Specification of Common Interface for reporting of Relying Parties to Data Protection Authorities

Verified on 2026-10-29


Specification of Common Interface for reporting of Relying Parties to Data Protection Authorities

Abstract

The present document specifies the common protocols and interfaces according to Article 5a (5) (a) (x) of (EU) No 910/2014 used by a Wallet Unit for reporting a Wallet-Relying Party to the competent national Data Protection Authority where an allegedly unlawful or suspicious request for data is received.

Licensing and Reuse

© European Union, 2025-2026.

This document is made available under the Creative Commons Attribution 4.0 International licence (CC BY 4.0), unless otherwise stated.

You may reuse this document provided that appropriate credit is given and any changes are indicated.

The full licence text is available at https://creativecommons.org/licenses/by/4.0/ .

Versioning

VersionDateDescription
0.12025-05-27Initial version for first discussions.
0.22025-06-12Update after first discussions.
0.92025-06-22Update after second focus meeting.
0.102025-07-16Minor editorial update and templates for subject and body of email.
0.112026-01-30Editorial update (licensing and reuse clarification)
1.02026-08-12Final Version.

Notational Conventions

The key words "MUST", "MUST NOT", "REQUIRED", "SHALL", "SHALL NOT", "SHOULD", "SHOULD NOT", "RECOMMENDED", "NOT RECOMMENDED", "MAY", and "OPTIONAL" in this document are to be interpreted as described in "Key words for use in RFCs to Indicate Requirement Levels" RFC2119. The interpretation should only be applied when the terms appear in all capital letters.

1. Introduction

The present document specifies the common protocols and interfaces according to Article 5a (5) (a) (x) of (EU) No 910/2014 used by a Wallet Unit for invoking a suitable external application, such as a browser or an email client, to report a Wallet-Relying Party (WRP) to the competent national Data Protection Authority (DPA) where an allegedly unlawful or suspicious request for data is received.

The general approach with respect to the protocols and interfaces specified in the present document are based on the result of the related discussions documented in the corresponding L+M-Discussion-Paper.

2. Requirements

2.2 High-Level Requirements

The set of high-level requirements after the discussions documented in the L+M-Discussion-Paper and the two focus meeting for the present specification, which added RPT_DPA_07, RPT_DPA_08 and RPT_DPA_09 are as follows:

IndexRequirement specification
RPT_DPA_01When prompted by the User, a Wallet Unit SHALL use the available contact details of the DPA available in the supervisory_authority field of the wallet-relying party registration certificate and SHALL make it easy for the User to send a report of allegedly unlawful or suspicious Relying Party presentation requests to this DPA.
RPT_DPA_02The user interface enabling a User to start the process of reporting a Wallet-relying Party to a DPA SHALL be accessible via the log provided by the Wallet Unit.
RPT_DPA_04Wallet providers SHALL ensure that wallet units allow wallet users to substantiate the reports, including by attaching relevant information to identify the wallet-relying parties, and the wallet users’ claims in machine-readable format.
Note: The log kept by the Wallet Unit is machine-readable and specified in TS10 in order to enable data portability. An excerpt from this log therefore can be used to substantiate the report.
RPT_DPA_05A Wallet Unit SHALL log the initiation of a report sent to the DPA in a log file so that it can be presented to the User in the dashboard (as specified in Topic 19 and TS10).
RPT_DPA_06The contact information for the DPA in the supervisoryAuthority field SHALL include at least one of infoURI, email or phone.
RPT_DPA_07aIn case of email the Wallet Unit SHOULD invoke a mail client available on the platform of the User with a mailto: link and the text in the subject of the mail prepared by the Wallet Unit according to RPT_DPA_06 SHALL clearly indicate that the purpose of the mail is to report a WRP to the DPA and state that an allegedly unlawful or suspicious request for data has been received.
RPT_DPA_07bIn case of infoURI the Wallet Unit SHOULD invoke a browser available on the platform of the User.
RPT_DPA_07cIn case of phone the Wallet Unit SHOULD invoke a phone application available on the platform of the User.
RPT_DPA_08The text in the subject of the mail prepared by the Wallet Unit according to RPT_DPA_06 SHOULD indicate the identity of the WRP and also an involved intermediary, if applicable, which sent the allegedly unlawful or suspicious request.
RPT_DPA_09The text in the body of the mail prepared by the Wallet Unit according to RPT_DPA_06 SHALL contain the necessary information to identify the WRP and also an involved intermediary, if applicable, and allows that the request can be handled by the DPA in an efficient manner.

