kSIST-TS FprCEN/TS 18297:2026
(Main)EUDI Wallet Held Assets Access Control, Operation and Management
- Abstract
This document specifies the functionality of the Wallet Unit for Access Control to Wallet Held Assets (WHAs) i.e. personal data relating to the Wallet User and stored in the Wallet Unit. It defines the Wallet Access Control decision Engine (WACE) and the corresponding functional requirements, resulting in recommendations to the user on decision to be made.
This document aims at:
1) describing and specifying an Access Control Model supporting access control to the various possible operations on WHA(s);
2) providing the definitions and classification of the various types of data and metadata, and supporting access control to the various possible operations on WHA(s) ;
3) describing and specifying a W ACE controlling the access to the various possible operations on WHA(s) and the notification returned by the Wallet Access Control Decision Engine to a Wallet Unit;
4) identifying requirements applicable to the Wallet Access Control Decision Engine;
This document also:
- identifies technical specifications and standards that can be used to support the concepts described herein;
- specifies additional requirements for the use of the identified specifications to meet the above objectives;
- provides the missing technical specifications needed to meet the above objectives where needed;
- provides examples and use cases;
The Access Control Model and Wallet Access Control Decision Engine defined in this document aim to comply with the regulator requirements regarding access control.
The following areas are out of the scope of this document:
1) content and encoding of the policies assigned for the disclosure of WHA(s),
2) implementation choice and encoding of Wallet Held Access Control Metadata;
3) encoding of electronic attestation(s) of attributes which are in the remit of ETSI/TC ESI.
- Status
- Not Published
- Public Enquiry End Date
- 22-Dec-2026
- Technical Committee
- ITC - Information technology
- Current Stage
- 5520 - Unique Acceptance Procedure (UAP) (Adopted Project)
- Start Date
- 28-Oct-2026
- Due Date
- 17-Mar-2027
- Completion Date
- 04-Nov-2026
kSIST-TS FprCEN/TS 18297:2026 is a CEN draft Technical Specification for EUDI Wallet Held Assets Access Control, Operation and Management. It specifies how a Wallet Unit controls access to Wallet Held Assets (WHAs), including the Wallet Access Control Decision Engine (WACE), the metadata it uses, and the recommendations or decisions it returns to the user. It is written for wallet implementers, Wallet Providers, PID Providers, issuers, and relying parties that need a common access-control model for EUDI Wallet operations.
What does kSIST-TS FprCEN/TS 18297:2026 specify?
kSIST-TS FprCEN/TS 18297:2026 specifies the access-control functionality for a Wallet Unit when it handles WHAs, meaning personal data relating to the Wallet User and stored in the Wallet Unit. The document focuses on how access is evaluated before an operation is carried out, so implementers can protect disclosure, update, deletion, backup, restoration, and related wallet actions.
The document is organized around a data model, an access-control model, and operational requirements. Clause 5 defines Wallet Held Access Control Metadata, Relying Party Request (RP Request) content, and the difference between policies and instructions. Clause 6 describes the access-control flow for relying parties and for user-initiated operations. Clause 7 contains the normative operational requirements that implementations must meet for conformance.
| Annex | What it covers |
|---|---|
| Annex C | Example implementation material for embedded disclosure policy, WACE action logic scripts, and code examples |
| Annex D | Notification catalogues and default notification text for wallet access-control decisions |
The scope is broad in one important way: the model is intended for any Wallet Unit and any kind of WHA, including Wallet Units that do not claim eIDAS compliance. The document excludes the content and encoding of disclosure policies, the implementation choice and encoding of Wallet Held Access Control Metadata, and the encoding of electronic attestations of attributes that belong to ETSI/TC ESI.
What are the key requirements of kSIST-TS FprCEN/TS 18297:2026?
kSIST-TS FprCEN/TS 18297:2026 makes Clause 7 the conformance point for operational behavior. That means implementers need to look to Clause 7 for the actual requirements, while Clauses 5 and 6 provide the structures and flow logic that those requirements rely on.
Metadata, policies, and request handling
kSIST-TS FprCEN/TS 18297:2026 separates access-control metadata into Policies and Instructions. Policies are meant to be enforced by the Wallet, while Instructions are guidance for the Wallet User when the user must make the decision. In practice, this matters because a wallet may automate policy checks, but still need to present human-readable guidance for consent or refusal.
The document also defines how Wallet Held Access Control Metadata and RP Request data are organized. Clause 5 covers Wallet Held Access Control Metadata, including policies, instructions, data organization, and a mapping to existing structures. It also describes RP Request elements such as relying party authentication, relying party authorizations, processing information notice, Wallet User authentication, and request content and security control.
Access-control flow for relying party operations
For relying party operations, kSIST-TS FprCEN/TS 18297:2026 uses the WACE to evaluate the request before disclosure or another operation is allowed. Clause 6 and Clause 7 together describe the flow: the Wallet Unit checks the WHA, retrieves and evaluates policy data, checks the relying party, and then presents the result to the Wallet User where required.
The operational controls in Clause 7 include verification of WHA validity, policy retrieval and verification, relying party request checking, assessment of the Wallet User authentication level, evaluation of declared conditions of use, validation of relying party role and identifier, and optional checks for pricing and intermediary constraints. In practice, this means the Wallet can decide whether a requester is allowed to see or act on a WHA, and can also recommend that the user deny access when the checks fail.
User decision and wallet response
kSIST-TS FprCEN/TS 18297:2026 requires the Wallet to support a user decision step for relying party operations. The Wallet User can review the recommendation, optionally select which WHAs to share, authenticate when required, and in some cases override the Wallet recommendation if policy allows it. The final wallet response can grant access with conditions or deny access.
