Feedback on the Draft Implementing Regulation for Qualified Trust Service Providers – Proposals for Strengthening Legal Certainty, Interoperability and Cybersecurity

Our feedback presents targeted proposals to strengthen the draft Implementing Regulation for Qualified Trust Service Providers (QTSPs) under eIDAS 2.0. We advocate for enhanced legal certainty, global interoperability, and robust cybersecurity by embedding core principles like exclusive control over digital records, immutable metadata audit trails, and the mandatory use of globally recognised identifiers (e.g., LEI/vLEI alongside EORI). Drawing on the complementary European Trade Indexes Registry (EUTIR) framework, we outline how QTSPs can serve as the foundational trust layer for the EU’s digital economy, enabling secure cross-border trade, SME finance, and seamless integration with initiatives like the Digital Product Passport and CBAM.