Note, that recommended templates for the subject and body of the mail according to RPT_DPA_07a, RPT_DPA_08 and RPT_DPA_09 are provided in Section 3.3 below.

3. Specification of Protocols and Interfaces

3.1 System Architecture

As agreed upon within the discussions documented in the L+M-Discussion-Paper the general approach is to utilise the already existing interfaces and processes of the competent national data protection authorities as much as possible and abstain from the creation of additional technical interfaces.

The resulting system architecture is depicted in the following figure:

Overview

3.2 Interfaces

As shown in the figure above, there are the following interfaces:

  • (I1) - is a user-friendly user interface, which allows to access the functionality of the Wallet Unit and which in particular allows to report a WRP from which an allegedly unlawful or suspicious request for data has been received to the competent national DPA, or to another DPA chosen by the User. This functionality shall be immediately accessible when such a request has been received or later based on the information stored in the Transaction Log. Wallet Units shall allow Users to substantiate the reports by attaching relevant information to identify the WRP and the requested claim names in machine-readable format. The technical details of this format will be derived from the normalised format of the transaction log, which will be specified based on the related discussions within the H-Discussion-Paper.

  • (I2) - is a platform-specific interface, which allows to invoke a browser on the platform to open a specific URL of the DPA in charge of supervising the WRP, which has submitted an allegedly unlawful or suspicious request.

  • (I3) - represents a logical interface provided by the web application of the competent national DPA responsible for the supervision of the WRP at the given URL contained in the supervisory_authority.infoURI contained in the wallet-relying party registration certificate according to ETSI TS 119 475 V1.2.1 (2026-03) (Table 7).

  • (I4) - is a platform-specific interface, which allows to invoke a mail client on the platform of the User with a mailto: link with the email address supervisory_authority.email contained in the wallet-relying party registration certificate according to ETSI TS 119 475 V1.2.1 (2026-03) (Table 7).

  • (I5) - represents a logical interface given by the mail system of the DPA, which is assumed to exist, if the wallet-relying party registration certificate according to ETSI TS 119 475 V1.2.1 (2026-03) (Table 7) contains supervisory_authority.email.

  • (I6) - is a platform-specific interface, which allows to invoke the phone application of the platform in order to call the competent national DPA.

  • (I7) - is the phone system of the DPA, which SHALL exist, if there is only supervisory_authority.phone number included in the wallet-relying party registration certificate.

3.3 Recommended templates for the subject and the body in (I4)

It is RECOMMENDED to use the following template for the subject of the email prepared in (I4) and mentioned in RPT_DPA_07a and RPT_DPA_08:

Reporting an allegedly unlawful or suspicious request received from commonName

It is RECOMMENDED to use the following template for the body of the email prepared in (I5) and mentioned in RPT_DPA_09:

Dear Ladies and Gentlemen,
we have received a request from commonName, which seems to be
suspicous and potentially unlawful. Therefore we kindly ask you to
have closer look at the received request provided as attachment of
the present mail and consider to take further actions, if deemed appropriate.
Thank you very much in advance for your efforts.
Best Regards

Here, the parameter commonName is the common name from the wallet-relying party access certificate according to EN 319 412-3 (clause 4.2.1), as specified in ETSI TS 119 475 V1.2.1 (2026-03) (Table 1).

3.4 Process

The process for reporting a WRP to the competent national DPA where an allegedly unlawful or suspicious request for data has been received is completely analogous to the process for requesting the deletion of data at a WRP according to TS7, where the essential difference is that in this case the contact information of the DPA is extracted from the supervisory_authority element in the wallet-relying party registration certificate before the corresponding application (i.e. browser, mail client or phone application) on the platform of the User is invoked. In addition to the subject and the body of the pre-filled mail, there may also be an attachment with the request from the WRP as specified in RPT_DPA_04.