Electronic Signatures and Trust Infrastructures (ESI); Policy and Security requirements for Providers of Electronic Attestation of Attributes Services

DTS/ESI-0019471

General Information

Status
Not Published
Current Stage
12 - Completion
Due Date
19-May-2025
Completion Date
26-May-2025
Ref Project
Standard
ETSI TS 119 471 V1.1.1 (2025-05) - Electronic Signatures and Trust Infrastructures (ESI); Policy and Security requirements for Providers of Electronic Attestation of Attributes Services
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TECHNICAL SPECIFICATION
Electronic Signatures and Trust Infrastructures (ESI);
Policy and Security requirements for Providers of Electronic
Attestation of Attributes Services

2 ETSI TS 119 471 V1.1.1 (2025-05)

Reference
DTS/ESI-0019471
Keywords
digital identity, EAA, EUDI wallet, identity,
trust services
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ETSI
3 ETSI TS 119 471 V1.1.1 (2025-05)
Contents
Intellectual Property Rights . 5
Foreword . 5
Modal verbs terminology . 5
Introduction . 5
1 Scope . 7
2 References . 7
2.1 Normative references . 7
2.2 Informative references . 7
3 Definition of terms, symbols and abbreviations . 8
3.1 Terms . 8
3.2 Symbols . 9
3.3 Abbreviations . 10
3.4 Notation . 10
4 EAA trust services . 10
4.1 Overview . 10
4.2 EAA Issuance services . 11
4.2.1 Initiation . 11
4.2.1.1 General . 11
4.2.1.2 EUDIW specific . 11
4.2.2 EAA issuance . 11
4.2.2.1 General . 11
4.2.2.2 Verification of attributes against authentic sources . 12
4.2.2.3 EUDIW specific . 12
4.2.3 EAA Usage . 14
4.2.3.1 General . 14
4.2.3.2 EUDIW Specific . 14
4.2.4 EAA Renewal . 14
4.2.4.1 General . 14
4.2.4.2 EUDIW Specific . 14
4.2.5 EAA Revocation . 14
4.2.5.1 General . 14
4.2.5.2 EUDIW Specific . 15
4.3 EAA validation services . 16
4.3.1 General . 16
4.3.2 EUDIW Specific . 16
5 Risk Assessment . 16
6 General provision on policies and practices . 17
6.1 EAAS practice statement . 17
6.1.1 General . 17
6.1.2 EUDIW specific . 17
6.2 Terms and conditions . 17
6.3 Information security policy . 17
6.4 EAA policy . 17
7 EAASP management and operation . 18
7.1 Internal organization. 18
7.1.1 Organization reliability . 18
7.1.2 Segregation of duties . 18
7.2 Human resources . 18
7.3 Asset management . 18
7.4 Access control . 19
7.5 Cryptographic controls . 19
7.5.1 General . 19
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4 ETSI TS 119 471 V1.1.1 (2025-05)
7.5.2 Key pair generation and installation . 19
7.5.3 EAAS key protection and cryptographic module engineering controls . 20
7.5.4 Other aspects of key pair management . 21
7.5.5 EUDIW specific . 21
7.6 Physical and environmental security . 21
7.7 Operation security . 21
7.8 Network security . 21
7.9 Vulnerabilities and Incident management . 22
7.10 Collection of evidence for EAASP internal services . 22
7.11 Business continuity management . 22
7.11.1 General . 22
7.11.2 Back up . 22
7.11.3 Crisis management . 23
7.12 EAASP and EAAS termination and termination plans . 23
7.13 Compliance. 23
7.14 Supply chain . 23
History . 24

ETSI
5 ETSI TS 119 471 V1.1.1 (2025-05)
Intellectual Property Rights
Essential patents
IPRs essential or potentially essential to normative deliverables may have been declared to ETSI. The declarations
pertaining to these essential IPRs, if any, are publicly available for ETSI members and non-members, and can be
found in ETSI SR 000 314: "Intellectual Property Rights (IPRs); Essential, or potentially Essential, IPRs notified to
ETSI in respect of ETSI standards", which is available from the ETSI Secretariat. Latest updates are available on the
ETSI IPR online database.