This matters because the standard is not just about machine-to-machine authorization. It also defines how the Wallet User is kept in the loop, which is important for privacy, transparency, and informed consent.
User-initiated operations
kSIST-TS FprCEN/TS 18297:2026 also covers user-initiated operations on WHAs, including view, update, deletion, suspension, revocation, sharing, backup, restoration, and reinitialization of authentication factors. Clause 7 distinguishes these from relying party operations and treats them as system-enforced decisions rather than user-overridable recommendations.
In practice, this means a wallet can let the authenticated user manage their own data, but only within the limits of issuer policy, legal obligations, and wallet configuration. The document also covers transaction logs and log sharing, which are part of the user-facing management functions.
Log management and audit
kSIST-TS FprCEN/TS 18297:2026 includes controls for log deletion, log retention, and audit availability. Transaction logs for relying party and user operations are retained for the period set by national law, or at least six months, and must be available to competent authorities on request.
This matters for dispute handling, privacy-rights exercises, and investigations. The log requirements give implementers a clear reason to design traceable audit storage rather than treating logs as temporary debug data.
What terms does kSIST-TS FprCEN/TS 18297:2026 define?
- Wallet Held Asset (WHA) - Personal data relating to the Wallet User and stored in the Wallet Unit, including attributes, attestations, logs, keys, and certificates where applicable.
- Wallet Access Control Decision Engine (WACE) - The Wallet Unit component that processes access-control requests for operations on WHAs and produces the resulting decision or recommendation.
- Relying Party (RP) - An external entity that requests or performs operations on WHAs through the Wallet Unit under access-control rules.
- Relying Party Request (RP Request) - The message sent by the relying party to the Wallet Unit that includes the request to access WHAs.
- Wallet held access control metadata - Access-control metadata stored locally or retrieved dynamically that carries the policies used for access-control decisions.
- Processing information notice - The RP Request data elements that explain purpose, retention period, and related details to help the user make an informed decision.
- Wallet Unit Attestation (WUA) - A verifiable data object that describes the Wallet Unit and supports authentication and validation of its components.
- Wallet User authentication - The process by which the Wallet User proves identity to the Wallet Unit, for example with PIN, biometrics, or device possession, to authorize access to WHAs.
Who uses kSIST-TS FprCEN/TS 18297:2026?
kSIST-TS FprCEN/TS 18297:2026 is used by Wallet Providers, PID Providers, wallet solution developers, and organizations that implement the Wallet Unit or the WACE. It is also relevant to issuers and WHA providers that define the policies, instructions, and metadata attached to WHAs.
Relying Parties use it to understand what checks the Wallet may perform before allowing access to assets, and what kind of user-facing decision they may receive. Quality managers and compliance teams use it to define conformance claims, scope implementation choices, and confirm that logging, user-decision, and metadata handling match the specified model.
The document is especially relevant in the EUDI Wallet ecosystem, where access control must support privacy, transparency, and secure disclosure of personal data.
Which standards are used with kSIST-TS FprCEN/TS 18297:2026?
kSIST-TS FprCEN/TS 18297:2026 normatively refers to two ETSI documents:
- ETSI TS 119 472-3 - Provides profiles for issuance of an Electronic Attestation of Attributes (EAA) or Person Identification Data (PID), which supports the credential side of the wallet model.
- ETSI TS 119 475 V1.2.1:2026 - Defines relying party attributes that support the Wallet User’s authorization decisions, which feeds the RP authentication and RP authorization checks.
Other referenced specifications shape the document’s examples and terminology:
- ISO/IEC 18013-5:2021 - Used in the document’s PID and mobile driving licence examples.
- ISO/IEC TS 27560:2023 - Supports the Processing Information Notice structure and consent-related information.
- ETSI TS 119 476-3 - Supports Wallet Unit Attestation and Wallet Instance Attestation concepts used with selective disclosure and trust binding.
- ETSI TS 119 476-2 - Supports selective disclosure and zero-knowledge proof considerations mentioned for wallet presentation approaches.
- CEN/TS 18098:2026 - Provides onboarding guidance for user PID in European Digital Identity Wallets.
What does the kSIST-TS FprCEN/TS 18297:2026 document contain?
kSIST-TS FprCEN/TS 18297:2026 contains tables, flow descriptions, notification catalogues, and worked examples that support implementation of wallet access control. Table 1 maps Clause 5 topics to the operational controls in Clause 7, and Table 5 classifies WHAs into types T1 to T5 with examples such as PID, wallet-unit-related data, attestations, and transaction logs.
Clause 6 contains the access-control model and step-by-step flows for relying party access and user access. Annex C adds implementation material, including embedded disclosure policy examples, WACE action-logic scripts, a credential-embedded logic model, and code examples in C and Rust. Annex D provides notification catalogues for relying party and user operations, together with default notification text and localisation considerations for wallet user interfaces.
