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NL-P-01

NL EUDI Wallet Certification System

Organisational and Security Requirements for Wallet and PID Providers

RC1.0

2026.11.01

Document referenceNL-P-01
VersionRC1.0
StatusRelease Candidate Draft
Date01/11/2026
Document typeCommon requirements specification for Wallet Providers and PID Providers
Parent frameworkNL-SYS-01 NL-P-P/W
Scheme OwnerKingdom of the Netherlands Minister of Economic Affairs
Certification targetWallet Providers and PID Providers under the NL EUDI Wallet Certification System
Primary audienceWallet Providers, PID Providers, CABs and Scheme Owners
Secondary audienceSupervisory bodies, accreditation bodies and EUDI Wallet ecosystem stakeholders
Assurance level <identity proofing CIR 2015/1502> and <evaluation, EU Regulation 2019/881>High/High
Related DocumentsNL-P-02 NL-P-03 NL-P-P/W04*
VersionStateDate
RC1.0Consolidated provider requirements aligned to ETSI EN 319 401 V3.2.1 and the NL EUDI Wallet Certification System.Release Candidate2026-10-31

1 Introduction​

1.1 Foreword​

This document (NL-P-01) specifies common organisational, technical, operational, security and resilience requirements for Wallet Providers and PID Providers participating in the NL EUDI Wallet Certification Scheme ("Stelsel").

The structure of the provider requirements follows ETSI EN 319 401 V3.2.1. References in that standard to a Trust Service Provider or trust service have been adapted to the relevant Wallet Provider, PID Provider and provider service context. This document does not claim that Wallet Providers or PID Providers are trust service providers solely because this structure is used.

This document shall be read with NL-SYS-01 and the applicable provider certification scheme, NL-P-W for Wallet Providers or NL-P-P for PID Providers.

Role-specific lifecycle and fraud-management requirements remain in NL-P-W04* and NL-P-P04*. Productfunctional and product-cybersecurity requirements remain in NL-FS and NL-CS.

1.2 Scope​

The document uses the control structure of ETSI EN 319 401 V3.2.1, adapted to the EUDI Wallet Provider and PID Provider context. Other NL-P*-requirement documents contain more specific requirements that apply in addition to this requirements document.

The certified scope includes the provider organisation and the people, processes, information, infrastructure, cloud and hosting services, cryptographic services, interfaces, suppliers and operational controls used to provide wallet or PID services.

For the Wallet Provider, this includes wallet onboarding, activation and wallet-unit lifecycle operations.

For the PID Provider, it includes identity proofing, PID issuance, binding, status, suspension, revocation and lifecycle operations.

In the NL-SYS-01 NL Certification System Framework, certification of Wallet Providers and certification of the PID Provider are separate subordinate certifications. For a Wallet Provider, these certificates form part of the assurance evidence used for the top-level certification and national admission decision. This document does not define that top-level certification decision, admission conditions, product-functional certification or wallet-solution cybersecurity certification.

This document lists the common organisational, policy, security, operational and resilience requirements to be met by an EUDI Wallet Provider and a PID Provider seeking and maintaining certification under the NL EUDI Wallet Certification System. The requirements constitute subsidiary normative requirements for the Wallet Provider Certification Scheme (NL-P-W) and the PID Provider Certification Scheme (NL-P-P).

2 Legal Basis & References​

2.1 Legal Basis​

The legal basis for these requirements is formed by the Union and applicable national legislation governing European Digital Identity Wallets, electronic identification, cybersecurity risk management and incident reporting.

The following instruments are particularly relevant:

  • Regulation (EU) No 910/2014, as amended by Regulation (EU) 2024/1183, establishing the European Digital Identity Framework.
  • Commission Implementing Regulation (EU) 2024/2982 on protocols and interfaces supported by the European Digital Identity Framework.
  • Commission Implementing Regulation (EU) 2024/2979 on integrity and core functionalities of European Digital Identity Wallets.
  • Commission Implementing Regulation (EU) 2024/2977 on person identification data and electronic attestations of attributes.
  • Commission Implementing Regulation (EU) 2024/2981 on the certification of European Digital Identity Wallets
  • Commission Implementing Regulation (EU) 2024/2690, where the provider or certified service falls within its scope or where its technical and methodological requirements are adopted by the applicable national framework.
  • Commission Implementing Regulation (EU) 2015/1502 concerning assurance levels for electronic identification means, including assurance level High.

Where national transposition or sector-specific rules impose more specific or stricter requirements, those requirements prevail. The applicant shall identify the competent authority, applicable reporting obligations and any sector-specific cybersecurity requirements relevant to its certified services.