Pursuant to the ETSI Directives including the ETSI IPR Policy, no investigation regarding the essentiality of IPRs,
including IPR searches, has been carried out by ETSI. No guarantee can be given as to the existence of other IPRs not
referenced in ETSI SR 000 314 (or the updates on the ETSI Web server) which are, or may be, or may become,
essential to the present document.
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the oneM2M Partners. GSM and the GSM logo are trademarks registered and owned by the GSM Association.
Foreword
This Technical Specification (TS) has been produced by ETSI Technical Committee Electronic Signatures and Trust
Infrastructures (ESI).
Modal verbs terminology
In the present document "shall", "shall not", "should", "should not", "may", "need not", "will", "will not", "can" and
"cannot" are to be interpreted as described in clause 3.2 of the ETSI Drafting Rules (Verbal forms for the expression of
provisions).
"must" and "must not" are NOT allowed in ETSI deliverables except when used in direct citation.
Introduction
The present document provides detailed policy and security requirements for Electronic Attestation of Attributes (EAA)
services and EAA service providers, which play a critical role under the eIDAS Regulation [i.1].
The eIDAS Regulation [i.1] aims to enhance trust in electronic transactions within the internal market by providing a
common foundation for secure electronic identification and trust services. One of the key components of this regulation
is the concept of EAA, which enables the verification and validation of specific attributes of natural persons, legal
persons and objects in an electronic form.
The present document specifies the policies and security requirements for EAA service providers offering EAA
services. It includes comprehensive requirements for the verification of attributes, the issuance of attestations, and the
validation services required to ensure the integrity and reliability of the EAA lifecycle.
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6 ETSI TS 119 471 V1.1.1 (2025-05)
Key aspects covered in the present document include policy and security requirements:
• guidelines on how trust service providers should verify and generate electronic attestations of attributes,
ensuring that all processes are secure and reliable;
• attributes verification: requirements for verifying the identity and specific attributes of individuals or entities
requesting attestations, ensuring unequivocal certainty;
• issuance and validation of EAAs: requirements on protocols for the secure issuance and validation of
electronic attestations, including the use of privacy-preserving techniques to protect user data;
• risk management: comprehensive risk assessment procedures to identify and mitigate potential threats to the
security and integrity of EAA services;
• compliance and auditability: requirements for maintaining detailed logs and records of all transactions and
operations related to the issuance of EAAs to support auditability and transparency.

ETSI
7 ETSI TS 119 471 V1.1.1 (2025-05)
1 Scope
The present document specifies policy and security requirements for electronic attestation of attributes trust service
providers and the attestation of attributes services they provide.
More specifically the present document specifies policy and security requirements on attributes issuance and validation
of EAA by the trust service provider.
2 References
2.1 Normative references
References are either specific (identified by date of publication and/or edition number or version number) or
non-specific. For specific references, only the cited version applies. For non-specific references, the latest version of the
referenced document (including any amendments) applies.
Referenced documents which are not found to be publicly available in the expected location might be found in the
ETSI docbox.
NOTE: While any hyperlinks included in this clause were valid at the time of publication, ETSI cannot guarantee
their long term validity.
The following referenced documents are necessary for the application of the present document.
[1] ETSI EN 319 401: "Electronic Signatures and Trust Infrastructures (ESI); General Policy
Requirements for Trust Service Providers".
2.2 Informative references
References are either specific (identified by date of publication and/or edition number or version number) or
non-specific. For specific references, only the cited version applies. For non-specific references, the latest version of the
referenced document (including any amendments) applies.
NOTE: While any hyperlinks included in this clause were valid at the time of publication, ETSI cannot guarantee
their long term validity.
The following referenced documents may be useful in implementing an ETSI deliverable or add to the reader's
understanding, but are not required for conformance to the present document.
[i.1] Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on
electronic identification and trust services for electronic transactions in the internal market and
repealing Directive 1999/93/EC.
NOTE: The eIDAS regulation as amended by Regulation (EU) 2024/1183 of the European Parliament and of the
Council of 11 April 2024 amending Regulation (EU) No 910/2014 as regards establishing the European
Digital Identity Framework.
[i.2] ISO/IEC TS 23220-2:2024: "Cards and security devices for personal identification - Building
blocks for identity management via mobile devices - Part 2: Data objects and encoding rules for
generic eID systems".
[i.3] Commission Implementing Regulation (EU) 2024/2977 of 28 November 2024 laying down rules
for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council
as regards person identification data and electronic attestations of attributes issued to European
Digital Identity Wallets.
