NL-FS-P full text
This is the text of NL-FS-P, converted automatically from the PDF so you can read and search it here. The PDF is authoritative. Tables with merged cells can be flattened, and text inside diagrams is only in the images. The individual requirements are listed separately.
NL-FS-P
EUDI Wallet Functional Certification PID Issuance Service Conformance
RC1.0 2026-11-06
| Document reference | NL-FS-P |
|---|---|
| Version | RC1.0 |
| Status | Release Candidate |
| Date | 2026-11-06 |
| Document type | Framework document |
| Parent framework | none |
| Scheme Owner | Kingdom of the Netherlands Minister of Economic Affairs |
| Certification target | European Digital Identity Wallets and the electronic identification scheme under which they are provided |
| Primary audience | System/Scheme Owner, CABs, PID providers |
| Secondary audience | EUDI Wallet ecosystem stakeholders |
| Assurance level <identity proofing CIR 2015/1502> and <evaluation, EU Regulation 2019/881> | High/High |
| Subsidiary Documents | NL Certification System Documents |
| History of changes | History of changes | ||
|---|---|---|---|
| Version | Change | Status | Date |
| RC1.0 | First consolidated version | Release Candidate Draft | 2026-11-06 |
1 Scope
This document specifies the functional certification scope for a person identification data (PID) issuance service within the common EUDI Wallet Certification System, as well as the corresponding requirements for functional conformance. It also provides a corresponding Implementation Conformance Statement (ICS).
It identifies the documents that form the legal basis for certification, containing functional requirements applicable to PID issuance services.
This document is one of the two principal scope documents of the functional certification scheme; the other, NL-FS-W, addresses the conformance of a wallet solution. This document operates within the framework, methodology and evaluation rules defined in NL-FS.
This document is intended for conformity assessment bodies and for PID providers preparing a PID issuance service for certification.
2 Legal basis
The functional certification scope defined in this document derives from Regulation (EU) No 910/2014 as amended by Regulation (EU) 2024/1183, in particular Article 5a (European Digital Identity Wallets) and Article 5c(1) (Certification of European Digital Identity Wallets).
Further functional requirements are specified in the Commission Implementing Regulations adopted under Article 5a(23) and Article 5a(24) of this Regulation, in particular:
- Commission Implementing Regulation (EU) 2024/2979 (integrity and core functionalities of European Digital Identity Wallets),
- Commission Implementing Regulation (EU) 2024/2982 (protocols and interfaces to be supported by the European Digital Identity Wallet Framework);
- Commission Implementing Regulation (EU) 2024/2977 (person identification data and electronic attestations of attributes issued to European Digital Identity Wallets);
Under Article 5c(1), the certification scope comprises the requirements of Article 5a(4), (5) and (8) and, where applicable, the standards and technical specifications referred to in Article 5a(24).
3 Normative references
The following documents are referred to in the text in such a way that some or all of their content constitutes requirements of this document.
- (a) NL-SYS-02, EUDI Wallet Certification System - Vocabulary
- (b) NL-FS, EUDI Wallet Functional Certification Scheme
- (c) Commission Implementing Regulation (EU) 2024/2979
- (d) Commission Implementing Regulation (EU) 2024/2982
- (e) Commission Implementing Regulation (EU) 2024/2977
- (f) RFC 2119, Key words for use in RFCs to Indicate Requirement Levels, S. Bradner, March 1997
4 Terms and definitions
For the purposes of this document, the terms and definitions given in NL-SYS-02 and NL-FS apply. In particular, the terms test objective, classification, reference test method, test area, verification by inspection and Implementation Conformance Statement (ICS) are used as defined in NL-FS, and the terms person identification data (PID), PID provider, wallet unit and wallet instance are used as defined in NL-SYS-02. The definitions given in Article 2 of CIR 2024/2977 also apply.
5 Certification scope for a PID issuance service
The object of certification in scope of this document is a PID issuance service provided by a PID provider. The certification scope comprises:
- (a) the conformity of the functional behaviour of the service observable at its interface towards the wallet unit, by which person identification data is issued
- (b) the conformity of the person identification data issued by the service.
6 Requirements for functional conformance
6.1 Overview
This chapter lists the requirements of the scheme regarding the features of PID issuance services mandated in the legal instruments. These requirements for functional conformance enable modularity of the certification regarding these features. This allows a PID provider to indicate which of the legally mandated features are implemented.