2.2 Normative references​

The following documents contain provisions which, through reference in this document, constitute requirements or criteria for its application. The latest applicable version adopted by the NL EUDI Wallet Certification System shall be used unless a specific version is stated:

  • ISO/IEC 17065, Conformity assessment - Requirements for bodies certifying products, processes and services.
  • ISO/IEC 17067, Conformity assessment - Fundamentals of product certification and guidelines for product certification schemes.
  • ISO/IEC 27001, Information security management systems - Requirements.
  • ISO/IEC 27002, Information security controls.
  • ISO/IEC 27005, Guidance on managing information security risks.
  • ETSI EN 319 401 V3.2.1 (2026-01), used as the baseline for the common provider controls in Chapters 4 to 7

2.3 Parent Documents​

  • NL-SYS-* , NL EUDI Wallet Certification System.framework NL-P-* Provider certification schemes

2.4 Informative references​

  • The European Digital Identity Wallet Architecture and Reference Framework

3 Terms & Abbreviations​

The key words "shall", "shall not", "should", "should not", "may", "need not", "will", "will not", "can" and "cannot" are interpreted in accordance with ETSI drafting rules. "Shall" identifies a mandatory certification requirement. Requirement identifiers are stable references for evaluation plans, evidence records, findings and certificates.

3.1 Terms​

PID Provider: the legal entity responsible for identity proofing and issuing and managing PID for EUDI Wallet Units, including the PID-provider obligations allocated by NL-SYS-01 and NL-P-P.

Wallet Provider: the legal entity responsible for providing and operating the EUDI Wallet service and for the walletprovider obligations allocated by NL-SYS-01 and NL-P-W.

Certified scope: the provider role, services, locations, systems, processes, interfaces and outsourced activities covered by the provider certificate.

Provider service: the organisational and technical service, including supporting processes and dependencies, within the certified scope of a Wallet Provider or PID Provider.

provider: a Wallet Provider, a PID Provider, or both, according to the applicability of a requirement.

3.2 Abbreviations​

  • WSCD - Wallet Secure Cryptographic Device
  • WSCA - Wallet Secure Cryptographic Application
  • TSP - Trust Service Provider
  • RTO - Recovery Time Objective
  • RPO - Recovery Point Objective
  • PID - Person Identification Data
  • ISMS - Information Security Management System
  • EUDIW - European Digital Identity Wallet
  • CAB - Conformity Assessment Body

3.3 Symbols​

No special symbols are defined.

4 Overview​

Chapters 4 to 7 transpose the horizontal control domains of ETSI EN 319 401 V3.2.1 to Wallet Providers and PID Providers. Unless marked role-specific or conditional, each requirement applies to both provider roles and to all systems and outsourced services within their certified scope.

4.1 General​

Provider conformity is assessed as service certification under the NL EUDI Wallet Certification System.

The Wallet Provider remains responsible for the secure provision and operation of wallet-related services and for maintaining valid assurance evidence for the wallet solution in scope.

The PID Provider remains responsible for controlled PID issuance, status and lifecycle management, and the supporting trust and fraud-management services within its certified scope.

4.2 Applicability of conditional requirements​

Requirement

ID

REQ-4.2-01

Normative requirement Applies to Typical evidence

The Provider shall document, for every requirement marked conditional

or role-specific, whether it is applicable and the factual basis for that

determination.

Document review,

interview and

operating records

Requirement IDNormative requirementApplies toTypical evidence
REQ-4.2-02A determination of non-applicability shall not transfer, waive or obscure a responsibility that remains with the Provider under law, the NL certification system, a certification contract or an outsourcing arrangement.BothDocument review, interview and operating records

Requirement

ID

REQ-4.2-03

Normative requirement Applies to Typical evidence

The CAB shall be given sufficient architecture, service-decomposition

and responsibility-allocation information to validate applicability

decisions.

Document review,

interview and

operating records

Both

Both

5 Risk management framework and risk assessment​

The Provider shall apply the risk-management framework and risk-assessment principles of ETSI EN 319 401 to the certified provider service, taking account of the NL-SYS-01 allocation of responsibilities, provider dependencies and the system risk register under NL-SYS-04.

