Topic U - EUDI Wallet Trust Mark

Version	Date	Description
`0.1`	21.05.2025	Initial version

GitHub discussion

1. Introduction

1.1 Discussion Paper topic description

This document is the Discussion Paper for European Digital Identity Cooperation Group regarding Topic U: EUDI Wallet Trust Mark.

The European Commission has released a technical specification on the topic, Specification of EUDI wallet Trust Mark, hereafter the [Trust Mark Specification].

Risks TBA

1.3 Key words

This document uses the capitalised key words 'SHALL', 'SHOULD' and 'MAY' as specified in RFC 2119, i.e., to indicate requirements, recommendations and options specified in this document.

In addition, 'must' (non-capitalised) is used to indicate an external constraint, for instance a self-evident necessity or a requirement that is mandated by an external document. The word 'can' indicates a capability, whereas other words, such as 'will' and 'is' or 'are' are intended as statements of fact.

1.4 Document structure

Chapter 2 introduces the legal requirements for EUDI Wallet Trust Mark.
Chapter 3 describes the problem and objectives of this paper, and the existing HLRs on the topic.
Chapter 4 presents the agreed technical specification approach for the EUDI Wallet Trust Mark.
Chapter 5 discusses introduction of new, or update of existing HLRs in the ARF Annex 2 for realisation of the EUDI Wallet Trust Mark UI views in the Wallet Instances.
Chapter 6 lists the additions and changes that will be made to the ARF as a result of discussing this topic with Member States.

2 Legal requirements for EUDI Wallet Trust Mark in Regulation EU 2024/1183

According to Article 3 (50), the EUDI Wallet Trust Mark is defined as "a verifiable, simple and recognisable indication which is communicated in a clear manner that a European Digital Identity Wallet has been provided in accordance with this Regulation.”
According to Article 5a (5)(a) (iv), the Trust Mark must be displayed to the User.
According to Article 5a (8)(a), the Member States shall provide validation mechanisms free-of-charge, in order to: (a) ensure that the authenticity and validity of European Digital Identity Wallets can be verified;
According to the Article 5d, the European Commission publishes the list of certified EUDI Wallets as an official list in the Official Journal of the European Union, thus acting as a reference for which Wallet Solutions are certified. Removal from the list means certification is no longer valid.

3. Problem statement

The purpose of a visible and recognisable trust mark on the EUDI Wallet is to add trust in the EUDI Wallet ecosystem and help the Users to recognise and validate the certification status of the EUDI Wallet Solutions of their EUDI Wallet Provider.

A technical solution exists to verify the certification status of each Wallet Unit before any digital transaction is carried out between the Wallet Unit and its counterparts: the Wallet Unit Attestation, but as a technical and non-visible attestation towards the Wallet Users it doesn't provide the visibility and recognisability wanted. A means to deliver a visible trust mark to the Wallet Unit is therefore to be arranged, and the Users shall be provided means to personally verify the status of the Wallet Solution their Wallet Unit represents.

Neither this discussion paper nor the technical specification is responsible for the visual elements of the EUDI Wallet Trust Mark realisation - responsible entity is a parallel European Commission project that takes input from the Member States and [Trust Mark Specification]. It is stated in the [Trust Mark Specification] that the European Commission is responsible for the EUDI Wallet Trust Mark in terms of graphic design, ownership of the logo registration process and takes responsibility for drafting rules and usage guidelines, and distribution to the designated actors within the ecosystem.

The specification work, which is usually carried out once the HLRs have been defined in the ARF, has already been completed. The Section 3 of the [Trust Mark Specification] specifies the mandatory action-oriented high-level requirements for a simple solution that 1) focuses on providing the EUDI Trust Mark logo only to valid Wallet Instances, and 2) enables the Wallet Provider to equip each Wallet Instance with links to the EU list of certified EUDI Wallets and the individual (certified) Wallet Solution information page underneath the main list. The European Commission will provide the EUDI Wallet Trust Mark graphics elements and will host the Wallet Solution specific content that will be displayed to Wallet Users through a browser window opened from the Wallet Instance upon the User making an deliberate action (e.g. a tap/click of a provided link). Two types of URLs are defined - one to open the page containing the general list of certified EUDI Wallets at the time of reviewing the page, the other that contains information specific to the certified Wallet Solution.

Thus, the purpose of this discussion paper is to clarify which additional high-level requirements, if any, should be brought in as new, or updated in the Annex 2 of the Architecture Reference Framework and what should be stated about the EUDI Wallet Trust Mark in the main text of the ARF based on what has already been agreed for the actual solution to be implemented by the responsible actors in the EUDI ecosystem.