Relations
- Effective Date
- 28-Jan-2026
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Frequently Asked Questions
kSIST-TS FprCEN/TS 18297:2026 is a draft published by the Slovenian Institute for Standardization (SIST). Its full title is "EUDI Wallet Held Assets Access Control, Operation and Management". This standard covers: This document specifies the functionality of the Wallet Unit for Access Control to Wallet Held Assets (WHAs) i.e. personal data relating to the Wallet User and stored in the Wallet Unit. It defines the Wallet Access Control decision Engine (WACE) and the corresponding functional requirements, resulting in recommendations to the user on decision to be made. This document aims at: 1) describing and specifying an Access Control Model supporting access control to the various possible operations on WHA(s); 2) providing the definitions and classification of the various types of data and metadata, and supporting access control to the various possible operations on WHA(s) ; 3) describing and specifying a W ACE controlling the access to the various possible operations on WHA(s) and the notification returned by the Wallet Access Control Decision Engine to a Wallet Unit; 4) identifying requirements applicable to the Wallet Access Control Decision Engine; This document also: - identifies technical specifications and standards that can be used to support the concepts described herein; - specifies additional requirements for the use of the identified specifications to meet the above objectives; - provides the missing technical specifications needed to meet the above objectives where needed; - provides examples and use cases; The Access Control Model and Wallet Access Control Decision Engine defined in this document aim to comply with the regulator requirements regarding access control. The following areas are out of the scope of this document: 1) content and encoding of the policies assigned for the disclosure of WHA(s), 2) implementation choice and encoding of Wallet Held Access Control Metadata; 3) encoding of electronic attestation(s) of attributes which are in the remit of ETSI/TC ESI.
This document specifies the functionality of the Wallet Unit for Access Control to Wallet Held Assets (WHAs) i.e. personal data relating to the Wallet User and stored in the Wallet Unit. It defines the Wallet Access Control decision Engine (WACE) and the corresponding functional requirements, resulting in recommendations to the user on decision to be made. This document aims at: 1) describing and specifying an Access Control Model supporting access control to the various possible operations on WHA(s); 2) providing the definitions and classification of the various types of data and metadata, and supporting access control to the various possible operations on WHA(s) ; 3) describing and specifying a W ACE controlling the access to the various possible operations on WHA(s) and the notification returned by the Wallet Access Control Decision Engine to a Wallet Unit; 4) identifying requirements applicable to the Wallet Access Control Decision Engine; This document also: - identifies technical specifications and standards that can be used to support the concepts described herein; - specifies additional requirements for the use of the identified specifications to meet the above objectives; - provides the missing technical specifications needed to meet the above objectives where needed; - provides examples and use cases; The Access Control Model and Wallet Access Control Decision Engine defined in this document aim to comply with the regulator requirements regarding access control. The following areas are out of the scope of this document: 1) content and encoding of the policies assigned for the disclosure of WHA(s), 2) implementation choice and encoding of Wallet Held Access Control Metadata; 3) encoding of electronic attestation(s) of attributes which are in the remit of ETSI/TC ESI.
kSIST-TS FprCEN/TS 18297:2026 is classified under the following ICS (International Classification for Standards) categories: 33.040.01 - Telecommunication systems in general. The ICS classification helps identify the subject area and facilitates finding related standards.
kSIST-TS FprCEN/TS 18297:2026 has the following relationships with other standards: It is inter standard links to SIST EN ISO 16890-3:2024. Understanding these relationships helps ensure you are using the most current and applicable version of the standard.
kSIST-TS FprCEN/TS 18297:2026 is available in PDF format for immediate download after purchase. The document can be added to your cart and obtained through the secure checkout process. Digital delivery ensures instant access to the complete standard document.
Standards Content (Sample)
SLOVENSKI STANDARD
01-december-2026
Nadzor dostopa, delovanje in upravljanje sredstev v denarnici EUDI
EUDI Wallet Held Assets Access Control, Operation and Management
EUDI Wallet Held Assets Zugangskontrolle, Betrieb und Verwaltung
Ta slovenski standard je istoveten z: FprCEN/TS 18297
ICS:
33.040.01 Telekomunikacijski sistemi Telecommunication systems
na splošno in general
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
FINAL DRAFT
TECHNICAL SPECIFICATION
SPÉCIFICATION TECHNIQUE
TECHNISCHE SPEZIFIKATION
October 2026
ICS
English Version
EUDI Wallet Held Assets Access Control, Operation and
Management
EUDI Wallet Held Assets Zugangskontrolle, Betrieb und
Verwaltung
This draft Technical Specification is submitted to CEN members for Vote. It has been drawn up by the Technical Committee
CEN/TC 224.
CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia,
Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway,
Poland, Portugal, Republic of North Macedonia, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Türkiye and
United Kingdom.
Recipients of this draft are invited to submit, with their comments, notification of any relevant patent rights of which they are
aware and to provide supporting documentation.
Warning : This document is not a Technical Specification. It is distributed for review and comments. It is subject to change
without notice and shall not be referred to as a Technical Specification.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION
EUROPÄISCHES KOMITEE FÜR NORMUNG
CEN-CENELEC Management Centre: Rue de la Science 23, B-1040 Brussels
© 2026 CEN All rights of exploitation in any form and by any means reserved Ref. No. FprCEN/TS 18297:2026 E
worldwide for CEN national Members.
