In short
The Regulation does not impose the same obligations on everyone. A relying party registers before relying on the wallet Art. 5b(1); a provider that wants to become qualified goes through a conformity assessment and through the supervisory body Art. 21(1); an attestation issuer follows rules that depend on the kind of attestation Art. 45h Art. 45d Art. 45f; finally, where a Member State requires electronic identification to access an online public service, it also accepts the wallet Art. 5f(1). For each of these four profiles, this step offers a starting guide.
Steps 1 to 6 explain the framework. This last step reads it again from where you stand: which obligations target you, which texts to read first, what to check. It also contains a fourth register, Asphalia advice: boxes on method, priorities and pitfalls, written by Asphalia. These boxes are not law; the obligations they mention are still followed by their reference.
What is your profile?
| Profile | You are… | What concerns you first | Guide |
|---|---|---|---|
| Relying party | a natural or legal person that relies on electronic identification, a wallet or a trust service Art. 3(6) | registration before relying on the wallet, and the data you may request Art. 5b(1) Art. 5b(3) | relying party |
| Provider wanting to become qualified | a trust service provider that wants to provide a qualified trust service Art. 3(20) | the notification of intention, the conformity assessment report and inclusion in the trusted list Art. 21(1) Art. 21(3) | qualified provider |
| Attestation issuer | a provider of electronic attestations of attributes, qualified (QEAA), public (PuB-EAA) or non-qualified (EAA) Art. 3(45) Art. 3(46) Art. 3(16)(g) | the requirements specific to your kind of attestation and issuance to wallets Art. 45g | attestation issuer |
| Public service | a public sector body that provides online services Art. 5f(1) | acceptance of the wallet and of notified identification means, recognition of signatures and seals Art. 5f(1) Art. 6(1) Art. 27 Art. 37 | public service |
Roles can be combined. An attestation provider identifies itself to wallet units with its wallet-relying party access certificate Art. 4(2), a certificate issued only to registered relying parties Art. 7(2). The register of wallet-relying parties also provides for the entitlements of provider of qualified, non-qualified or public attestations, and an indication of whether the relying party is a public sector body Annex I. So read all the guides that concern you.
The diagram starts from what you do. If you rely on the wallet, you are a relying party and you register Art. 3(6) Art. 5b(1). If you want to provide a qualified trust service, you notify your intention with a conformity assessment report, then you are audited at least every 24 months Art. 21(1) Art. 20(1). If you issue attestations, the rules depend on their kind Art. 45d Art. 45f Art. 45h. If you offer an online public service that requires electronic identification, the Member State also accepts the wallet Art. 5f(1). The bottom band recalls the combination of roles described above Art. 4(2) Annex I.
Dates of application to know
Several implementing regulations do not apply as soon as they enter into force. The table reproduces the dates that the texts set, without calculating any.
| Text | Subject | Applicable from | Profiles concerned |
|---|---|---|---|
| Implementing Regulation 2025/1572 | Notification of intention and verification before the start of a qualified service | 19 August 2026 Art. 5 | qualified provider |
| Implementing Regulation 2025/1569 Art. 6 to Art. 9 | List of issuing public bodies, catalogues of attributes and of attestation schemes, verification against authentic sources | 19 August 2026 Art. 11 | attestation issuer, public service |
| Implementing Regulation 2025/848 | Registration of wallet-relying parties | 24 December 2026 Art. 11 | relying party, attestation issuer, public service |
| Implementing Regulation 2025/846 | Cross-border identity matching of natural persons by public sector bodies | 24 December 2026 Art. 1 Art. 6 | public service |
| Implementing Regulation 2026/1735 Art. 1(3) | Amendment of the verification of attributes against authentic sources (mechanism complying with Annex IV, signed or sealed result) | 1 January 2027 Art. 1(3) Art. 2 | attestation issuer, public service |
| Implementing Regulation 2025/2527 | Qualified certificates for website authentication | 6 January 2027 Art. 2 | qualified provider |
| Implementing Regulation 2026/248 Art. 1(1) Art. 3(1) | Advanced signature and seal formats recognised by the Member States that require them | 23 February 2027 Art. 6 | public service |
| Implementing Regulation 2025/1566 | Verification of identity and attributes before the issuance of a qualified certificate or a qualified attestation | 19 August 2027 Art. 2 | qualified provider, issuer of qualified attestations |
| Implementing Regulation 2025/1567 | Remote management of qualified signature and seal creation devices | 19 August 2027 Art. 2 | qualified provider |
| Regulation 910/2014, acceptance of the wallet by certain private relying parties | Period counted from the entry into force of the implementing acts on the wallet and its certification | thirty-six months after that entry into force Art. 5f(2) | relying party |
The other wallet deadlines are presented in step 3.