[i.4] OpenID for Verifiable Credential Issuance.
[i.5] EU Architectural Reference Framework.
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8 ETSI TS 119 471 V1.1.1 (2025-05)
[i.6] ISO/IEC 15408-1:2022: "Information security, cybersecurity and privacy protection — Evaluation
criteria for IT security".
[i.7] ISO/IEC 19790:2025: "Information security, cybersecurity and privacy protection — Security
requirements for cryptographic modules".
[i.8] FIPS 140-2: "Security Requirements for Cryptographic Modules".
[i.9] FIPS 140-3: "Development".
[i.10] ETSI TS 119 312: "Electronic Signatures and Trust Infrastructures (ESI); Cryptographic Suites".
[i.11] ETSI EN 319 411-1: "Electronic Signatures and Trust Infrastructures (ESI); Policy and security
requirements for Trust Service Providers issuing certificates; Part 1: General requirements".
[i.12] ISO/IEC 18013-5:2021 "Personal identification — ISO-compliant driving licence — Part 5:
Mobile driving licence (mDL) application".
3 Definition of terms, symbols and abbreviations
3.1 Terms
For the purposes of the present document, the terms given in ETSI EN 319 401 [1] and the following apply:
attribute: characteristic, quality, right or permission of a natural or legal person or of an object
NOTE: As per eIDAS definition [i.1].
attestation of attributes validation: process of verifying and confirming that an attestation of attributes is valid
attribute(s) subject: natural persons, legal person or entity the attribute(s) is(are) referring to
authentication: electronic process that enables the electronic identification of a natural or legal person to be confirmed,
or the origin and integrity of data in electronic form to be confirmed
NOTE: As per eIDAS definition [i.1].
authentic source: repository or system, held under the responsibility of a public sector body or private entity, that
contains and provides attributes about a natural or legal person and is considered to be a primary source of that
information or recognised as authentic in accordance with Union or national law, including administrative practice
NOTE 1: As per eIDAS definition [i.1].
NOTE 2: This include any source irrespective of its form that can be relied upon to provide accurate data,
information and/or evidence that can be used to provide attributes about a natural or legal person.
Electronic Attestation of Attributes (EAA): attestation in electronic form that allows the authentication of attributes
NOTE: As per eIDAS definition [i.1].
electronic attestation of attributes policy: set of rules that indicates the applicability of an EAA to a particular
community and/or class of application with common requirements
NOTE 1: See clause 4.2.2 of ETSI EN 319 411-1 [i.11] for further explanation.
NOTE 2: This refers to a sector or service specific policies (i.e. banking, age verification).
electronic attestation of attributes practice statement: statement of the practices that an EAASP employs in
providing a trust service
NOTE: As per ETSI EN 319 401 [1] definition [1].
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9 ETSI TS 119 471 V1.1.1 (2025-05)
electronic attestation of attributes service policy: set of rules that indicates the applicability of EAA service with
common controls and security requirements
NOTE: See ETSI EN 319 401 [1] trust service policy definition note.
Electronic Attestation of Attributes Service Provider (EAASP): natural or legal person who provides one or more
EAA services either as a qualified or as a non-qualified trust service provider
NOTE: As per eIDAS definition [i.2].
Electronic Attestation of Attributes subject (EAA subject): natural or legal person that holds the Electronic
Attestation of Attributes
Electronic Attestation of Attributes subscriber (EAA subscriber): natural or legal person bound by agreement with
an Electronic Attestation of Attributes service provider to any subscriber obligations
electronic attestation of attributes trust service: electronic service which supports the issuance and/or validation of
electronic attestation of attributes
electronic identification: process of using person identification data in electronic form uniquely representing either a
natural or legal person, or a natural person representing a natural or legal person
NOTE: As per eIDAS definition [i.1].
electronic identification means: material and/or immaterial unit containing person identification data and which is
used for authentication to an online service or, where appropriate, to an offline service
NOTE: As per eIDAS definition [i.1].
European digital identity wallet: electronic identification means, which allows the user to securely store, manage and
validate identity data and electronic attestations of attributes, to provide them to relying parties and to other users of
European Digital Identity Wallets, and to sign by means of qualified electronic signatures or to seal by means of
qualified electronic seals
NOTE: As per eIDAS definition [i.1].
