Updated version of EBW definition, version 1.1 by stavamichal · Pull Request #281 · webuild-consortium/wp4-architecture

stavamichal · 2026-07-30T19:47:23Z

Based on issue Scope and Context: Regulatory Alignment (EC Proposal & EP Amendments) update #236
Added information based on last known proposed Regulation of European Council on EBW from 9th June, 2026
Added challanges and open topics we do know so far
Added References to mentioned facts

Saramandus · 2026-08-07T08:20:26Z

-This document draws on the EUDI Wallet regulations, EWC deliverables<sup><sup>[\[1\]](#footnote-0)</sup></sup>, and relevant industry and consortium publications, and incorporates the draft Implementing Act on Business Wallet.
+This document draws on the EUDI Wallet regulations, EWC deliverables [\[6\]](#references), and relevant industry and consortium publications. Its main legal reference is the text of the proposed Regulation on the establishment of European Business Wallets as agreed in the Council’s general approach of 9 June 2026, published as Council document 10346/26 [\[2\]](#references), read together with the original Commission proposal COM(2025) 838 [\[1\]](#references) and the European Parliament ITRE rapporteur’s draft report [\[3\]](#references).
+
+### Legislative status


Suggest addition to section 2.2 in the Blueprint instead.

As requested, I have moved the legislative status to 2.2 in commit 44e1785

Saramandus · 2026-08-07T08:21:16Z

+
+Where this document cites Articles, Recitals or the Annex without further qualification, it refers to the Council general approach text.
+
+## Purpose of the European Business Wallet


Suggest this to be merged into either chapter 1.1 "Background" or 2.2 "EBW framework"

I was looking into chapters 1, 2 and 3 and I didn't find any right place where the description of EBW purpose would fit better. To be honest, IMHO believe that this particular text should stay in Business Wallet Definition. I have shorten it in f9050b3 If you insist that this is not a good place for it, I would rather remove it instead of moving it somewhere else.

Saramandus · 2026-08-07T08:28:42Z

+1. Authorisations in the wallet are **technical**. They do not create, limit or otherwise affect any power of attorney or legal mandate under national or Union law (Article 5(1)(j), Recital 18).
+2. The authorisation system should remain compatible with the EU digital power of attorney established by Directive (EU) 2025/25 (Recital 18).
+
+### Relationship with the EUDI Wallet


I would suggest streamlining this text a bit, Passages discussing Recital 4 precedence (where the EBW Regulation takes precedence over ARF in case of inconsistency) or the ITRE draft report's non-operative architectural directions are better placed in the main body.

The high-level framing of how the EBW "builds on and complements" the eIDAS framework is already (partially at least) covered in Section 2.2 of the main Blueprint.

The functional interaction patterns fits nicely here though;

Distinction: Natural persons (EUDI) vs. Legal persons (EBW).

Authentication: How the EUDI Wallet is used to "unlock" or operate the EBW.

Hybrid Roles: How sole traders bridge the two worlds.

Makes sense to me, I have simplified it in e5f27d5

Saramandus · 2026-08-07T08:30:33Z

+    class EBW businessWallet
+```
+
+### Key terminology


The Blueprint has a glossary. Add the missing words to that glossary instead and suggest changes if you think it differs.

Removed and the glossary updated where needed in 1717203

Saramandus · 2026-08-07T08:32:49Z

+| Provider of EBW-OID | A qualified trust service provider, a public sector body responsible for an authentic source, or the Commission (for Union entities). |
+| Critical assets | Assets within or in relation to a wallet unit whose compromise would have a very serious, debilitating effect on the ability to rely on that unit (Article 3(27)). |
+
+## Legal effect: the principle of equivalence


Should also be moved, to section 2.2 on "The EBW Framework".

This principle is a cornerstone of the Regulation's legal mandate and provides the necessary context for why public sector bodies must accept EBW-based actions and belong in the main document. Moving it keeps Appendix D focused on being a lean, functional reference for our development teams.

