Feedback on the Draft Implementing Regulation on Qualified Electronic Ledgers: Preparing the Ground for a Digital Business Wallet Trust Layer

October 2025

Our feedback on the draft Implementing Regulation for Qualified Electronic Ledgers aims to future-proof the legal framework by embedding essential functionalities’such as metadata lifecycle management, exclusive control, and harmonised certification’that ensure interoperability and legal validity across all electronic documents. We advocate for these amendments to lay the groundwork for a Digital Business Wallet and to align seamlessly with upcoming Union-wide digital registries like EUTIR, thereby supporting the Single Market’s green and digital transition while safeguarding Europe’s digital sovereignty.