Page
Contents
European foreword . 4
Introduction . 5
1 Scope . 6
2 Normative references . 6
3 Terms and definitions . 7
4 Conformance claim (Normative) . 14
4.1 Applicability of this document . 14
4.2 Items subject to conformance . 14
4.3 Applicable requirements . 14
5 Data Model . 15
5.1 General . 15
5.2 Wallet Held Access Control Metadata. 16
5.2.1 Overview . 16
5.2.2 Policies . 16
5.2.3 Instructions . 20
5.2.4 Data organization . 21
5.2.5 Metadata mapping and reference to existing structures (informative) . 21
5.3 Relying Party Request (RP Request) . 22
5.3.1 Overview . 22
5.3.2 Relying Party Authentication . 22
5.3.3 Relying Party Authorizations (RP Authorizations) . 23
5.3.4 Processing Information Notice . 24
5.3.5 Wallet User Authentication . 25
5.3.6 Relying Party Request data structures. 25
5.3.7 Relying Party Request Content and Security Control . 25
5.4 Aspects which are out of scope . 26
5.5 Considerations relating to the various privacy approaches for presentation of
Wallet Held Asset(s) . 27
6 Access Control Model . 27
6.1 General . 27
6.2 Wallet Held Asset (WHA) . 27
6.3 Access Control Model to WHAs . 28
6.3.1 General . 28
6.3.2 Relying Party access control over WHA . 29
6.3.3 User access control over WHA . 38
7 Wallet access control operational requirements . 46
7.1 General . 46
7.2 Metadata management . 48
7.2.1 CTRL-MTDMG . 48
7.3 RP operations access control . 50
7.3.1 Wallet access control decision . 50
7.3.2 Wallet user decision . 65
7.3.3 Wallet response . 72
7.4 User operations access control . 76
7.4.1 General . 76
7.4.2 User operations overview . 76
7.4.3 Wallet Unit processing . 78
7.4.4 Return the final decision . 80
7.4.5 Execute user operation . 80
7.5 Log Management and User Control . 85
7.5.1 General . 85
7.5.2 CTRL-ULOGD: Log deletion . 86
7.5.3 CTRL-LOG: Log retention and audit . 87
Annex A (informative) Mapping with the eIDAS regulation [1] . 88
Annex B (informative) Risk Analysis Matrix . 89
Annex C (informative) Embedded Disclosure Policy Implementation Example . 91
C.1 General . 91
C.2 Action Logic Scripts . 91
C.3 Examples of coding . 94
C.3.1 General. 94
C.3.2 Example of WACE action logic in C language validating CBOR formatted request
input . 95
C.3.3 Rust Example of WACE action logic validating JSON formatted request input . 97
C.3.4 Rust Example of WACE action logic validating CBOR formatted request input .100
C.3.5 Referencing WACE action logic bytecode from within credentials .103
Annex D (informative) Wallet User Notifications .105
D.1 General .105
D.2 Relationship to Clause 7 requirements.105
D.3 Notifications for RP operations over WHAs .105
D.4 Notifications for User Access Control operations .108
D.5 Language and localisation considerations .109
D.6 Domain-specific notification content .110
D.7 Presentation of detailed reasons for access not granted recommended .110
D.8 Reporting to supervisory authority .110
D.9 Withdrawal of consent .111
D.10 Transaction log recording of notification details .111
Bibliography .112
European foreword
This document (FprCEN/TS 18297:2026) has been prepared by Technical Committee CEN/TC 224,
"Personal identification and related personal devices with secure element, systems, operations and
privacy in a multi sectorial environment", the secretariat of which is held by AFNOR.
This document is currently submitted to the Vote on TS.
Introduction
The eIDAS regulation [1] as amended establishes a common framework for European Digital Identities.
A central new feature is the European Digital Identity Wallet (EUDI Wallet or Wallet) which can be used
to manage various wallet held asset(s) or WHA(s). These WHAs are personal data (as per [2]) relating
to the Wallet User, which can be presented and managed by the Wallet User through the Wallet.
WHAs encompass(es) various types of data and includes (but is not limited to):
— attribute(s) relating to the Wallet User (e.g. PID;
— electronic attestation(s) of attributes of any type including with embedded disclosure policies:
non qualified electronic attestation(s) of attributes, qualified electronic attestation(s) of attributes
or EAAs issued by or on behalf of a public sector body responsible for an authentic source;
— attribute(s) or electronic attestation(s) of attributes relating to the wallet unit;
— transactions log keeping track of the access to the personal data stored in the wallet unit;
— public keys, associated certificates, and key attestations (e.g. proof of association) supporting
cryptographic binding and trust establishment;
NOTE 1 Depending on implementation, Wallet Held Assets (WHAs) can be stored, processed, or accessed by
the wallet unit from locations other than the user’s local device. This includes scenarios where the wallet unit
operates in a cloud-based environment on behalf of the Wallet User. This architectural flexibility allows for
broader scalability, device independence, and policy enforcement, and it applies not only to transaction logs but
to all types of WHAs.
Important aspects of the Wallet are privacy, transparency and security. Security and privacy imply that
the Wallet implements access control before carrying out any operation on WHAs (presentation, view,
update, deletion). For instance, privacy could be compromised by revealing WHAs to Relying Parties
who are not allowed to handle them (e.g. under GDPR [2]). Transparency on the other hand implies that
the Wallet User (1) is empowered with accepting or refusing the fulfilment of any operation on WHAs
and (2) makes informed decision regarding the fulfilment of any operation on WHAs when such decision
is deferred to them.
Access control for the various operations possible on WHAs is needed, namely:
— presentation of one or several WHAs under request of a relying party;
— management of one or several WHAs by the Wallet User through theirwallet unit (view, update,
deletion, backup to and restoration from the wallet provider back end);
— access to one or several WHAs by a relying party (e.g. presentation, revocation).
This access control relies on a wallet access control decision engine (WACE) which is a dedicated sub
component of a wallet unit verifying whether the access can be granted before the wallet unit can
process the operation.
The WACE ensures the Wallet User (1) is empowered with accepting or refusing the fulfilment of the
operation on WHAs and (2) makes wallet access control decision engine regarding the fulfilment of the
operation on WHAs when such decision is deferred to them.
