Comments on and recommendations for the German EUDI wallet architecture relating to cryptographic security

In the document attached I have placed some pointwise comments on and recommendations for the German EUDI wallet architecture:

  • Comment #1 Architecture does not consistently uses eIDAS concepts, most notably the WSCA
  • Comment #2 Architecture does not formulate verifiable (cryptographic) security objectives to be met
  • Comment #3 No analysis/motivation on resistance against high attack potential, e.g. nation states
  • Comment #4: No clarity on whether the D-wallet WSCA should be based on HSM-firmware or not
  • Comment #5: No clarity of the mitigation of “Repudiation Risk”

Each comment is followed by a recommendation. At the end of the document I have placed a section with the references used.

Kind regards, D-wallets_comments_and_recommendations.pdf Eric Verheul 28 July 2025

Edited by Eric Verheul
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