach will foster a diverse ecosystem of solutions, promote efficiency,

and ensure that Business Wallets are tailored to actual market demands.

EUU, Alm.del - 2024-25 - Bilag 597: Notat samt høringssvar vedr. europæisk virksomhedstegnebog

In this context, we also advocate for a gradual implementation of the EBW, consistent

with this market-driven model.

Call for an adequate impact assessment

Denmark notes with concern that the Commission does not plan to carry out a full im-

pact assessment for the EBW regulation. Given the legal and operational complexity of

the initiative, this is problematic. Any regulation

–

especially one extending or adapting

the eIDAS2 framework

–

must be thoroughly evaluated for its administrative implica-

tions and regulatory burdens.

The 2021 eIDAS2 impact assessment does not adequately cover the challenges intro-

duced by the EBW, particularly given the shift in subject from natural to legal persons.

Conclusion: A call for proportional, flexible and coordinated implementation

In essence, Denmark fully supports the EBW as an initiative serving to be a horizontal

enabler for the Commission’s simplification agenda,

while the initiative, if implemented

correctly and with caution, is foreseen to have the capacity to unlock the full potential of

the digital Single Market. The regulation should be seen as an opportunity to limit and

recalibrate burdens introduced by eIDAS2, not expand them. It must avoid overlapping

obligations, ensure national flexibility, and support well-established systems already in

place, and support secure identification for business-to-business interactions.

Denmark remains committed to engaging in constructive dialogue and sharing its ex-

periences and best practices. Please find attached a technical annex with input and

questions for further clarification.

We look forward to continued dialogue with the Commission and other Member States

on shaping a solution that brings genuine benefits to Europe’s businesses and admin-

istrations alike.

EUU, Alm.del - 2024-25 - Bilag 597: Notat samt høringssvar vedr. europæisk virksomhedstegnebog

Annex: Main concerns, recommendations and clarifying questions

The Danish Agency for Digital Government oversees the national eID solution (MitID),

the eID for businesses (MitID Erhverv), and Denmark’s work with the European Digital

Identity Wallet (EUDI Wallet). MitID Erhverv is mandatory for all Danish companies and

public authorities and has effectively streamlined public-private digital interactions.

Given the maturity of Denmark’s current infrastructure, it is crucial that any new EU

regulation, including the EBW, provides tangible added value and does not impose dis-

proportionate obligations.

Key Recommendations

Based on our experience with digital identity frameworks, we present three key recom-

mendations. Our response draws on extensive experience with digital identity systems

and digital transformation within both the public and private sectors.

1. Address existing gaps before imposing new requirements (Remove legal

person wallets from eIDAS2)

Quote from the Call for Evidence:

“The European

Business Wallet initiative will expand the European Digital Identity

Framework to economic operators and public administrations.”

Concern

Member States are already required under eIDAS2 to support wallets for legal persons

and for natural persons representing legal persons. However, implementation guid-

ance, technical specifications, and legal frameworks for legal person wallets are still

lacking. So far, development efforts have focused almost exclusively on wallets for nat-

ural persons.

It is unclear how

the proposed EBW “expands” the framework in eIDAS2 or how it would

interact with, replace, or supplement existing obligations. This creates confusion and

raises the risk of duplicated efforts.

Recommendation

Rather than introducing overlapping obligations, the EBW regulation should serve as

an opportunity to streamline and clarify responsibilities. Specifically:

•

eIDAS2 should be amended so that Member States are only obliged to support

wallets for natural persons (including those representing legal persons).

The Business Wallet should be positioned as a voluntary, market-driven tool

–

not a parallel mandatory system.

•

This approach would reduce implementation burdens and align regulatory expec-

tations with the current level of maturity across Member States.

EUU, Alm.del - 2024-25 - Bilag 597: Notat samt høringssvar vedr. europæisk virksomhedstegnebog

2. Minimize and clearly describe mandatory implementation burdens

Quotes from the Call for Evidence:

“The Business Wallet will be a tool to facilitate B2G, B2B and G2G interactions.”

“Imposing specific obligations on Member States and public administrations…”

“Accepting data in all formats compatible with the Business Wallet…”

Concern

The EBW is described ambiguously as both an "identity infrastructure" and a "tool,"

without clarifying whether it refers to an application, architecture, technical standard, or

policy framework. This ambiguity makes it difficult to assess how the EBW comple-

ments or differs from the EUDI Wallet or existing national systems like MitID Erhverv.

Moreover, some proposed obligations

–

for example, accepting data in all compatible

formats

–

are overly broad and vague. Without a clearer scope, such requirements risk

becoming disproportionately burdensome for Member States, especially those that al-

ready operate successful digital systems or those with limited digital maturity.

The broad promise of EBW enabling B2B, B2G, and G2G data exchanges goes far

beyond the current scope of eIDAS2 and implies substantial infrastructure and process

redesign across the EU.

Recommendations

•

Define who will develop and operate the Business Wallet, including responsi-

bilities for development, maintenance, funding, liability, and operational over-

sight.

Clearly specify any required actions from Member States and ensure they are

proportionate, targeted, and context-sensitive.

Frame the EBW as a flexible, standards-based framework that Member States

and the private sector can adopt when there is clear demand and added value.

Acknowledge that only a limited set of services may benefit from cross-border

digital solutions; not all interactions merit inclusion under a broad EBW man-

date.

•

3. Build upon existing frameworks to create synergies and value (Reuse eI-

DAS2 building blocks)

Quote from the Call for Evidence:

“The EBW will provide a single, secure, interoperable

cloud-based identity solution...

deploying AI and advanced analytics to reduce manual processing.”

Concern

Framing the EBW as a separate “cloud-based identity solution” risks creating a parallel

system that duplicates the work and standards already established under eIDAS2.

Without alignment, this could lead to fragmentation, interoperability issues, and greater

costs for businesses and public administrations.

EUU, Alm.del - 2024-25 - Bilag 597: Notat samt høringssvar vedr. europæisk virksomhedstegnebog

Recommendation

•

Build on the technical architecture and trust service models established under

eIDAS2.

Identify which business-specific requirements truly fall outside the current eI-

DAS2 scope and adapt the framework only where necessary.

Reduce certification and privacy requirements where justified by the lower sen-

sitivity of business use cases.

Promote adoption of common identifiers, such as a unique business ID and

harmonised Power of Attorney models, across all Member States using exist-

ing building blocks.

•

4. Outstanding questions for clarification

To ensure that the EBW regulation is fit-for-purpose and proportionate, we kindly ask

the Commission to clarify:

1. Who will provide and operate the EBW? Will it be a single EU-provided tool or

market-based? Who will ensure operational continuity, governance, and fund-

ing?

What formats are considered “compatible”? What technical obligations follow

from the requirement to “accept data” in these formats?

3. How will the regulation account for Member States that already have mature

systems, like MitID Erhverv? What steps will be taken to avoid disrupting

functioning solutions?

4. How will the EBW be designed to accommodate Member States with less de-

veloped infrastructure, including registries and administrative processes es-

sential to digital transactions?

Who will be required to use the “secure and legally recognized channels,”

and for what types of interactions? What legal implications follow from these

requirements?

How will the Commission ensure that the impact assessment is methodologi-

cally sound and reflects realistic cost-benefit scenarios across different Mem-

ber States?

Claims such as the €2 trillion in annual losses due to reporting re-

quirements must be substantiated with clear evidence.