When the operation on WHAs involves a relying party (presentation or management of WHAs), the
WACE also outputs a notification to the relying party containing the decision regarding the fulfilment of
the operation on WHAs. That decision can be that the access is granted, refused, or granted provided the
relying party meets some supplemental conditions;
NOTE 2 In addition to issuers and QTSP/TSP, other parties interacting with the wallet can deliver credentials
or attestations that the user may want to host on their wallet. Access control is needed for the WACE to manage
such operations when e.g. these assets are updated, deleted, etc.
1 Scope
This document specifies the functionality of the wallet unit for Access Control to Wallet Held Assets
(WHAs), i.e. personal data relating to the Wallet User and stored in the wallet unit. It defines the wallet
access control decision engine (WACE) and the corresponding functional requirements, resulting in
recommendations to the user on decision to be made.
This document aims at:
1) describing and specifying an access control model supporting access control to the various
possible operations on WHAs;
2) providing the definitions and classification of the various types of data and metadata, and
supporting access control to the various possible operations on WHAs;
3) describing and specifying a WACE controlling the access to the various possible operations on
WHAs and the notification returned by the wallet access control decision engine to a wallet unit;
4) identifying requirements applicable to the wallet access control decision engine.
This document also:
— identifies technical specifications and standards that can be used to support the concepts
described herein;
— specifies additional requirements for the use of the identified specifications to meet the above
objectives;
— provides the missing technical specifications needed to meet the above objectives where needed;
— provides examples and use cases.
The access control model and wallet access control decision engine defined in this document aim to
comply with the requirements regarding access control laid down in eIDAS [1]. Nevertheless, this
document is applicable to any wallet unit , even those which do not claim compliance with eIDAS [1].
The following areas are out of the scope of this document:
5) content and encoding of the policies assigned for the disclosure of WHAs,
6) implementation choice and encoding of wallet held access control metadata;
7) encoding of electronic attestation(s) of attributes which are in the remit of ETSI/TC ESI.
2 Normative references
The following documents are referred to in the text in such a way that some or all of their content
constitutes requirements of this document. For dated references, only the edition cited applies. For
undated references, the latest edition of the referenced document (including any amendments) applies.
ETSI TS 119 472-3, Electronic Signatures and Trust Infrastructures (ESI); Profiles for Electronic
Attestation of Attributes; Part 3: Profiles for issuance of EAA or PID
ETSI TS 119 475 V1.2.1:2026, Electronic Signatures and Trust Infrastructures (ESI); Relying party
attributes supporting EUDI Wallet user's authorization decisions
3 Terms and definitions
For the purposes of this document, the following terms and definitions apply.
ISO and IEC maintain terminology databases for use in standardization at the following addresses:
• ISO Online browsing platform: available at http://www.iso.org/obp
• IEC Electropedia: available at http://www.electropedia.org/
3.1
access control model
conceptual framework that defines the processes, roles, data structures, and decision logic governing
how access to wallet held asset (3.25)(s) (WHAs (3.25)) is granted, denied, or made conditional within a
wallet unit (3.32)
Note 1 to entry: An access control model describes the steps and components required to evaluate access requests
to WHAs (3.25), including the role of the wallet access control decision engine (3.23) (WACE), relevant policies,
metadata (3.8), relying party (3.16) requests, and user decisions.
Note 2 to entry: This document defines an access control model applicable to operations involving both relying
parties and the Wallet User, covering actions such as presentation, update, deletion, and management of WHAs
(3.25).
3.2
attribute
authorization, quality, right or permission of a natural or legal person or of an object
Note 1 to entry: This includes also attribute from the PID (3.10) set (each individual items from the PID (3.10)) as
defined in eIDAS regulation [1].
Note 2 to entry: This definition is drawn from [1].
3.3
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 or object and that is considered to be a
primary source of that information or recognized as authentic in accordance with Union or national law,
including administrative practice
Note 1 to entry: Authentic Sources are sources for attributes on, for instance, address, age, gender, civil status,
family composition, nationality, education and training qualifications titles and licences, professional
qualifications titles and licences, public permits and licences, or financial and company data. https://eu-digital-
identity-wallet.github.io/eudi-doc-architecture-and-reference-framework/latest/architecture-and-reference-
framework-main/
3.4
credential
evidence or testimonials that support a claim of identity or assertion of an attribute (3.2) and usually
are intended to be used more than once
[SOURCE: Committee on National Security Systems, CNSSI No. 400Ctrl9, Committee on National Security
Systems (CNSS) Glossary, April 6, 2015. Unclassified.]
3.5
certificate policy
named set of rules that defines the applicability of a certificate to a particular community or class of
applications with shared security requirements
Note 1 to entry: A certificate policy is used to indicate the level of assurance, scope of usage, and expected
trustworthiness of a certificate issued within a specific trust framework.
Note 2 to entry: Certificate policies are defined and maintained by certificate authorities and trust service
providers. They can be referenced in certificate extensions and interpreted by relying parties to inform
authorization decisions.
Note 3 to entry: Certificate policies are specified in ETSI EN 319 411-1 [3] and ETSI EN 319 411- 2 [4], which
defines requirements for trust service providers issuing qualified and non-qualified certificates.
3.6
electronic attestation of attributess
EAA
EAAs
attestation in electronic form that allows the authentication of attributes
Note 1 to entry: This definition is drawn from [1] Article 3.
3.7
embedded disclosure policy
set of rules, embedded in an EAAs by its provider, that indicates the conditions that a Wallet relying
party (3.16) has to meet to access the EAAs
Note 1 to entry: This definition is drawn from the draft implementing regulation taken for implementation of
Article 5a(23) of eIDAS Regulation [1].