Requirement IDNormative requirementApplies toTypical evidence
REQ-5-01The Provider shall establish, implement, maintain and continually improve a documented risk-management framework covering the certified provider service.BothDocument review, interview and operating records
REQ-5-02The framework shall define risk ownership, risk acceptance authority, assessment criteria, treatment options, review frequency and escalation thresholds.BothDocument review, interview and operating records
REQ-5-03The Provider shall maintain a current risk assessment addressing threats, vulnerabilities, dependencies and impacts affecting confidentiality, integrity, availability, authenticity, privacy and sole user control.BothDocument review, interview and operating records
REQ-5-04The Provider shall map its assessment to the system risk register maintained under NL-SYS-04 and shall identify provider-specific additions, assumptions and residual risks.BothDocument review, interview and operating records
REQ-5-05Risk assessment shall cover interfaces and dependencies between the Wallet Provider, PID Provider, wallet solution, WSCA/WSCD, trust services, access-certificate services, registration-certificate services and other material ecosystem components.BothDocument review, interview and operating records
REQ-5-06The Provider shall reassess risk following significant change, incident, vulnerability disclosure, material supplier change, threat-intelligence update or change to applicable legal or scheme requirements.BothDocument review, interview and operating records
REQ-5-07Risk treatment decisions shall identify responsible owners, target dates, required evidence and residual-risk acceptance.BothDocument review, interview and operating records
REQ-5-08Risks that may affect certificate validity, subordinate assurance evidence, national admission conditions or another provider shall be reported in accordance with NL-SYS-01 and the applicable provider scheme.BothDocument review, interview and operating records
REQ-5-09The Wallet Provider shall specifically assess risks arising from wallet onboarding, activation, binding to the user, wallet-unit lifecycle operations and integration with the designated PID Provider.Wallet ProviderDocument review, interview and operating records
REQ-5-10The PID Provider shall specifically assess risks arising from identity proofing, PID issuance, binding to a wallet unit, status services, revocation, fraud detection and dependencies shared by multiple Wallet Providers.PID ProviderDocument review, interview and operating records

6 Policies and practices​

The Provider shall establish the policies, practice statements and terms needed to describe and govern its certified service. References in ETSI EN 319 401 to a Trust Service Practice Statement are implemented here as a Provider Practice Statement for the Wallet Provider or PID Provider.

6.1 Provider Practice Statement​

Requirement IDNormative requirementApplies toTypical evidence
REQ-6.1-01The Provider shall maintain a Provider Practice Statement describing how it implements the requirements applicable to the certified service.BothDocument review, interview and operating records
REQ-6.1-02The statement shall define the service scope, supported architectures, provider roles, trust dependencies, operational responsibilities, control ownership and applicable policy documents.BothDocument review, interview and operating records
REQ-6.1-03The statement shall identify material deviations, limitations, assumptions and external services on which conformity depends.BothDocument review, interview and operating records
REQ-6.1-04The statement shall be approved by accountable management, version-controlled and reviewed at least annually and following material change.BothDocument review, interview and operating records

6.2 Terms and conditions​

Requirement IDNormative requirementApplies toTypical evidence
REQ-6.2-01The Provider shall publish or otherwise make available clear terms and conditions for users and relevant ecosystem participants before service use.BothDocument review, interview and operating records
REQ-6.2-02Terms shall describe the service, user obligations, limitations, support channels, complaint routes, suspension and termination conditions, privacy information and relevant liability provisions.BothDocument review, interview and operating records
REQ-6.2-03The Wallet Provider shall explain wallet eligibility, onboarding, activation, recovery, suspension, termination and consequences of loss or compromise.Wallet ProviderDocument review, interview and operating records
REQ-6.2-04The PID Provider shall explain PID issuance, validity, status, revocation, correction and user redress procedures.PID ProviderDocument review, interview and operating records

6.3 Information and network security policy​

Requirement

ID

REQ-6.3-01

Requirement

ID

Normative requirement Applies to Typical evidence

The Provider shall maintain an information and network security policy

approved by accountable management and aligned with the certified

service risk assessment.

Normative requirement Document review, interview and operating records Applies to Typical evidence

REQ-6.3-02 The policy shall allocate security responsibilities, define governance

and reporting, and require measurable security objectives.

Document review,

interview and

operating records

Requirement IDNormative requirementApplies toTypical evidence
REQ-6.3-03The Provider shall review the policy at planned intervals and after significant incidents, vulnerabilities or changes.BothDocument review, interview and operating records

Requirement

ID

Normative requirement Applies to Typical evidence

REQ-6.3-04 Compliance with the policy shall be monitored and evidenced through

management review, internal audit, metrics and corrective action.

Document review,

interview and

operating records

Both

Both

Both

7 Provider management and operation​

The Provider shall implement and operate the management and technical controls in this chapter across its certified scope. The chapter follows the control sequence of clause 7 of ETSI EN 319 401 and applies it to wallet and PID service operations.

7.1 Internal organisation​

Both provider roles shall apply the organisational governance, reliability and segregation-of-duties requirements of ETSI EN 319 401 clause 7.1 within their respective certified scope.