Person Identification Data (PID): set of identity attributes that uniquely identifies a natural or legal person in the
context of the EEA provisioning
NOTE: eIDAS requires PID to be issued in accordance with EU or national law and within the context of a
(notified) eID scheme.
Qualified Electronic Attestation Of Attributes (QEAA): electronic attestation of attributes, which is issued by a
qualified trust service provider and meets the requirements laid down in Annex V of eIDAS Regulation [i.1]
NOTE: As per eIDAS definition [i.1].
Qualified Electronic Attestation Of Attributes Services Provider (QEAASP): electronic attestation of attributes
services provider who is granted the qualified status by an EU National Supervisory Authority
NOTE: As per eIDAS definition [i.1].
relying party: natural or legal person that relies upon an electronic identification, European Digital Identity Wallets or
other electronic identification means, or a trust service
NOTE: As per eIDAS definition [i.1].
wallet unit: specific setup of the wallet solution for an individual user
NOTE: As described in CIR (EU) 2024/2977 Article 2.2 [i.3].
3.2 Symbols
Void.
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10 ETSI TS 119 471 V1.1.1 (2025-05)
3.3 Abbreviations
For the purposes of the present document, the abbreviations given in ETSI EN 319 401 [1] and the following apply:
ARF EU Architectural Reference Framework
CIR Commission Implementing Regulation
EAA Electronic Attestation of Attributes
EAAP Electronic Attestation of Attributes Policy
EAAS Electronic Attestation of Attributes Service
EAASP Electronic Attestation of Attributes Service Provider
EAASPol Electronic Attestation of Attributes Service Policy
EAASPS Electronic Attestation of Attributes Services Practice Statement
EAL Evaluation Assurance Level
EQ Electronic Qualification
EUDIW European Union Digital Identity Wallet
HSM Hardware Security Module
ISO International Organization for Standardization
JWT JSON Web Token
LoA Level of Assurance
mDL mobile Driving License
OpenID4VCI OpenID for Verifiable Credential Issuance
PID Person Identification Data
PIM Person Identification Means
QEAA Qualified Electronic Attestation of Attributes
QEAAS Qualified Electronic Attestation of Attributes Service
QEAASP Qualified Electronic Attestation of Attributes Service Provider
QSCD Qualified Signature Creation Device
QTSP Qualified Trust Service Provider
SD-JWT Selective Disclosure JSON Web Token
TSP Trust Service Provider
VC Verifiable Credentials
VI Video Identification
WSCA Wallet Secure Cryptographic Application
WSCD Wallet Secure Cryptographic Device
WUA Wallet Unit Attestation
3.4 Notation
Each requirement is identified as follows:
REQ-EAASP-< the clause number>-<2-digit number - incremental> identifies requirements referred to the non-
qualified service provider.
REQ-QEAASP-< the clause number>-<2-digit number - incremental> identifies requirements referred to the
qualified service provider.
REQ-EAAS-< the clause number>-<2-digit number - incremental> identifies requirements referred to the service.
4 EAA trust services
4.1 Overview
An EAASP is a trusted entity that issues and/or validates attributes referred to attributes' subject. The EAASP acts as a
reliable and trusted third-party authority that vouches for the accuracy and validity of the information provided in the
EAA. The EEASP is responsible for ensuring the truthfulness, validity, and timeliness of the attributes and data
provided by the authentic or other source, the EAA Subject, and the EAA Subscriber.
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11 ETSI TS 119 471 V1.1.1 (2025-05)
4.2 EAA Issuance services
4.2.1 Initiation
4.2.1.1 General
REQ-EAASP-4.2.1.1-01: When issuing an EAA, the EAASP shall verify the identity, along with specific attributes
where applicable, of the EAA Subject and/or EAA Subscriber to whom it is issued in accordance with the EAAS and
EAASPol.
REQ-EAASP-4.2.1.1-02: The EAASP shall verify that the request contains all necessary information for creating the
EAA. The EAASP shall collect and verify the following:
a) That the EAA subject is identical to the EAA Subscriber;
b) When the EAA subject differs from the EAA Subscriber, the EAA Subscriber identity, any additional
information required for verification; and
c) That the attribute and attribute subject correspond to the EAA Subject.