3.8
metadata
data that provides information about attributes, but not the content of the attribute (3.2)
[SOURCE: Wikipedia - https://en.wikipedia.org/wiki/Metadata#cite_note-1 ]
3.9
personal data
information relating to an identified or identifiable natural person (‘data subject’); an identifiable
natural person is one who can be identified, directly or indirectly, in particular by reference to an
identifier such as a name, an identification number, location data, an online identifier or to one or more
factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that
natural person
Note 1 to entry: In this document, personal data are typically represented as Wallet Held Assets (WHAs) managed
by the Wallet User and may be subject to selective disclosure, access control, and transaction logging.
Note 2 to entry: In this document, PII is often represented as Wallet Held Assets (WHAs (3.25)) managed by the
Wallet User, and may be subject to selective disclosure, access control, and transaction logging.
[SOURCE: Regulation (EU) 2016/679, Article 4(1) [5]]
3.10
person identification data
PID
credential (3.4), (1) containing the set of person identification data, (2) demonstrating that the PID
provider (3.11) vouches for their integrity and authenticity and their binding with the wallet unit (3.32)
and the User, and (3) that is verifiable
Note 1 to entry: This definition is drawn from the CIR (EU) 2024/2979 [6].
Note 2 to entry: Within this document, person identification data (PID) designates a credential (3.4) containing
one or several data from the person identification data as described by eIDAS Article 3(3) and further refined by
the implementing act . This definition differs from the meaning of person identification data (PID) as provided for
in eIDAS Article 3(3) and further refined by the implementing act, which designates the set of data comprising
person identification data.
Note 3 to entry: Person identification data (PID) is a technical representation of one or several data from the
person identification data (PID) as defined by eIDAS Article 3(3) and further refined by the implementing act. PID
can be of different formats (e.g. SD-JWT or MSO with mdoc as per ISO/IEC 18013-5:2021 [7]).
Note 4 to entry: Throughout this document there is not differentiation between the person identification data
(PID) of a natural person or the one of a legal person.
3.11
PID provider
natural or legal person responsible for issuing and revoking the person identification data and ensuring
that the person identification data of a user is cryptographically bound to a wallet unit
Note 1 to entry: This definition is drawn from the CIR (EU) 2024/2979 [6].
Note 2 to entry: The PID provider is the entity responsible for (1) ensuring PID (3.10) uniquely represents a person
(natural or legal) and (2) issuing the PID (3.10) (s) into the wallet unit (3.32) of a Wallet User authorized to present
the PID (3.10) of that person.
[SOURCE: CEN/TS 18098:2026 [8]]
3.12
processing information notice
data elements from the RP Request (3.20) that specifies purpose, retention period and other elements
that assist the user to make an informed decision to grant access or deny access to the wallet held assets
(WHA (3.25))
Note 1 to entry: Processing information notice may be encoded in natural language or machine readable language
(ex ISO/IEC TS 27560:2023 [9]).
[SOURCE: ISO/IEC TS 27560:2023 [9]]
3.13
public issued EAA
EAAs (EAAs (3.6)) issued by a public sector body that is responsible for an authentic source (3.3) or by
a public sector body that is designated by the Member State to issue such attestations of Attributes on
behalf of the public sector bodies responsible for authentic sources in accordance with Article 45f and
with Annex VII of [1]
Note 1 to entry: eIDAS Article 3(3) defines “person identification data” as “set of data that is issued in accordance
with Union or national law and that enables the establishment of the identity of a natural or legal person, or of a
natural person representing another natural person or a legal person”.
Note 2 to entry: With in this document, PID is a technical representation of one or several data from the person
identification data (PID) as defined by eIDAS Article 3(3). Therefore, for the same set of person identification data
as defined by eIDAS Article 3(3), there may be one or several PID(s), each being characterized for instance by (1)
its format (e.g. MSO with mdoc as per ISO/IEC 18013-5:2021 [7]), (2) the number and combination of person
identification data as defined by eIDAS Article 3(3) it contains, or (3) the granularity of the information (e.g. year
of birth, month of birth, etc.). The set of person identification data as defined by eIDAS Article 3(3) may be
contained in a single credential, or scattered across several credentials.
Note 3 to entry: Throughout this document there is not differentiation between the person identification data
(PID) of a natural person or the one of a legal person.
3.14
qualified certificate
qualified certificate for electronic signature, qualified certificate for electronic seal or qualified
certificate for website authentication (QWAC).
Note 1 to entry: These types of certificates are defined in eIDAS Regulation [1].
3.15
qualified electronic attestation of attributes
QEAA
QEAAs
EAAs, which is issued by a qualified trust service provider and meets the requirements laid down in [1]
Annex V
Note 1 to entry: This definition is drawn from [1] Article 3.
3.16
relying party
RP
RPs
external entity that interacts with the Wallet Unit to request and receive, or perform operations on
Wallet Held Assets (WHAs), based on access control policies and metadata
Note 1 to entry: A Relying Party may act in different roles, including as a verifier, credential issuer, or a trusted
service provider. Regardless of role, all such entities are subject to the same access control enforcement process
defined in this specification.
Note 2 to entry: This definition is drawn from [1] Article 3.
Note 3 to entry: This definition expands on the narrower use of “Relying Party” in ETSI TS 119 475 V1.2.1:2026
[10], which assumes a verifying role. In the context of Wallet Access Control, issuers and service providers may
also operate as Relying Parties when accessing WHAs or invoking Wallet-controlled operations.
