What Changes with eIDAS 2.0 Regulation for Trust Services

Regulation (EU) 910/2014 (eIDAS) has been the foundation of the European legal framework for electronic signatures, digital identity, and trust services since 2016. In 2025, its revision comes into force: eIDAS 2.0 Regulation, which expands its scope to strengthen security, interoperability, and mutual recognition between Member States.

Beyond the new European Digital Identity (EUDI Wallet), eIDAS 2.0 also introduces adjustments to electronic registered delivery services (ERDS), including registered email.

1. The objective of eIDAS 2.0

The new regulation seeks to consolidate a single market for digital trust services, ensuring that any European citizen or company can:

• Identify and sign electronically with the same level of legal validity throughout the EU.
• Send and receive certified communications between different providers, without loss of traceability or probative value.
• Trust in a common and verifiable framework, based on harmonized technical standards (ETSI, CEN).

In summary, eIDAS 2.0 strengthens cross-border digital trust and lays the foundations for a fully interoperable electronic identity.

2. Strengthening interoperability between providers

One of the objectives of eIDAS 2.0 is to ensure that European trust services can interoperate with each other in a secure and standardized way.

For electronic registered delivery services (ERDS) that operate in closed environments —where both sender and recipient use platforms from different providers—, the new ETSI EN 319 522 standard defines how to exchange certified messages between different providers with traceability and verifiable evidence.

However, this model does not affect services that use conventional email (SMTP) as a delivery channel, such as eEvidence, where the message is delivered directly to the recipient’s email server (for example, Gmail, Outlook, or a corporate server).

In this type of service, interoperability is already guaranteed by the email protocol itself, and the added value lies in the certification of the sending, content, and delivery process, not in the exchange between providers.

3. Impact on electronic registered delivery services (ERDS)

The impact of eIDAS 2.0 on non-qualified ERDS, such as registered email, is mainly positive and clarifying. The new regulation:

• Strengthens the legal security and pan-European recognition of services that provide verifiable technical evidence.
• Promotes technical harmonization that facilitates evidence validation between Member States.
• Does not impose the obligation to interoperate with other providers when the service is based on open infrastructures such as email.

Consequently, eEvidence does not need to modify its technical architecture, since its service fulfills the essential purpose of eIDAS: reliably accrediting the sending, content, and delivery of an electronic communication.

4. Does eIDAS 2.0 affect services that certify conventional emails?

Not directly.

Services that certify emails sent to standard servers (SMTP), such as eEvidence, do not depend on the interoperability framework between providers introduced by ETSI EN 319 522.

The new regulation does reinforce, however, the legitimacy and probative validity of this type of service, by reiterating in its article 43.1 that legal effect or probative value cannot be denied to a non-qualified service simply because it does not appear on a trust list (TSL).

In summary:

• eEvidence already operates within the eIDAS legal framework.
• It does not need to interoperate with other ERDS to guarantee the legal validity of its evidence.
• Its model —based on open standards, technical traceability, and qualified timestamps— naturally aligns with the principles of eIDAS 2.0.

5. European digital identity (EUDI Wallet)

One of the main novelties of eIDAS 2.0 is the creation of the European Digital Identity Wallet (EUDI Wallet): a secure application that will allow citizens and companies to identify and sign electronically throughout the EU.

Although its full implementation will take a few years, the EUDI Wallet will allow:

• Access to public and private services in any EU country.
• Digitally sign documents with a single recognized system.
• Link verified identities to trust services such as advanced signatures or registered email.

6. New recognized trust services

eIDAS 2.0 expands the catalog of regulated trust services, incorporating new types such as:

• Qualified electronic archiving
• Electronic attribute management
• Remote identification and authentication services

This framework opens the door to greater convergence between services, facilitating the automation of legal, contractual, and administrative processes throughout Europe.

7. What doesn’t change: the validity of registered email

The new regulation fully maintains the principle of legal validity of electronically certified communications, whether qualified or not.

Registered email remains a legally admissible means to certify:

• Who sent a message.
• What exact content was transmitted.
• When and to whom it was delivered.

This means that non-qualified services, such as eEvidence, maintain their probative validity throughout the European Union, as long as they provide verifiable technical evidence of the process.

eIDAS 2.0 does not require modifying the architecture or operation of the registered email service, but rather strengthens its fit within the European digital trust ecosystem.

Frequently Asked Questions (FAQ)

What’s the difference between an ERDS and a QERDS?

An ERDS (electronic registered delivery service) offers verifiable technical evidence of sending and delivery. A QERDS (qualified service) additionally meets additional requirements for party identification and is supervised by a national authority.

Can a non-qualified service have legal validity?

Yes. Article 43.1 of eIDAS establishes that no service can be rejected as evidence for not being qualified, as long as it provides verifiable evidence.

Will there be interoperability between providers?

Only for those services that operate in closed networks or need to exchange messages between different providers. Services that use standard email (like eEvidence) are already interoperable by design.

What opportunities does eIDAS 2.0 bring for companies?

It strengthens trust in electronic communications, facilitates pan-European identification, and increases judicial and administrative acceptance of digital evidence.

Conclusion

eIDAS 2.0 Regulation does not change the validity or legal basis of registered email, but strengthens its recognition and fit within the new European digital trust ecosystem.

For services like eEvidence, which certify conventional emails with complete technical traceability, the new regulation represents additional validation of their open and verifiable model, fully aligned with the principles of interoperability, transparency, and security of the European Union.