REQ-EAASP-4.2.1.1-03 [CONDITIONAL]: If the requested EAA Subject is not the EAA Subscriber then the
EEASP shall obtain and verify evidence (electronic or otherwise) that confirms the right to act on behalf of the EAA
Subject.
REQ-EAASP-4.2.1.1-04 [CONDITIONAL]: If validation of the attributes is against authentic source, the EAASP
shall verify the identity of the authentic source used to verify attributes.
EXAMPLE: Verification of identity can be based on a qualified electronic signature or qualified electronic seal.
REQ-EAASP-4.2.1.1-05 [CONDITIONAL]: When the EAA Subscriber requests the issuance of an EAA for
attributes listed in Annex VI that requires consultation of an authentic source, and provided that national authorities
have established a secure access system, the EAASP should be able to verify the authenticity of the attribute(s) by at
least electronic means.
4.2.1.2 EUDIW specific
In addition, when the EAA is issued to a EUDIW the following requirements apply:
REQ-EAASP-4.2.1.2-01 [CONDITIONAL]: If the EAASP is supporting OpenID4VCI [i.4], the EAASP should
support an attestation issuance interface compliant with the OpenID4VCI protocol or an equivalent to issue EAAs to
Wallet Units, enabling interoperability between trust service providers and Wallet Unit holders.
REQ-EAASP-4.2.1.2-02: The EAASP shall implement mechanisms to authenticate Wallet Units before issuing an
EAA, verifying that the Wallet Unit comes from a trusted Wallet Provider.
REQ-EAASP-4.2.1.2-03: The EAASP shall validate that the Wallet Secure Cryptographic Device (WSCD) of the
Wallet Unit complies with the required security level before issuing an EAA.
NOTE: This can be validated using information, such a certification information, provided by the Wallet
Provider.
4.2.2 EAA issuance
4.2.2.1 General
REQ-EAASP-4.2.2.1-01: The EAASP shall request only the minimum data necessary for the issuance of the EAA, in
line with the principle of data minimization.
In particular:
REQ-EAASP-4.2.2.1-02: The EAASP shall ensure that the minimum set of attributes required for the issuance of EAA
are acquired in accordance with the EAAP.
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12 ETSI TS 119 471 V1.1.1 (2025-05)
REQ-EAASP-4.2.2.1-03: The EAASP shall verify attributes against one or more authentic or not authentic source, as
stated in EAAP.
REQ-EAASP-4.2.2.1-04: The EAASP shall define the attributes to be verified by the content and nature of the EAA
defined in EAAP.
REQ-EAASP-4.2.2.1-05: The EAASP shall not verify identity attributes that are not necessary for the EAA issuance.
NOTE: Necessary attributes are those that will be included in the EAA and possibly further attributes, e.g. unique
identity, that are necessary to enable validation of the attributes that will be included in the EEA.
REQ-EAASP-4.2.2.1-06: The EAASP shall issue EAA securely to maintain their authenticity and integrity.
REQ-EAASP-4.2.2.1-07: The EAASP shall take measures against forgery of the EAA.
REQ-EAAS-4.2.2.1-08: The EAAS shall be able to authenticate itself towards the subject of the EAA and towards the
means into which the EAA is issued.
REQ-EAASP-4.2.2.1.09: The EAASP shall issue an EAA in conformance with the EAASPol and EAAP they claim
conformity against.
REQ-EAASP-4.2.2.1-10 [CONDITIONAL]: If the EAASP supports a status service, EAAS policy shall indicate in
EAA revocation information which contains a URL indicating the location where a Relying Party can obtain a status list
or revocation list, and an identifier or index for this specific certificate or attestation within that list.
EXAMPLE: e.g. short-term EAA does not require a status service to be supported.
4.2.2.2 Verification of attributes against authentic sources
REQ-QEAASP-4.2.2.2-01: The QEAASP shall verify the authenticity of the attributes requested by EAA Subject or
EAA Subscriber for an identified EAA Subject against the relevant authentic source at national level or via designated
intermediaries recognised at national level.
REQ-QEAASP-4.2.2.2-02: The verification shall be as required by the EEAP.
REQ-QEAASP-4.2.2.2-03: The verification should, if possible, be carried out electronically.
4.2.2.3 EUDIW specific
In addition, when the EAA is issued to a EUDIW the following requirements apply:
REQ-EAASP-4.2.2.3-01: Before the EAA is issued to a EUDIW, the EAASP shall verify and validate the PID/LPID
received from the Wallet Unit.