3.17
relying party access to special WHAs category
situation in which a Relying Party requests access to Wallet Held Assets (WHAs) that include or relate
to special categories of personal data (see 3.17), which may require enhanced protection measures
according to applicable policy or regulation
Note 1 to entry: Such requests can require enhanced Wallet User authentication, selective disclosure, or issuer-
enforced policies (e.g. Embedded Disclosure Policies) before access is granted.
Note 2 to entry: Examples of special category WHAs include health-related data, biometric identifiers, or personal
information associated with increased privacy or security risk when not properly protected.
Note 3 to entry: The designation of special category WHAs is determined by the data issuer or attribute provider
through Wallet Held Access Control Metadata or other configured policies. The Wallet does not inherently classify
services as critical or sensitive.
3.18
relying party authentication
means by which a Relying Party proves its identity to the Wallet Unit using an Access Certificate as
defined by applicable regulation (e.g. CIR (EU) 2024/2979 [6])
Note 1 to entry: The Wallet User retains the ability to control whether a Relying Party Request is accepted,
depending on how the Wallet evaluates the authentication outcome.
Note 2 to entry: The Access Certificate enables the Wallet Unit to authenticate the origin of a Relying Party Request
before allowing access to Wallet Held Assets (WHAs).
Note 3 to entry: The Access Certificate typically contains information such as the RP identifier, domain, and in
some implementations, the session or specific request is cryptographically bound to the certificate authority chain.
3.19
relying party authorizations
RP Authorizations
attributes of a Relying Party which characterize the very nature of the Relying Party
Note 1 to entry: RP Authorizations encompass various information, such as its identification, its role, its
entitlements, its sector, the identification of its certification authority, etc.
Note 2 to entry: RP Characteristics may according to ETSI TS 119 475 V1.2.1:2026 [10] be role or other attributes.
3.20
relying party request
RP Request
message sent from the Relying Party to the Wallet Unit which includes a request to access WHAs
3.21
sensitive personal data
special categories of personal data that require enhanced protection due to their sensitive nature, as
defined in Article 9(1) of the GDPR
Note 1 to entry: These include data revealing racial or ethnic origin, political opinions, religious or philosophical
beliefs, trade union membership, genetic or biometric data, health data, or data concerning a natural person’s sex
life or sexual orientation.
Note 2 to entry: In this document, such data may be classified as Wallet Held Assets (WHAs) subject to stricter
access control and disclosure limitations. Such classification is up to WHA's provider and depends on their policy
and jurisdictional context. Accordingly, the designation of personal data as sensitive may be reflected in associated
metadata or policy requiring enhanced protection measures.
[SOURCE: GDPR Article 9(1)]
3.22
critical service
service (aka critical) provided by a Relying Party of which the consequence incurred by the wallet user
may be severe or harmful in case of impersonation attack, and thus requiring strong authentication and
user binding of the presented credentials
Note 1 to entry: Metadata configured by their issuer(s) indicates that some assets are subject to highest care
(security, privacy) before being disclosed. It depends on (1) the attribute, (2) the RP domain or authorizations or
registration attestation, (3) the transaction purpose, (4) the risk incurred by the user in case of misuse of such
data. A standard cannot define what “sensitive personal data” are but the issuer can do ; it is part of metadata
configuration (see example given in Annex C).
3.23
wallet access control decision engine
WACE
component of the Wallet Unit in charge of processing the access control request to an operation on a
WHA
Note 1 to entry: An access control decision engine ensures the Wallet User is empowered with accepting or
refusing the fulfilment of the operation on WHAs and makes an informed decision regarding the fulfilment of the
operation on WHAs when such a decision is deferred to them.
3.24
wallet held access control metadata
access control metadata that may be locally stored or dynamically retrieved and that features the
policies fir access control to WHAs
Note 1 to entry: Wallet held access control metadata is also known as wallet held metadata in this document.
3.25
wallet held asset
WHA
WHAs
personal data relating to the Wallet User and stored in the Wallet Unit
Note 1 to entry: WHAs encompass(es) various types of data and includes but is not limited to:
— attribute(s) relating to the Wallet User (e.g. PID );
— electronic attestation(s) of attributes of any type including with embedded disclosure policies:
Non-qualified electronic attestation(s) of attributes, qualified electronic attestation(s) of attributes or EAAs issued
by or on behalf of a public sector body responsible for an authentic source;
— attribute(s) or electronic attestation(s) of attributes relating to the Wallet Unit;
— transactions log keeping track of the access to the personal data stored in the Wallet Unit;
--- pseudonym;
— keys and certificates.
Note 2 to entry: Pseudonyms can be generated/renewed with some randomization whereby they are dynamic
assets that might not be part of WHAs as they are computed on-demand within the wallet.
3.26
wallet held asset policy manager
entity responsible for defining, managing, or updating access control–relevant policies and metadata
associated with a WHA, including but not limited to embedded disclosure policies (EDP)
Note 1 to entry: Access control–relevant policies may include disclosure conditions, usage constraints, assurance
requirements, pricing conditions, or other issuer-defined restrictions associated with a WHA.
3.27
wallet held metadata management interface
interface exposed by the Wallet Unit and/or the WACE through which authorized parties (WHA
Providers, Wallet Provider, authenticated Wallet User) may perform lifecycle operations on wallet held
access control metadata, namely provisioning, updating, deleting and reading
3.28
wallet unit attestation
WUA
WUAs
data object that describes the components of the wallet unit or allows authentication and validation of
those components
Note 1 to entry: This definition is drawn from the CIR (EU) 2024/2979 [6].