3.1 Existing high-level requirements in the ARF

In the current ARF main text, there is no elaboration on the EUDI Wallet Trust Mark (marked as item for future discussion, i.e. this discussion paper).

Regarding Annex 2 of the ARF, a requirement to render the trust mark is covered in High Level Requirement DASH_09 in [Topic 19] on User navigation requirements (DASH_08 provided here just to bring in the full context):

Index	Requirement specification
DASH_08	For a natural-person User, a Wallet Instance SHALL provide a User interface.
DASH_09	The User interface referred to in DASH_08 SHALL display an EU Digital Identity Wallet Trust Mark complying with technical specifications. Note: The Commission will develop technical specifications for this Trust Mark.

4 Technical specification of the EUDI Wallet Trust Mark

Section 2.1 the [Trust Mark Specification] covers the mandatory part of the EUDI Wallet Trust Mark solution, and the respective requirements for realisation of the solution are covered in Section 3 of the [Trust Mark Specification]. This section covers requirements from the perspectives of the EUDI Wallet Users, the Wallet Providers, the European Commission and the Member States. A few of those requirements may be worth raising in the ARF style of high-level requirements after they have been discussed with the Member States. Section 5 of this discussion paper will cover for this purpose, prior to that a few relevant pieces of the specification are discussed here.

4.1 Solution's actors and expected outcomes

The system architecture for delivery of the specified solution is visualised in the Section 4.2.1 of the [Trust Mark Specification], provided here as a copy for reference:

Trust-Mark-Component-Architecture

Similarly, a copy of the EU Commission and Wallet Provider -side actor descriptions #5-7, #9-11 and #13-14 accompanying the system architecture picture (for complete listing see Section 4.2.2 of the [Trust Mark Specification]) is provided below for convenience:

"The European Commission's responsible unit for the Trust Mark information and listing of certified EUDI Wallets manages that - (5) The EUDI Wallet Trust Mark materials are available online as required behind a web resource (TrustMarkResourceURL) - (6) the certified Wallet Solution is given a WalletSolutionID, information of the Wallet Solution is added to the official list of certified wallets - (7) a Wallet Solution specific information page is created and published online

...

(9) The Wallet Provider is sent information required for configuring the certified Wallet Solution and issuing the Wallet Unit Attestation: the assigned WalletSolutionID, the TrustMarkResourceURL, the ListOfCertifiedWalletsURL, the WalletSolutionInfoPageURL, and (OPTIONALLY) the WalletVerifierToolURL.

...

The Wallet Provider, after receiving the information,
- updates the Wallet Solution asset where needed (10) in order to - (11) be able to render the Wallet Solution specific EUDI Wallet UI view with expected graphics and other information of the Trust Mark.

...

The User can at their discretion - view (13) the official EUDI Trust Mark information from the UI view of the EUDI Wallet, and - (14) access the EUDI Wallet listing and individual Wallet Solution pages."

As such, with these guidelines present the technical specification is clear on how the solution is realised on the system level. It leaves out the definition required for providing 'standard' UI views towards the certification information on a Wallet Unit, as such information (with logo/trust mark graphics and readily localised pieces of information to render) is set for the European Commission to design and release.

5 High-Level Requirements for arranging the EUDI Wallet Trust Mark view in the Wallet Instance User Interface

The Wallet User related requirements EWTM-U4 - EWTM-U10 of the [Trust Mark Specification] contain action oriented requirements that bring in a few implementation aspects (for arranging the Wallet UI views, mostly). These requirements are collected to a table below, and a respective new ARF High-Level Requirement text is proposed on the right column, where such makes sense.

The proposed locations for EUDI Wallet Trust Mark related HLRs in the ARF Annex 2, unless a totally new Topic # is wished for, are Topic 19 on User navigation requirements & transport logs, and Topic 40 on Wallet Instance installation and Wallet Unit activation and management.

The below table is to be evolved via discussions in the focus group meetings. Bolded text are suggested modifications to existing HLRs.