REQ-EAASP-4.2.2.3-02: The EAASP shall authenticate to the EUDIW instance implementing mutual authentication
mechanisms that use an access certificate issued by a qualified Certificate Authority.
REQ-EAASP-4.2.2.3-03: The EAASP shall validate the EUDIW instance, whether the EUDIW instance is revoked or
suspended.
REQ-EAASP-4.2.2.3-04 [CONDITONAL]: When the EAA is issued to a EUDIW with wallet binding, the EAASP
SHALL verify that:
• the WSCD described in the WUA received from the Wallet Unit has proven possession of the private key
corresponding to the public key in the WUA; and
• the WSCD has proven possession of the attestation private key.
REQ-EAASP-4.2.2.3-05 [CONDITONAL]: When the EAA is issued with wallet binding that includes association
between two or more public keys protected by the same WSCD, the EAASP should verify the said keys are associated.
REQ-EAASP-4.2.2.3-06 [CONDITIONAL]: When the EAAP specifies that wallet binding is required, the EAASP
shall implement device binding, ensuring that the EAA is cryptographically bound to a WSCA used by the EUDI
Wallet Unit.
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13 ETSI TS 119 471 V1.1.1 (2025-05)
REQ-EAASP-4.2.2.3-07: The EAASP shall:
• verify the authenticity of the Wallet Unit by validating the signature over the Wallet Unit Attestation (WUA);
• accept only the trust anchors in the Wallet Provider Trusted List(s) for the Wallet Solutions they support;
• verify that the EUDIW Provider is present in a Wallet Provider Trusted List;
• authenticate and validate the WUA using the trust anchor(s) registered for the Wallet Provider in the Wallet
Provider Trusted List; and
• verify that the Wallet Unit's WUA is not revoked.
REQ-EAASP-4.2.2.3-08 [CONDITIONAL]: When using the OpenID4VCI protocol or equivalent issuance protocol
for issuing EAAs to a EUDIW, the EAASP shall include its access certificate in its client metadata.
REQ-EAASP-4.2.2.3-09: The EAASP shall implement measures to mitigate the risk of user linkability, including
support for limited-validity attestations or once-only attestations as determined by the EAASP policy.
REQ-EAASP-4.2.2.3-10: The EAASP shall support selective disclosure of attributes in issued EAAs, allowing users to
share only specific attributes required by a Relying Party without revealing others.
REQ-EAASP-4.2.2.3-11: The EAASP shall support mechanisms to mitigate the risk of user linkability, including at
least one of the following:
a) limited-time attestations that expire after a defined period;
b) once-only attestations that can only be presented once;
c) rotating-batch attestations that can be used in random order; or
d) Per-Relying Party attestations that are unique to specific Relying Parties.
REQ-EAASP-4.2.2.3-12 [CONDITIONAL]: When applicable, the EAASP shall implement mechanisms to bind
EAAs to the Wallet Unit's device (device binding), ensuring that EAAs cannot be cloned or used from unauthorized
devices.
REQ-EAASP-4.2.2.3-13: The EAASP shall support batch issuance when requested by the Wallet Unit, allowing
multiple EAAs with the same content to be issued simultaneously for privacy-preserving presentations.
REQ-EAASP-4.2.2.3-14 [CONDITIONAL]: The EAASP shall ensure that the issued EAA is compatible with both
proximity presentation flows (supervised and unsupervised) and remote presentation flows (same-device and cross-
device).
REQ-EAASP-4.2.2.3-15: The EAASP may include in the EAA an embedded disclosure policy containing rules
determining which types of Relying Party are allowed to receive specific attributes from the attestation.
REQ-EAASP-4.2.2.3-16: The EAASP shall implement mechanisms that allow the re-issuance of the EAA upon
request from the Wallet Unit, in case of approaching expiration, attribute value changes, or to maintain privacy
protections, consistent with the approach chosen to mitigate Relying Party linkability.
REQ-EAASP-4.2.2.3-17: The EAASP shall ensure that each EAA contains unique, cryptographically independent
elements to prevent tracking across multiple presentations.
REQ-EAASP-4.2.2.3-18: The EAASP shall ensure that the technical validity period of EAAs is determined
considering both security requirements and privacy implications, particularly the risk of user tracking.