A four-stage method
Asphalia advice
A four-stage method.
- Identify your roles. Start from your actual activities, not from titles. A single organisation can be a relying party, an issuer of attestations and a customer of a qualified provider. Each role has its own obligations.
- Map the obligations. For each role, list the articles of the Regulation and the implementing acts that target you, with their date of application. The guides in this step serve as a starting point.
- Measure the gaps. Compare each obligation with your existing processes: risk management, information security, data protection, change management. Many requirements tie in with them; few start from scratch.
- Plan. Rank the gaps by deadline and by effort, appoint an owner for each, and plan a review with each new implementing act or corrigendum.
Asphalia advice
The most common pitfalls.
- Working on the ARF as if it were mandatory. The ARF (version 3.0.0 in this corpus ARF 3.0.0) describes itself as informative § 1.3 Purpose, scope and audience: start from the Regulation and the implementing acts, and use the ARF to understand the architecture.
- Reading a replaced text. Regulation 910/2014 was substantially amended in 2024 Art. 1; several implementing acts have already been amended or corrected. Work on the consolidated version and check the corrigenda.
- Believing that a cited standard applies in full. An act may target only certain clauses, or adapt them; step 5 shows how to read it.
- Forgetting deferred dates of application. An act in force is not always applicable: see the table above.
- Ignoring the national level. Supervisory body, register of relying parties, trusted list: these pieces are national. Make enquiries early with the authorities of your State.
In Belgium
In Belgium
Situation checked in the corpus on 30-10-2026.
A supervisory body set up within FPS Economy is responsible for supervising trust service providers Art. I.18 Art. XV.26(2). In Belgium, the guide for a provider that wants to become qualified therefore points to this body. The Belgian situation (supervisory body, trusted list, FPS BOSA, CCB) is detailed in step 6.
No source in the corpus, consulted on 30-10-2026, designates the Belgian registrar of wallet-relying parties, which each Member State must designate Art. 3(3).
Consolidation without official value
This step cites the consolidated versions, published on EUR-Lex, of Regulation 910/2014 and Implementing Regulations 2024/2977, 2025/848 and 2025/1569 Regulation (EU) No 910/2014 — consolidated version of 18/10/2024 Implementing Regulation (EU) 2024/2977 — consolidated version of 11/08/2026 Implementing Regulation (EU) 2025/848 — consolidated version of 11/08/2026 Implementing Regulation (EU) 2025/1569 — consolidated version of 11/08/2026, as well as the Code of Economic Law in its consolidated version Code of Economic Law, Book XII, Title 2 (Art. XII.24-XII.39) + Art. I.18, XV.25-26, XV.123. These consolidations are documentation tools: only the Official Journal of the European Union and the Belgian Official Gazette (Moniteur belge) are authentic.
Key points
- Your obligations depend on your role, and roles can be combined Art. 4(2) Annex I.
- A relying party registers before relying on the wallet Art. 5b(1).
- A qualified provider starts only once its status is included in the trusted list Art. 21(3).
- The rules for an attestation issuer depend on the kind of attestation Art. 45d Art. 45f Art. 45h.
- Several acts apply only in 2026 or 2027 Art. 11 Art. 2.
Written by Asphalia.