TS Index	TS Requirement	Proposed ARF Index	Proposed ARF Requirement specification
EWTM-U4	As a user of a EUDI Wallet, after installation, I want a means to check that the EUDI Wallet Solution certification is legitimate as part of the EUDI Wallet Instance activation. Note: Certification related information is made available to the EUDI Wallet Unit via the WUA issuance.	WIAM_05	During the activation process of a new Wallet Unit, the Wallet Provider SHALL verify that the new Wallet Instance is a genuine instance of its Wallet Solution and as part of the User onboarding offer the User a means to check the formal certification information of their Wallet Solution.
EWTM-U5	As a User of a EUDI Wallet, I want a means to check on demand if the EUDI Wallet Unit that I am currently using is a Certified EUDI Wallet.	DASH_09	The User interface referred to in DASH_08 SHALL ~~display~~ provide a view with the ~~an~~ EU Digital Identity Wallet Trust Mark and accompanying information of the certification status of the Wallet Solution complying with technical specification provided on the EUDI Wallet Trust Mark. (Original note to be removed.)
EWTM-U6	As a User of a EUDI Wallet, I want to be able to read fresh high-level information of the Certification status when I select (click or tap) a visual indicator (logo) of the EUDI Wallet Trust Mark in the EUDI Wallet Unit.	DASH_13 (New)	The view of DASH_09 SHALL in addition to the Trust Mark provide links to the certification information defined in the technical specification provided on the EUDI Wallet Trust Mark.
EWTM-U7	As a User of a EUDI Wallet, I want the EUDI Wallet Trust Mark to be always positioned in a standard location (such as UI view or menu item) in the EUDI Wallet Unit.	DASH_14 (New)	Positioning of the view of DASH_09 in the Wallet UI navigation should follow provided design guidelines from the European Commission. Note: The information/UI view should probably be offered to the User at first upon Wallet Unit activation (see WIAM_05 in Topic 40) and be located under the 'Settings' or 'About' view or similar of the Wallet Instance. Guidance from the European Commission is expected to the Wallet Providers.
EWTM-U10	As a physically impaired User of a EUDI Wallet, I want to have accessibility support within realisation of the requirements set in EWTM-U4 - EWTM-9. Note: Accessibility considerations from WCAG 2.1 such as screen reader compatibility, color contrast, or keyboard navigation must to be addressed in the end-user implementation and guidelines to be provided. Users with visual impairments, cognitive disabilities, or low digital literacy may face challenges in: - perceiving the Trust Mark (e.g., reliance on visual-only indicators), - understanding certification status (e.g., clarity of meaning in B1-level local language) or - Reacting to certification changes (e.g., what actions should be taken if revoked?)	(N/A)	Note: Expecting a separate future discussion topic on Accessibility within the ARF, suggestion is NOT to define particular accessibility HLR/s for the EUDI Wallet Trust Mark.

6 Additions and changes to the ARF

The ARF does not currently cover the use case details of the EUDI Wallet Trust Mark outside of expecting an implementation according to the European Commission provided specification. If a new use case description with higher level requirements compared to the ones in the specification (see elaboration on the previous Section of this paper), a new describing section for the ARF should contain the nucleus of the use case to provide basic understanding for readers that will not read the [Trust Mark Specification].

6.1 High-Level Requirements to be added

The following High-Level Requirements will be added in Annex 2 Topics 19 an 40 of the ARF:

Final HLRs to be listed after the focus group meetings.

6.2 High-Level Requirements to be changed

The following requirement is modified (changes in bold):

NOTE: There is only one HLR on the topic in the ARF, the DASH_09 of Topic 19 presented in section 2. Topic 40 covers Wallet Provider actions upon Wallet Unit activation and maintenance, where some of the requirements on the Trust Mark could fit, albeit are mostly related to the user interface of the Wallet Instance?

To be added after the focus group meetings.

6.3 Descriptions to be added to the ARF main document

Proposed draft text for the description on the utility of EUDI Wallet Trust Mark:

"According to the [European Digital Identity Regulation] the User needs to be provided a means to verify that they are installing or (after initialisation) are indeed using a trusted, certified EUDI Wallet Solution. The simple solution to arrange aforementioned is a Trust Mark UI view that when invoked in the Wallet Instance renders official trust mark graphics/logo, an informational text about certification localised for User's device language and provides web links to trusted list of EUDI Wallets and the Wallet certification information page of User's Wallet Solution in use. The latter two are hosted and managed dynamically by the European Commission, therefore the use case depends on certain metadata that will be known to the Wallet Provider only when the Wallet certification process has been completed (i.e., the Wallet needs to bypass certification with incomplete - or a test version of the - EUDI Wallet Trust Mark UI view).

The [Trust Mark Specification] concentrates on defining the exact technical contents and the provisioning process to enable the UI view rendering at the Wallet Instance. The Annex 2 Topics 19 and 40 (Editorial note: initial proposed Topics) set the broad requirements as part of the EUDI Wallet Dashboard function and what is required upon Wallet Unit activation and maintenance phases.""

Final texts to be added after the focus group meetings.

7 References

Reference	Description
[WCAG 2.1]	Web Content Accessibility Guide version 2.1
[Trust Mark Specification]	Specification of EUDI Wallet Trust Mark
[Issuance WUA Specification]	Specification of Wallet Unit Attestations (WUA) used in issuance of PID and Attestations