
Where the EUDI Wallet Certification Scheme Stops Short — and Three Changes We Asked For
ENISA’s draft EUDI Wallet certification scheme handles the provider layer cleanly, but the wallet-held decision layer — where eIDAS 2.0 Article 5a user rights actually operate — sits distributed across sections of the Security Requirements rather than named and sequenced as one evaluable surface. This post explains how the scheme already touches the decision layer in pieces, shows the layered architecture, and sets out the three focused asks we submitted before the 30 April 2026 deadline — additions that consolidate the layer without expanding the scheme’s scope.