[cooperation-wg] RIPE NCC Response to Proposed EC Regulation on Electronic ID and Trust Services

Dear colleagues,

At the recent RIPE 66 Meeting, Andrea Servida of the European Commission delivered a presentation on the proposed EU Regulation on electronic identification and trust services for electronic transactions in the internal market. Video, transcript and minutes of the session are available at:
https://ripe66.ripe.net/programme/meeting-plan/coop-wg/

Text of this proposed Regulation is available on the European Commission website:
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:52012PC0238:EN:NOT
[available in various languages and formats]

Based on the RIPE 66 presentation and the discussions that it provoked, the RIPE NCC has identified a number of serious concerns with the proposal, and we believe that the current proposal text may be interpreted in ways that conflict with the basic intent of the Regulation.

Specifically, we believe that the proposal could be interpreted as applying to technologies and services beyond electronic identification (eID) and eID-related trust services, perhaps extending to cover unrelated technologies to eID such as Domain Name Security Extensions (DNSSEC) and Resource Public Key Infrastructure (RPKI). An analysis
about the scope of the proposed Regulation and possible implications can be found at:
https://www.ripe.net/internet-coordination/internet-governance/multi-stakeholder-engagement/eu/analysis-of-the-proposed-eid-regulation/

Such a broad scope for the Regulation could serve to inhibit efforts by the Internet technical community in the EU (often in collaboration with colleagues and counterparts around the world) to secure the infrastructure of the Internet. We also believe that such a broad scope is not the intention of the Regulation.

The RIPE NCC plans to send a letter, detailing our concerns and specific suggestions for edits to the text of the Regulation, to relevant Members of the European Parliament (MEPs), European Commission staff and government officials. A draft of this letter can be found at:
https://www.ripe.net/internet-coordination/internet-governance/multi-stakeholder-engagement/eu/letter-regarding-eid-regulation/

It is important to send this letter quickly to ensure that officials have a chance to reflect on our concerns before committing to a position on the Regulation. With that in mind, we would appreciate any feedback from the RIPE community on the language of the letter, the positions and the strategy. Such feedback may be provided on the Cooperation Working Group mailing list or directly to the RIPE NCC at <ncc at ripe.net>.

We would also welcome any information that community members can provide on MEPs that might have an interest in this issue. We encourage RIPE community members to contact their national MEPs regarding this Regulation, and please feel free to use any or all of the language found in the draft RIPE NCC letter.

Best regards,

Axel Pawlik
Managing Director, RIPE NCC