eIDAS Implementation Challenges: The Case of Estonia and the Netherlands

Solid eID (electronic identification) infrastructures form the backbone of today’s digital transformation. In June 2014, the European Commission adopted the eIDAS regulation (electronic identification and trust services for electronic transactions in the internal market) as a major initiative towards EU-wide eID interoperability; which receives massive attention in all EU member states in recent years. As a joint effort of Estonia and the Netherlands, this study provides a comparative case study on eIDAS implementation practices of the two countries. The aim was to analyze eIDAS implementation challenges of the two countries and to propose a variety of possible solutions to overcome them. During an action learning workshop in November 2019, key experts from Estonia and the Netherlands identified eIDAS implementation challenges and proposed possible solutions to the problems from the policy maker, the service provider and the user perspective. As a result, we identified five themes of common challenges: compliance issues, interpretation problems, different practices in member states, cooperation and collaboration barriers, and representation of legal persons. Proposed solutions do not only involve changes in the eIDAS regulation, but different actions to develop an eIDAS framework and to improve cross-border service provision - which has recently become an important topic among member states. Eventually, the study provides practical input to the ongoing eIDAS review process and can help member states to overcome eIDAS implementation challenges.