Note 2 to entry: A Wallet Unit Attestation is a credential identifying a Wallet Unit, demonstrating that the Wallet
Provider vouches for the (1) security, (2) trustworthiness of that Wallet Unit and (3) the binding between that
Wallet Unit and the User, and that is verifiable.
Note 3 to entry: ETSI TS 119 476-3 [11] further specifies the Wallet Unit Attestation as comprising one Wallet
Instance Attestation (WIA), attesting the integrity and authenticity of the wallet instance, and one or more Wallet
Key Attestations (WKA), attesting properties of cryptographic keys stored in the Wallet Unit's key storage. The
Wallet Unit Attestation is a device-and-key security attestation, not a user identity credential."
3.29
wallet provider
natural or legal person who provides wallet solutions
Note 1 to entry: This definition is drawn from the CIR (EU) 2024/2979 [6].
Note 2 to entry: The wallet provider is the entity that is responsible for provisioning and managing one or more
Wallet Solution and Wallet.
3.30
wallet solution
combination of software, hardware, services, settings, and configurations, including wallet instances,
one or more wallet secure cryptographic applications (WSCA) and one or more wallet secure
cryptographic devices (WSCD)
Note 1 to entry: This definition is drawn from the CIR (EU) 2024/2979 [6].
3.31
wallet unit trust attestation
WUTA
credential (1) describing the properties - including the security properties - of the Wallet Solution, the
Wallet Instance, the device on which it is installed and the WSCD, (2) containing the information
allowing to cryptographically bind PID and attestation of any kind to the Wallet Unit, (3) for which the
Wallet Provider vouches and (4) which is verifiable
Note 1 to entry: A Wallet Unit Trust Attestation (WUTA) is a Credential.
Note 2 to entry: The Wallet Unit Trust Attestation (WUTA) is a part of the Wallet Unit Attestation (WUA).
Note 3 to entry: The WUTA forms part of the WIA component of the WUA as decomposed in ETSI TS 119 476-3
[11](subject to confirmation once ETSI TS 119 476-3 [11] is stable).
[SOURCE: CEN/TS 18098:2026 [8]]
3.32
wallet unit
unique configuration of a wallet solution that includes wallet instances, wallet secure cryptographic
applications and wallet secure cryptographic devices provided by a wallet provider to an individual
wallet user
Note 1 to entry: This definition is drawn from the CIR (EU) 2024/2979 [6].
Note 2 to entry: A Wallet Unit includes any installed software which is part of an EUDI Wallet Solution, whether it
is installed on the User's device or on a server.
Note 3 to entry: In the case part of the Wallet Solution is installed on a server, despite there will be a single
installation on the server, each User will be associated to a unique configuration (containing its credentials, keys,
etc.) which then consists as the corresponding part of the Wallet Unit.
3.33
(wallet) user
natural person who is in control of the wallet unit
Note 1 to entry: In the context of this document, the User is the User of the Wallet Unit and is only one allowed to
use the PID(s) contained in the Wallet Unit. It may [RA1] not necessarily be the PID’s Subject.
Note 2 to entry: The User is the one allowed to use the PID(s) contained in the Wallet Unit. It is not necessarily the
PID’s Subject.
[SOURCE: CEN/TS 18098:2026 [8]]
3.34
wallet user authentication
process by which the Wallet User proves their identity to the Wallet Unit, using one or more
authentication factors (e.g. PIN, biometrics, possession of device), in order to authorize access to Wallet
Held Assets (WHAs)
Note 1 to entry: This process supports user approval, prevents impersonation, and can include generation of
cryptographic proof for binding the user to the WHAs.
Note 2 to entry: The Wallet Unit can enforce different assurance levels depending on the nature of the requested
WHAs, the Relying Party request, or policies defined in Wallet Held Metadata.
3.35
wallet held asset provider
relying party delivering Credentials to the user
Note 1 to entry: This can be for example a trust service provider, a qualified trust service provider, Wallet Provider
or PID Provider.
4 Conformance claim (Normative)
4.1 Applicability of this document
The Access Control Model described in this document and the corresponding requirements are generic
and can be applied to any operation on any kind of Wallet Held Assets (WHAs). In addition, it can be
applied to any kind of Wallet Unit, including those which do not comply with eIDAS regulation [1].
4.2 Items subject to conformance
This document defines conformance requirements for both the Wallet Unit and the Wallet Access
Control Decision Engine (WACE). Implementers may choose to claim conformance for one or both
components.
Implementations may also limit their conformance claim to specific types of Wallet Held Assets (WHAs)
and specific operations, provided that this scope is explicitly stated in the conformance declaration.
— A Wallet Unit that implements the WACE-based process to enforce Access Control over operations
on WHAs. A Wallet Unit is not mandated to support WACE, as WACE is intended as an EUDI Wallet
extra-functionality to enhance access control operations by the use of configurable metadata
determining further or specific PID Providers’ policies.
— the Wallet Access Control Decision Engine (WACE), an implementation-agnostic component of
the Wallet Unit in charge of processing the Access Control over operations on WHAs. The WACE
can either be a built-in functionality of the Wallet Unit, or a standalone application possibly
implemented in a variety of languages (see examples in Annex C). This document provides
description of the features of the WACE, its interfaces with the Wallet Unit, the data structure its
processes and the related requirements.
Nevertheless, this compliance may be limited to one or several WHAs and/or one or several operation(s)
on this(these) WHAs.
The comp
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