7.1.1 General​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.1-01The Provider shall maintain a documented organisational structure with clear accountability for the certified service.BothDocument review, interview and operating records
REQ-7.1-02Accountable management shall ensure adequate authority, budget, competence and independence for security, privacy, compliance, risk and incident-management functions.BothDocument review, interview and operating records

7.1.2 Organisation reliability​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.1-03The Provider shall identify conflicts of interest and implement controls to preserve trustworthy operation and impartial evidence production.BothDocument review, interview and operating records

7.1.3 Segregation of duties​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.1-04Incompatible duties shall be segregated, including development and production administration, request and approval, key activation and key use, evidence creation and evidence approval.BothDocument review, interview and operating records

7.2 Human resources​

Both provider roles shall apply every personnel-security requirement of ETSI EN 319 401 clause 7.2 to employees, contractors, trusted roles and relevant supplier personnel supporting their respective certified scope.

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.2-01Personnel and contractors in trusted roles shall be screened to a level proportionate to their access and responsibilities, subject to applicable law.BothDocument review, interview and operating records
REQ-7.2-02Role profiles shall define competence, authority, security responsibilities and required training.BothDocument review, interview and operating records
REQ-7.2-03Personnel shall receive introduction and recurring training covering security, privacy, fraud, incident reporting, social engineering and role-specific procedures.BothDocument review, interview and operating records
REQ-7.2-04Access and responsibilities shall be reviewed when employment or assignment changes and revoked promptly upon termination.BothDocument review, interview and operating records
REQ-7.2-05The Provider shall maintain sufficient staffing and succession arrangements for critical operations, incident response and crisis management.BothDocument review, interview and operating records

7.3 Asset management​

Both provider roles shall apply every asset-management requirement of ETSI EN 319 401 clause 7.3 to information, software, hardware, cryptographic material, media, services and supplier-managed assets in their respective certified scope.

7.3.1 General requirements​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.3-01The Provider shall maintain an inventory of information, software, hardware, cryptographic assets, services, data flows, interfaces and suppliers in the certified scope.BothDocument review, interview and operating records

7.3.2 Assets classification​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.3-02Assets shall have assigned owners and be classified according to confidentiality, integrity, availability, authenticity and privacy needs.BothDocument review, interview and operating records

7.3.3 Storage media and asset handling​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.3-03Rules shall govern acceptable use, secure handling, storage, transfer, return, sanitisation and disposal of assets and media.BothDocument review, interview and operating records
REQ-7.3-04Production datasets, identity evidence, PID data, wallet-unit identifiers, attestation material and security logs shall be protected against unauthorised access and inappropriate reuse.BothDocument review, interview and operating records

7.4 Access control​

Both provider roles shall apply every access-control requirement of ETSI EN 319 401 clause 7.4 to human, system, service and privileged access in their respective certified scope.

7.4.1 General​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.4-01Access shall be based on least privilege, need-to-know, role separation and explicit authorisation.BothDocument review, interview and operating records

7.4.2 Privileged and system administration accounts​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.4-02User and privileged access rights shall be approved, uniquely attributable, periodically reviewed and promptly revoked.BothDocument review, interview and operating records
REQ-7.4-03Privileged and system administration shall use dedicated accounts, controlled administration paths and enhanced monitoring.BothDocument review, interview and operating records

7.4.3 Administration systems​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.4-04Administrative systems shall be isolated from ordinary user environments and protected against direct Internet exposure unless specifically justified and controlled.BothDocument review, interview and operating records

7.4.4 Identification​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.4-05Identities used for operational access shall be verified before credentials are issued.BothDocument review, interview and operating records

7.4.5 Authentication​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.4-06Multi-factor authentication shall protect remote access, privileged access and access to security-critical systems.BothDocument review, interview and operating records
REQ-7.4-07Service-to-service access shall use mutually authenticated, authorised and cryptographically protected mechanisms with controlled credential lifecycles.BothDocument review, interview and operating records

7.5 Cryptographic controls​

Both provider roles shall apply every cryptographic-control requirement of ETSI EN 319 401 clause 7.5. The Wallet Provider shall apply these controls to wallet-service and wallet-unit-related cryptographic assets under its control. The PID Provider shall apply them to PID issuance, signing or sealing, binding and status-service cryptographic assets under its control.