REQ-EAASP-4.2.2.3-19: The EAASP should encode and structure the data element identifier and the attribute value
according to the schema specified in the relevant rulebook for the Attestation Type.
NOTE: PID Rulebook and the mDL Rulebook in Annex 3 of the EU Architectural Reference Framework [i.5].
ISO 23220-2 [i.2] specifies further requirements for attribute schemas which should be applied where no
rulebook exists.
ETSI
14 ETSI TS 119 471 V1.1.1 (2025-05)
4.2.3 EAA Usage
4.2.3.1 General
REQ-EAASP-4.2.3.1-01: The EAASP shall include in its practice statement and terms and conditions at least the
following EAA Subject's obligations:
a) an obligation to provide the EAASP with accurate and complete information in accordance with the
requirements of the present document;
b) an obligation for EAA to be only used in accordance with any limitations notified to the EAA Subscriber
and/or the EAA Subject;
c) prohibition of unauthorized use of the EAA.
REQ-EAASP-4.2.3.1-02 [CONDITIONAL]: When the EAA Subscriber acts on behalf of a natural or legal person, the
EAASP shall ensure that the EAA Subject has sole control over it, unless national legislation or EAASPol states
otherwise.
4.2.3.2 EUDIW Specific
In addition, when the EAA is issued to a EUDIW the following requirement applies:
REQ-EAASP-4.2.3.2-01: The EAASP shall ensure that issued EAAs can be presented in both proximity flows
(supervised and unsupervised) and remote flows (same-device and cross-device), according to user needs and Relying
Party requirements.
4.2.4 EAA Renewal
4.2.4.1 General
EAA renewal refers to the issuance of a new EAA to the EAA Subscriber without changing the EAA content, except for
the validity period, and public key where present, public key where present, salts hashes, and the issuer signature or
sealDone.
REQ-EAAS-4.2.4.1-01: Requests for renewal of an EAA issued to an EAA Subscriber shall follow the process set out
in the EAAS practice statement.
REQ-EAASP-4.2.4.1-02: The EAASP shall check the validity of the EAA to be renewed and that the information used
to verify the identity and attributes of the EAA Subject is still valid.
4.2.4.2 EUDIW Specific
In addition, when the EAA is issued to a EUDIW the following requirement applies:
REQ-EAASP-4.2.4.2-03 [CONDITIONAL]: The EAASP shall enable the initiation by a EUDIW Instance of a
secured session for re-issuance of attestations issued to this wallet by this EAASP.
4.2.5 EAA Revocation
4.2.5.1 General
REQ-EAASP-4.2.5.1-01: The EAASP shall follow its policies and practices when revoking an EAA.
REQ-EAASP-4.2.5.1-02: The EAASP shall revoke EAA based on authorized and validated EAA revocation requests
as soon as possible and with a delay of no more than 24 hours after the revocation request was received.
REQ-EAASP-4.2.5.1-03: Revocation process shall always be executed under EAASP's control.
ETSI
15 ETSI TS 119 471 V1.1.1 (2025-05)
REQ-EAASP-4.2.5.1-04: An EAASP issuing short-term EAA shall explicitly describe in the EAAS practice statement
which EAA cannot be revoked through a revocation management service and which EAA cannot be revoked even by
the EAASP on its own initiative.
REQ-EAASP-4.2.5.1-05: The EAASP shall revoke any non-expired EAA when:
a) in case of any errors, fraud, or at the request of the EAA Subscriber or EAA Subject; or
b) the EAA is no longer compliant with the EAAS practice statement, EAASPol or EAAP under which it has
been issued; or
c) the EAASP is aware of changes which impact the validity of the EAA; or
d) the EAASP is aware of a security incident that affects the EAA.
REQ-EAASP-4.2.5.1-06: The EAASP shall inform the EAA Subscriber and the EAA Subject, when possible, of a
revoked EAA, of the change of status of the EAA.
NOTE: It may not be possible to inform the EAA Subject for example, when it is an infant, or when is known to
be deceased or otherwise not available to be contacted.
REQ-EAAS-4.2.5.1-07: Once an EAA is revoked it shall not be reinstated.
REQ-EAAS-4.2.5.1-08: When an EAA is revoked, the revocation shall apply from that time to al
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