German EUDI Wallet Ecosystem Governance and Operating Model- ensures centralization, data collection and endangers privacy

Type

General

Summary

Currnt German EUDI Wallet Ecosystem Governance and Operating Model ensures centralization, data collection and endangers privacy, this shall be adjusted or clarified

Version and Section

Current

Feedback / Questions

eIDAS does not contain something like an orchestrator providing centralized website as de facto gatekeeper to certain ecosystem. What´s the legal basement for the gatekeeper in the German EUDI Wallet Ecosystem Governance and Operating Model?

How do you plan to force or convince QTSP to follow this approach as there`s no legal possibility for this? Why should QTSP not connect directly to EUDI Wallet as this will be part of their conformity assessment (and not the part with orchestrator)? How do you handle European, so Non-German QTSP?

How do you ensure that there`s no data collection or surveillance with the orchestrator as seemingly all transactions go via the orchestrator?

Why should Relying Party not connect directly with EUDI Wallet as this is legally defined in eIDAS? Why should RP & QTSP pay for this model as they legally don´t need the orchestrator to interact with the wallet?

How do you avoid breach of Art. 5b eIDAS (Privacy)?