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.5-01The Provider shall maintain a cryptographic policy covering approved algorithms, protocols, key lengths, key ownership, key lifecycle, certificate management and cryptographic agility.BothDocument review, interview and operating records
REQ-7.5-02Cryptographic keys shall be generated, stored, used, rotated, backed up, recovered, archived and destroyed under documented controls proportionate to their purpose.BothDocument review, interview and operating records
REQ-7.5-03Access to high-impact keys shall require strong authentication, separation of duties and tamper-resistant protection appropriate to the assessed risk.BothDocument review, interview and operating records
REQ-7.5-04The Provider shall monitor deprecation of algorithms, protocols and cryptographic products and maintain a transition plan.BothDocument review, interview and operating records
REQ-7.5-05The PID Provider shall protect PID signing or sealing keys and associated status-service keys in accordance with applicable trust-service and scheme requirements.PID ProviderDocument review, interview and operating records

7.6 Physical and environmental security​

Both provider roles shall apply every physical and environmental security requirement of ETSI EN 319 401 clause 7.6 to locations and facilities used directly or through cloud, hosting or colocation suppliers.

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.6-01Facilities hosting critical systems shall use layered physical access controls, monitoring, visitor management and access logging.BothDocument review, interview and operating records
REQ-7.6-02Environmental controls shall address power, fire, water, temperature, communications failure and other site-specific hazards.BothDocument review, interview and operating records
REQ-7.6-03Physical access rights shall be approved, reviewed and revoked, and anomalies shall be investigated.BothDocument review, interview and operating records
REQ-7.6-04Where cloud or colocation facilities are used, the Provider shall obtain and assess evidence that physical and environmental requirements are met.BothDocument review, interview and operating records

7.7 Operation security​

Both provider roles shall apply every operational-security requirement of ETSI EN 319 401 clause 7.7 to acquisition, development, configuration, change, testing, patching and operation of systems in their respective certified scope.

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.7-01The Provider shall maintain documented, approved and tested operating procedures for security-critical and service-critical activities.BothDocument review, interview and operating records
REQ-7.7-02Changes shall be risk-assessed, authorised, tested, traceable and supported by rollback or recovery arrangements.BothDocument review, interview and operating records
REQ-7.7-03Development, test, acceptance and production environments shall be appropriately separated.BothDocument review, interview and operating records
REQ-7.7-04Secure configuration baselines shall be defined, deployed, monitored and reviewed for deviation.BothDocument review, interview and operating records
REQ-7.7-05Malware protection, endpoint controls, patching and vulnerability remediation shall be implemented according to risk and defined target times.BothDocument review, interview and operating records
REQ-7.7-06Capacity, availability, performance and security-relevant service health shall be monitored against defined thresholds.BothDocument review, interview and operating records
REQ-7.7-07Backup and restoration procedures shall be tested and shall preserve confidentiality, integrity and recoverability.BothDocument review, interview and operating records
REQ-7.7-08The Provider shall control production access by developers and shall record and review exceptional access.BothDocument review, interview and operating records

7.8 Network security​

Both provider roles shall apply every network-security requirement of ETSI EN 319 401 clause 7.8 to internal, external and inter-provider networks, interfaces and administration channels in their respective certified scope.

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.8-01Networks shall be architected and segmented according to trust level, data sensitivity and service criticality.BothDocument review, interview and operating records
REQ-7.8-02Security boundaries shall enforce authenticated and authorised communications and minimise exposed services.BothDocument review, interview and operating records
REQ-7.8-03External and inter-provider interfaces shall be inventoried, threat-modelled, protected and monitored.BothDocument review, interview and operating records
REQ-7.8-04Network changes, firewall rules, routes, certificates and service endpoints shall be subject to controlled change management and periodic review.BothDocument review, interview and operating records
REQ-7.8-05The Provider shall deploy measures to detect and mitigate denial-of-service, anomalous traffic, lateral movement and data exfiltration.BothDocument review, interview and operating records

7.9 Vulnerabilities and incident management​

Both provider roles shall apply every vulnerability, monitoring, logging, incident-response, reporting, eventclassification and post-incident requirement of ETSI EN 319 401 clause 7.9. Each Provider shall additionally assess effects on the counterpart provider and the national trust framework.

7.9.1 Monitoring and logging​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.9-01The Provider shall collect, protect, correlate and review security logs sufficient for detection, investigation, certification evidence and legal obligations.BothDocument review, interview and operating records
REQ-7.9-02Time sources shall be synchronised and protected to support reliable event correlation.BothDocument review, interview and operating records

7.9.2 Incident response​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.9-03The Provider shall maintain documented incident response procedures with classification, escalation, containment, eradication, recovery and communication steps.BothDocument review, interview and operating records

7.9.3 Reporting​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.9-04Incidents and vulnerabilities that may affect certified conformity, users, another provider or the trust framework shall be reported to the CAB, Scheme Owner and competent authorities within applicable deadlines.BothDocument review, interview and operating records
REQ-7.9-05The Provider shall operate a vulnerability intake and coordinated disclosure process covering its own components and material suppliers.BothDocument review, interview and operating records

7.9.4 Event assessment and classification​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.9-06Events shall be assessed consistently for severity, affected assets, user impact, certificate impact, exploitation status and cross-provider consequences.BothDocument review, interview and operating records

7.9.5 Post-incident reviews​

Requirement

ID

REQ-7.9-07

Normative requirement Applies to Typical evidence

Post-incident reviews shall identify root causes, control failures,

corrective actions, responsible owners and lessons to be shared with

relevant parties.