As requested, the principle of equivalence has been moved to section 2.2 via bd1ece7

Saramandus · 2026-08-07T08:45:28Z

Thank you @stavamichal for the suggested update and all the work you have put into this! While the updated content provides important clarity, I have some concerns regarding the formatting and placement of this text within Appendix D and would like to suggest some updates:

Removal of Legal Citations: The inline references to specific Articles and Recitals (e.g., Article 5(1), Recital 25) are not standard for the Blueprint and make the text difficult to digest. Since these legislative texts are still in draft, including them everywhere risks making the Appendix outdated very quickly. I suggest removing these specific citations to maintain a clean, stable architectural reference.
Regulatory vs. Functional Content: Appendix D is defined as a 'non-technical working definition'. Much of the proposed update covers regulatory justifications (the 'why') and legal mandates. These belong in Chapter 2 (Regulatory and Foundational Alignment), which is the established home for our legal anchoring
Streamlining for Readability: We want to keep the Blueprint and its appendices simple and easy to read, with as little text as possible to make sure that our consortium members actually read it without being scared off by walls of text. ;) I believe the suggested text is currently too long and repetitive across the different subtitles. For example, the relationship with the EUDI Wallet and the active participant role are mentioned multiple times.

Proposal for the Section:

Consolidate the "Description": Keep the functional improvements (such as the shift to the 'Active Participant' role and the Article 5 functional list) but strip out the legislative jargon and citations
Relocate "Purpose" and "Legal Effect": Move these subsections entirely to Chapter 2.2, as they define the legal mandate rather than the functional identity of the wallet
-Refocus "Relationship with EUDI": Streamline this to the three functional points we need for implementation: the distinction of users (natural vs. legal), the authentication flow, and the exception for sole traders

The purpose of moving the regulatory 'weight' to the main body is to ensure Appendix D remains a lean, practical reference for our capability and use case teams.

stavamichal · 2026-08-10T08:09:33Z

@Saramandus Thanks for all the comments, we will process them as soon as possible.

- Based on issue webuild-consortium#236 - Added information based on last known proposed Regulation of European Council on EBW from 9th June, 2026 - Added challanges and open topics we do know so far - Added References to mentioned facts

stavamichal · 2026-08-10T13:34:57Z

I have removed unnecessary citations in 9d4a986

stavamichal · 2026-08-10T13:57:25Z

@Saramandus I have made few changes as you suggested. Please, let me know if this is more suitable as Annex document of EBW for D4.1. Thank you!

Saramandus

I think this is a good update to both the vocabulary and the Regulatory and foundational alignment chapter.

stavamichal requested a review from a team July 30, 2026 19:47

stavamichal mentioned this pull request Jul 30, 2026

Scope and Context: Regulatory Alignment (EC Proposal & EP Amendments) update #236

Open

Saramandus requested review from Saramandus, eklaver, malinnorlander and sander August 3, 2026 09:55

Saramandus reviewed Aug 7, 2026

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Saramandus requested changes Aug 7, 2026

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Updated version of EBW definition, version 1.1

e425120

- Based on issue webuild-consortium#236 - Added information based on last known proposed Regulation of European Council on EBW from 9th June, 2026 - Added challanges and open topics we do know so far - Added References to mentioned facts

stavamichal force-pushed the ms_update_ebw_definition branch from 897ecfc to e425120 Compare August 10, 2026 08:42

Šťava Michal added 6 commits August 10, 2026 13:52

Moving the legislative status to section 2.2

44e1785

Shorten the purpose of the EBW

f9050b3

Simplify the text describing relationship of EBW with EUDIW

e5f27d5

Move key terminology (where needed) to glossary

1717203

Move the article describing principle of equivalence to section 2.2

bd1ece7

Remove unnecessary citations and simplifie some text

9d4a986

Remove the semi-duplicit section of roles in the EBW context

35fb704

stavamichal requested a review from Saramandus August 10, 2026 13:55

Saramandus added Blueprint EBW labels Aug 11, 2026

Saramandus approved these changes Aug 21, 2026

View reviewed changes


		Where this document cites Articles, Recitals or the Annex without further qualification, it refers to the Council general approach text.

		## Purpose of the European Business Wallet

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Saramandus commented Aug 7, 2026

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