This chapter categorises the conformance requirements according to the CIR in which the corresponding feature is (primarily) discussed. The rightmost column indicates the conformance level of that feature under the scheme.
Note: In this version of this document, the lists of requirements may not be fully complete. Additionally, indicated conformance levels are subject to change.
The indicated conformance levels (Optional, Recommended, Required) shall be interpreted as specified in RFC 2119. In particular, where a feature is indicated as Recommended under the scheme, it means that there may exist valid reasons in particular circumstances for a PID provider to not implement such a feature in their PID issuance service, but the PID provider shall understand and carefully weigh the full implications before doing so and shall document these considerations. During the certification process, the certification body shall request this documentation for any recommended feature that is not implemented.
Where a PID issuance service implements a feature, it shall comply with all related functional requirements in the legal basis and in the corresponding standards mentioned therein.
6.2 Requirements from CIR 2024/2979 (Integrity and core functionalities)
None.
6.3 Requirements from CIR 2024/2982 (Protocols and interfaces)
| # | Item | Primary legal references | Conformance |
|---|---|---|---|
| 1. | PID issuance service supports PID issuance using OpenID4VCI | eIDAS Article 5a(5)(a)(i) CIR 2024/2982, Article 4 and Annex I (by referencing ETSI TS 119 472-3) | Recommended |
| 2. | PID issuance service supports PID issuance using the NL-specific issuance specification | - | Required |
6.4 Requirements from CIR 2024/2977 (PID and EAA)
| # | Item | Primary legal references | Conformance |
|---|---|---|---|
| 3. | PID issuance service supports PIDs in mdoc format | CIR 2024/2977 Article 3 and Annex (4) | Required |
| 4. | PID issuance service supports PIDs in SD-JWT VC format | CIR 2024/2977 Article 3 and Annex (4) | Required |
7 Implementation Conformance Statement
7.1 ICS template
Implementations Conformance Statements (ICS) are declarations, to be completed by the developer of an object of certification, regarding the features that are supported or not supported by the object of certification. For more information on such statements within the context of the scheme, please refer to section 6.3 of NL-FS.
Annex A includes the template of an ICS for PID issuance services. Note that the declared implementation choices (Annex A.3) reflect the functional conformance requirements listed in chapter 6.
PID providers seeking functional certification of their PID issuance service shall complete this ICS.
Annex A (normative) PID issuance service ICS template
This Annex provides the template for the Implementation Conformance Statement of the wallet solution. The wallet provider completes the template and submits it as part of the application for certification. The ICS records the object of certification and the declared implementation choices.
A.1 Identification of the object of certification
| Item | Declaration |
|---|---|
| PID issuance service name | |
| Version |
A.2 Identification of PID provider
| Item | Declaration |
|---|---|
| PID provider name | |
| PID provider full address | |
| Contact person name, title | |
| Contact phone number | |
| Contact e-mail address |
A.3 Declared implementation choices
The PID provider shall declare, using the tables below, whether the PID issuance service implements the mentioned features from the cited legal instruments.
Note: Although the contents of a PID are specified in CIR 2024/2977, the PID Provider does not declare in this ICS which of the optional PID attributes and metadata it supports. Instead, the PID Provider shall declare this using an ICS that is part of the test case specification for PID contents. For more information, see the discussion on Implementation Conformance Statements in section 6.3 of NL-FS.
A.3.1 Regarding CIR 2024/2979 (Integrity and core functionalities)
None.
A.3.2 Regarding CIR 2024/2982 (Protocols and interfaces)
| # | Item | Primary legal references | Declaration (Yes / No) |
|---|---|---|---|
| 1. | PID issuance service supports PID issuance using OpenID4VCI | eIDAS Article 5a(5)(a)(i) CIR 2024/2982, Article 4 and Annex I (by |
| referencing ETSI TS 119 472-3) | ||
|---|---|---|
| 2. | PID issuance service supports PID issuance using the NL-specific issuance specification | - |
A.3.3 Regarding CIR 2024/2977 (PID and EAA)
| # | Item | Primary legal references | Declaration (Yes / No) |
|---|---|---|---|
| 1. | PID issuance service supports PIDs in mdoc format | CIR 2024/2977 Annex section 4 | |
| 2. | PID issuance service supports PIDs in SD-JWT VC format | CIR 2024/2977 Annex section 4 |