Document review,

interview and

operating records

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.9-08The PID Provider shall assess systemic impact where an incident may affect multiple Wallet Providers or issued PIDs.PID ProviderDocument review, interview and operating records

7.10 Collection of evidence​

Both provider roles shall apply every evidence-collection and record-retention requirement of ETSI EN 319 401 clause 7.10 to operational, security, legal and certification evidence in their respective certified scope.

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.10-01The Provider shall identify evidence required to demonstrate conformity for initial certification, surveillance, special evaluation and recertification.BothDocument review, interview and operating records

Requirement

ID

Normative requirement Applies to Typical evidence

REQ-7.10-02 Evidence shall be attributable, complete, protected against alteration,

Requirement

ID

retained for the prescribed period and retrievable without undue delay. Both

Normative requirement Document review, interview and operating records Applies to Typical evidence

REQ-7.10-03 Collection and handling of forensic evidence shall preserve integrity,

Requirement

ID

REQ-7.10-04

chain of custody and legal admissibility where relevant.

Normative requirement Document review, interview and operating records Applies to Typical evidence

The Provider shall maintain traceability from each requirement to

implemented control, evidence source, owner, assessment result and

open finding.

7.11 Business continuity management​

Both provider roles shall apply every business-continuity, backup, redundancy, recovery and crisis-management requirement of ETSI EN 319 401 clause 7.11, including dependencies on the counterpart provider.

Document review,

interview and

operating records

Both

Both

Both

7.11.1 4.1 General​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.11-01The Provider shall maintain business continuity and disaster recovery arrangements covering the complete certified service and material dependencies.BothDocument review, interview and operating records
REQ-7.11-02Business impact analysis shall define maximum tolerable disruption, recovery priorities, RTOs and RPOs for critical services and data.BothDocument review, interview and operating records
REQ-7.11-03Continuity plans shall address loss of staff, facilities, infrastructure, supplier service, cryptographic capability and communications.BothDocument review, interview and operating records

7.11.2 Back up​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.11-04Backups shall be protected, geographically or logically separated as appropriate, and restoration shall be tested at planned intervals.BothDocument review, interview and operating records

7.11.3 Crisis management​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.11-05Crisis-management arrangements shall define command, decision rights, communications, stakeholder notification and transition back to normal operation.BothDocument review, interview and operating records
REQ-7.11-06Continuity and crisis exercises shall include scenarios involving compromise or unavailability of a counterpart Wallet Provider or PID Provider.BothDocument review, interview and operating records

7.12 Provider termination and termination plans​

Both provider roles shall apply every termination-planning requirement of ETSI EN 319 401 clause 7.12. The Wallet Provider shall address wallet-unit continuity or orderly cessation; the PID Provider shall address PID validity, status, revocation and evidence continuity.

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.12-01The Provider shall maintain a termination plan that supports an orderly cessation, transfer or replacement of the certified service.BothDocument review, interview and operating records
REQ-7.12-02The plan shall address user notification, data portability or lawful disposal, record retention, key and certificate status, supplier exit, continued status information and cooperation with the Scheme Owner and CAB.BothDocument review, interview and operating records
REQ-7.12-03The Wallet Provider plan shall address wallet suspension or migration, user access to records, and consequences for active wallet units.Wallet ProviderDocument review, interview and operating records
REQ-7.12-04The PID Provider plan shall address continuity of PID validity status, revocation information, evidence retention and effects on all dependent wallets.PID ProviderDocument review, interview and operating records
REQ-7.12-05The termination plan shall be reviewed and exercised at planned intervals and after material architectural or supplier changes.BothDocument review, interview and operating records

7.13 Compliance​

Both provider roles shall apply every compliance requirement of ETSI EN 319 401 clause 7.13, including legal evidence, accessibility, personal-data protection and management reporting.

