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Formal Comments

formal-comments

We issue formal comments as part of our role as advisor on all matters relating to the procesing of personal data.

Similar to our Opinions, our Formal Comments are issued in response to a request from the European Commission under Article 42(1) of Regulation (EU) 2018/1725 and address the data protection implications of a legislative proposal or a draft implementing or delegated act. Our Formal comments are usually shorter and more technical, or only address certain aspects of a proposal.

 

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6
Jun
2025

Formal comments on the draft Commission Implementing Regulation laying down rules as regards notification of information on certified qualified electronic signature creation devices and certified qualified electronic seal creation devices

EDPS Formal comments on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards notification of information on certified qualified electronic signature creation devices and certified qualified electronic seal creation devices

 

6
Jun
2025

Formal comments on the draft Commission Implementing Decision, as regards the centralised system for the identification of Member States holding conviction information on third-country nationals and stateless persons (ECRIS-TCN).

EDPS Formal comments on the draft Commission Implementing Decision, as regards technical specifications for the quality, resolution and processing of facial images, necessary for the technical development and implementation of the centralised system for the identification of Member States holding conviction information on third-country nationals and stateless persons (ECRIS-TCN).

 

Available languages: English
6
Jun
2025

EDPS Formal comments on the draft Commission Implementing Regulation as regards the format and procedures for notification of intention and verification with regard to the initiation of qualified trust services

EDPS Formal comments on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) No 910/2014 as regards the format and procedures for notification of intention and verification with regard to the initiation of qualified trust services.

6
Jun
2025

EDPS Formal comments on the draft Commission Implementing Regulation as regards the binding of date and time to data and establishing the accuracy of the time sources for the provision of qualified electronic time stamps

EDPS Formal comments on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) No 910/2014 as regards the binding of date and time to data and establishing the accuracy of the time sources for the provision of qualified electronic time stamps.

Available languages: English
6
Jun
2025

EDPS Formal comments on the draft Commission Implementing Regulation as regards reference standards for the verification of the identity and attributes to whom the qualified certificate or the qualified electronic attestation of attributes is to be issued

EDPS Formal comments on the draft Commission Implementing Regulation laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards reference standards for the verification of the identity and attributes of person to whom the qualified certificate or the qualified electronic attestation of attributes is to be issued.