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.13-01The Provider shall identify and maintain an inventory of legal, regulatory, contractual, certification-scheme and policy obligations applicable to the certified service.BothDocument review, interview and operating records
REQ-7.13-02The Provider shall conduct planned internal audits covering all requirements of this document and the applicable provider scheme.BothDocument review, interview and operating records
REQ-7.13-03Management shall review conformity, risks, incidents, vulnerabilities, audit results, supplier performance, complaints, objectives and corrective actions at planned intervals.BothDocument review, interview and operating records
REQ-7.13-04Nonconformities shall be recorded, root-caused, corrected and verified for effectiveness within risk-based timescales.BothDocument review, interview and operating records
REQ-7.13-05The Provider shall notify material changes affecting the certified object, assurance evidence or certificate scope before implementation where required by the applicable scheme.BothDocument review, interview and operating records

7.14 Supply chain​

Both provider roles shall apply every supply-chain requirement of ETSI EN 319 401 clause 7.14 to direct suppliers, service providers, cloud services, subcontractors, ICT products and critical components in their respective certified scope.

7.14.1 Supply chain policy​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.14-01The Provider shall maintain a supply-chain security policy covering selection, due diligence, contracting, onboarding, monitoring, change and exit.BothDocument review, interview and operating records
REQ-7.14-02Suppliers shall be classified by criticality, access, data handled, substitutability and potential impact on certificate validity or service continuity.BothDocument review, interview and operating records

7.14.2 Supply chain procedures and processes​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.14-03Supplier risk assessments shall cover ownership, jurisdiction, financial stability, personnel, security posture, vulnerabilities, concentration risk and subcontracting.BothDocument review, interview and operating records
REQ-7.14-04Contracts shall define security, privacy, availability, incident notification, vulnerability handling, audit rights, evidence access, change notification, data location, return or deletion and termination assistance.BothDocument review, interview and operating records

7.14.3 Responsibility, third-party agreements and SLA​

Requirement IDNormative requirementApplies toTypical evidence
REQ-7.14-05The Provider shall remain accountable for outsourced activities and shall ensure that the CAB and competent authorities can obtain necessary evidence.BothDocument review, interview and operating records
REQ-7.14-06Supplier performance and assurance evidence shall be reviewed at planned intervals and after material events.BothDocument review, interview and operating records
REQ-7.14-07The Provider shall maintain exit and substitution plans for suppliers whose failure could materially affect the certified service.BothDocument review, interview and operating records

Annex A (informative) Mapping to the eIDAS Regulation​

A.1 Purpose​

This annex identifies how the provider-control domains support the legal and operational obligations applicable to EUDI Wallet Providers and PID Providers under Regulation (EU) No 910/2014 as amended by Regulation (EU) 2024/1183.

It is an aid to assessment and does not replace the legal text, the applicable implementing acts or the allocation of responsibilities in NL-SYS-01.

  • Governance, risk and policy controls in Chapters 4 to 6 support demonstrable control of the provider service and its risks.
  • Access control, cryptographic controls, operations, network security and incident management in Chapter 7 support protection of wallet and PID services and their evidence.
  • Business continuity, termination and supply-chain controls support continued availability, orderly cessation and accountability for outsourced activities.
  • Role-specific wallet-onboarding, wallet-lifecycle, identity-proofing and PID-lifecycle obligations remain governed by NL-P-W, NL-P-P and their subsidiary documents.

A.2 Mapping​

The mapping below supports traceability between Regulation (EU) No 910/2014, as amended by Regulation (EU) 2024/1183, and the provider controls in this document. It does not establish legal compliance by itself and does not replace the applicable provider scheme, implementing acts or legal assessment.

eIDAS provisionProvider applicabilityCorresponding requirements in this document
Article 5a - provision, security and operation of European Digital Identity WalletsWallet Provider; PID Provider where its service supports PID availability, binding, status or lifecycleChapters 4-6; 7.1, 7.3-7.11, 7.13 and 7.14. Role-specific wallet and PID lifecycle requirements remain in NL-P-W and NL-P-P.
Article 5a - user control, security, privacy and transaction transparencyWallet Provider; PID Provider for PID processing and disclosure under its control7.3-7.10 and 7.13, supplemented by the applicable functional and cybersecurity requirements.
Article 5c - certification of European Digital Identity WalletsWallet Provider; PID Provider where its subordinate certificate or evidence supports the certified wallet solution7.10 and 7.13; traceability and evidence are used under NL-SYS-01 and the applicable provider scheme.
Article 5d - publication of a list of certified European Digital Identity WalletsWallet Provider, with system-level publication responsibilities governed by NL-SYS-017.10, 7.12 and 7.13 support accurate certificate evidence, change notification and termination information.
Article 5e - security breach of European Digital Identity WalletsWallet Provider; PID Provider where the breach affects PID issuance, status, binding or dependent wallets7.9, 7.11 and 7.12 support detection, reporting, containment, recovery, continuity and orderly restriction or cessation.
Article 10a - security breach concerning electronic identification schemesBoth where the certified provider service forms part of, or materially supports, the notified scheme7.9 and 7.11, together with reporting and coordination duties in NL-SYS-01.
Article 13(2) - limitations on use and liabilityBoth, where limitations are stated for the provider service6.2 and 7.13 support clear terms, limitations, liability information and evidence of legal compliance.
Article 15 - accessibility for persons with disabilitiesBoth6.2 and 7.13 support understandable terms, accessibility controls and consideration of applicable accessibility standards.
Articles 19a and 24(2)(fb) - security and incident obligations for trust service providersPID Provider only where it also acts as a trust service provider; otherwise informative for both provider rolesChapters 5-7, especially 7.9 and 7.11. Applicability depends on the provider's legal role and certified service.
Article 24(2)(a) - notification of changes or intended cessation by a qualified trust service providerPID Provider only where it is a qualified trust service provider; provider-scheme change notification applies separately to both7.12 and 7.13; scheme-specific notifications remain governed by NL-SYS-01, NL-P-W and NL-P-P.
Article 24(2)(b) - competent and reliable personnel and standardised proceduresPID Provider where acting as a qualified trust service provider; substantively relevant to both7.1, 7.2 and 7.7.
Article 24(2)(c) - financial resources or liability insurancePID Provider where acting as a qualified trust service provider; otherwise subject to applicable national and scheme rules7.1 and 7.13.
Article 24(2)(d) - pre-contractual information on precise terms and limitationsPID Provider where acting as a qualified trust service provider; clear provider terms apply to both6.2.
Article 24(2)(e)-(g) - trustworthy systems, protected data and measures against forgery or theftPID Provider where acting as a qualified trust service provider; substantively relevant to both5, 6.3 and 7.3-7.9.
Article 24(2)(h) - recording and retention of relevant informationPID Provider where acting as a qualified trust service provider; evidence-retention controls apply to both7.10 and 7.12.
Article 24(2)(i) - up-to-date termination planPID Provider where acting as a qualified trust service provider; termination planning applies to both7.12.

Annex B (informative) Mapping to CIR 2024/2690​

B.1 Introduction​

This annex explains how the requirements in Chapters 4 to 7 support assessment against Commission Implementing Regulation (EU) 2024/2690 where that Regulation applies to a Wallet Provider, PID Provider or supporting service within the certified scope. It is an assessment aid: it neither determines whether a Provider falls within the Regulation nor replaces the legal text, competent-authority supervision or a required conformity assessment.

Chapters 4 and 5 establish the control boundary and risk basis. Chapter 4 requires documented applicability decisions and responsibility allocation. Chapter 5 requires a maintained risk-management framework, current risk assessment, treatment and residual-risk decisions, reassessment after material events, and coverage of provider, ecosystem and supplier dependencies.

Chapter 6 establishes the governing documentation. The Provider Practice Statement describes the certified service, architecture, responsibilities, dependencies and implemented controls. Terms and conditions communicate relevant service conditions, while the information and network security policy establishes management-approved security governance, objectives, review and monitoring.

Chapter 7 provides the operational and technical control set. It covers organisation and personnel; assets and access; cryptography; physical, operational and network security; vulnerability and incident management; evidence; continuity and crisis management; termination; compliance; and supply-chain security. The requirement tables identify the applicable provider role and the typical evidence expected for assessment.

For assessment, the Provider and CAB should maintain one traceability matrix linking each applicable provision of Regulation (EU) 2024/2690 to the relevant Chapters 4 to 7 requirement identifiers, provider-scheme requirements, implemented controls, accountable owners and evidence. Evidence may be reused where it demonstrates both scheme conformity and regulatory implementation, but gaps in legal scope, role allocation or regulatory detail shall be assessed separately.

B.2 Mapping​

The mapping is intended to help avoid duplicate control implementation and duplicate evidence collection. It does not alter the scope of Regulation (EU) 2024/2690, determine whether a Provider is in scope, or replace an assessment required by competent authorities.

  • Risk analysis and information-system security: Chapters 4, 5 and 6.
  • Incident handling and reporting: Chapter 7.9.
  • Business continuity and crisis management: Chapter 7.11.
  • Supply-chain security: Chapter 7.14.
  • Security in acquisition, development, maintenance and change: Chapters 7.3, 7.7 and 7.14.
  • Assessment of effectiveness of controls and compliance: Chapters 7.10 and 7.13.
  • Cyber-hygiene, personnel security and access control: Chapters 7.2 and 7.4.
  • Cryptography and communications security: Chapters 7.5 and 7.8.
  • Asset management and physical security: Chapters 7.3 and 7.6.