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142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.1 Data Act | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.1.1 Essential Overview | In addressing the definition of a Smart Contract, the following objectives can be derived directly from the definition in Regulation (EU) 2023/2854 [i.1] "a computer program used for the automated execution of an agreement or part thereof, using a sequence of electronic data records and ensuring their integrity and the accuracy of their chronological ordering" and the wider application of that definition to that of a contract "an agreement that is intended to be enforceable by law and to the execution of a contract "the process of finalizing a legally binding contractual agreement between two or more parties and committing to the terms contained within that contract". 1) The automated execution of an agreement, or part thereof, represents the intended agreement of the parties. 2) The parties of the agreement can be correctly identified in case of legal dispute. 3) The recording of the sequence electronic records representing the agreement is maintained in a way which ensures their integrity and the accuracy of their chronological ordering. 4) A party of an agreement cannot later deny the agreement. 5) Privacy of sensitive information is maintained. This can include information in the data records and identities the parties of the agreement. The elements defined in the Data Act can be bound to a governance framework for identity (see Regulation (EU) 2024/1183 [i.2] to enable strict conformance to item 2). In addition, it is recognized that Smart Contracts are, implicitly, required to be transparent and explicable, arising from both items 1 and 2 above wherein the parties are able to agree that the Smart Contract is the intended agreement of the parties. It is noted that the identities of the parties to the agreement are only required to be identified by 3rd parties in the case of legal dispute and in accordance with item 5 it is reasonable to treat the identity of parties to the agreement as private. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.1.2 Terminology | Smart Contracts, Electronic Ledgers. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.1.3 Chain of Trust | Regulation (EU) 2023/2854 [i.1] is agnostic with respect to the Chain of Trust, and in particular with the production of Smart Contracts. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.2 eIDAS2 | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.2.1 Essential Overview | The Electronic Identification, Authentication, and Trust Services Regulation (eIDAS) was first published in 2014 to provide a standardized framework across the European Union for electronic identification (eID), electronic signatures, and trust services. The aim was to enable secure and seamless digital transactions across EU member states. The eIDAS2 Regulation [i.2], published in 2024, amends the original regulation, addressing some of its limitations and introducing significant new features to adapt to the evolving digital landscape. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 17 While eIDAS laid the foundation for cross-border digital identification and trust services in the EU, Regulation (EU) 2024/1183 [i.2] significantly expands and modernizes the framework. The key innovation is the European Digital Identity Wallet (EUDIW), which gives citizens more control over their personal data, enhances security, and ensures that both the public and private sectors embrace digital identities. This evolution reflects the increasing need for secure, user-controlled, and interoperable digital solutions across Europe. eIDAS2 does not address Smart Contracts in solo, but a Smart Contract as defined by the Data Act [i.1] may use elements of eIDAS2 [i.2] such as Electronic Ledgers that are cited in the Data Act. eIDAS2 regulation defines Electronic Ledgers as given below. The definition of Electronic Ledgers in Article 3: "(52) "electronic ledger" means a sequence of electronic data records, ensuring the integrity of those records and the accuracy of the chronological ordering of those records;" This definition matches the definition of Smart Contracts in Regulation (EU) 2023/2854 [i.1] for the use of: "a sequence of electronic data records and ensuring their integrity and the accuracy of their chronological ordering"; Section 11, Article (45k) defines the legal effects of Electronic Ledgers: "1. An electronic ledger shall not be denied legal effect or admissibility as evidence in legal proceedings solely on the grounds that it is in an electronic form or that it does not meet the requirements for qualified electronic ledgers. 2. Data records contained in a qualified electronic ledger shall enjoy the presumption of their unique and accurate sequential chronological ordering and of their integrity." and Article (45l) defines following specific requirements for Qualified Electronic Ledgers: "(a) they are created and managed by one or more qualified trust service providers; (b) they establish the origin of data records in the ledger; (c) they ensure the unique sequential chronological ordering of data records in the ledger; (d) they record data in such a way that any subsequent change to the data is immediately detectable, ensuring their integrity over time." |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.2.2 Terminology | Electronic Ledgers. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.2.3 Chain of Trust | Regulation (EU) 2024/1183 [i.2], as per the publication date of the present document, is agnostic with respect to the Smart Contracts and the Chain of Trust. This can change in the forthcoming eIDAS2 Implementing Acts. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.3 GDPR | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.3.1 Essential Overview | The General Data Protection Regulation (GDPR) [i.7] is a comprehensive legal framework established by the European Union to safeguard the personal data of individuals within the EU. It sets stringent rules for data privacy, ensuring that personal data is collected, processed, and stored with a high degree of transparency, security, and accountability. Regulation (EU) No 2016/679 [i.7] applies to all organizations that handle the personal data of EU residents, regardless of the organization's location, and imposes significant penalties for non-compliance. Smart Contracts can potentially support Regulation (EU) No 2016/679 [i.7] compliance by providing automated, transparent, and secure mechanisms for handling personal data, aligning with the regulation's requirements. One of the key ways Smart Contracts can assist is by automating consent management. They can store and track user consent in a tamper-proof manner on a ledger ensuring transparency and that personal data is only processed in accordance with the ETSI ETSI TR 119 540 V1.1.1 (2025-10) 18 agreed-upon terms. This automation can include limiting data usage to specific purposes and ensuring consent is periodically updated or revoked, when necessary, all of which enhances compliance with Regulation (EU) No 2016/679 [i.7] focus on individual control over personal data. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.3.2 Terminology | Not applicable. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.3.3 Chain of Trust | Regulation (EU) No 2016/679 [i.7] is agnostic with respect to Smart Contracts, Electronic Ledgers and the Chain of Trust. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.4 UNCITRAL model law on automated contracting | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.4.1 Essential Overview | The UNCITRAL Model Law [i.20] provides a legal framework to enable the use of automation in international contracts, including through the deployment of artificial intelligence techniques and Smart Contracts, as well as in machine-to-machine transactions. It is intended to complement and supplement existing laws on electronic transactions, in particular those based on other UNCITRAL electronic commerce texts, which have been enacted in over one hundred jurisdictions worldwide. The Model Law is the first legislative text to result from exploratory work conducted by UNCITRAL on legal issues related to the digital economy and digital trade, with work on data contracts and distributed ledger technology as described in ISO 22739 [i.3]. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.4.2 Terminology | Smart Contracts. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.2.4.3 Chain of Trust | The UNCITRAL Model Law [i.20] is agnostic with respect to the Chain of Trust. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3 Standardization | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.1 ISO/TC 307 | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.1.1 Essential Overview | The scope of ISO/TC 307 reads: "standardisation of blockchain technologies and distributed ledger technologies". Blockchain technology holds immense promise to revolutionize not only the financial domain, but a whole host of things from societal inclusion to efficiencies in government, health and all areas of business. ISO/TC 307, blockchain and distributed ledger technologies, has been set up to meet the growing need for standardization in this area by providing internationally agreed ways of working with it to improve security, privacy and facilitate worldwide use of the technology through better interoperability. This is especially relevant due to the number of enterprises, across various sectors, that are developing blockchain and distributed ledger technologies as a product. The standardization work of ISO/TC 307 has been divided into six groups, namely Foundations (WG1), Security, privacy and identity (WG2), Smart Contracts and their applications (WG3), Use cases (WG4); Governance (WG5), and Interoperability (WG6). The need for collaboration and cooperation has been identified and ISO/TC 307 is liaising with other organizations like ETSI (namely ETSI TC ESI, TC DATA), ISO and IEC committees, as well as external organizations, to minimize any overlap. ISO/TC 307 produced (among many) the following standard specifications and technical reports: ISO 22739 [i.3], ISO/TS 23635 [i.15], ISO 23257 [i.19], and ISO 24332 [i.21]. ISO 22739 [i.3] defines a vocabulary for Blockchain and distributed ledger technologies; ISO/TS 23635 [i.15] defines guidelines for governance defined blockchain and distributed ledger technologies. ISO 23257 [i.19] defines a reference architecture for distributed ledger technology systems including blockchain systems. The reference architecture addresses concepts, cross-cutting aspects, architectural considerations, and architecture views, including functional components, roles, activities, and their relationships for blockchain and distributed ledgers. ISO 24332 [i.21] analyses ETSI ETSI TR 119 540 V1.1.1 (2025-10) 19 challenges, considerations, and potential benefits of blockchain and distributed ledger technology in relation to records management standards and related standards for systems that create records that are required to be authoritative records; can be used as records systems; or can be used for records management, including records controls. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.1.2 Terminology | Smart Contracts and distributed ledgers as defined in ISO 22739 [i.3]. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.1.3 Chain of Trust | ISO 22739 [i.3], ISO/TS 23635 [i.15], and ISO 23257 [i.19] are agnostic with respect to the Chain of Trust. However, ISO/TC 307 in ISO/TS 23635 [i.15] discuss some trust requirements on (qualified) DLT systems. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.2 CEN/CENELEC/JTC 19 | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.2.1 Essential Overview | CEN/CLC/JTC 19 "Blockchain and distributed ledger technologies" was established based on the recommendations presented in the CEN-CENELEC White Paper [i.28] in 2018 on distributed and ledger technologies. It works in close contact with ISO/TC 307 "Blockchain and distributed ledger technologies". It established the following WGs with the given scope and work items: WG1 (development of standard for policy and security requirements for trust services providing Electronic Ledger services; standardization on functional and interoperability requirements for decentralized identifier and decentralized identity management where distributed ledger is only one possible infrastructure), WG2 (environmental and sustainability classification methodology of consensus mechanisms of blockchain and distributed ledger technologies); WG3 (development of standards for privacy in distributed ledger technologies to ensure compliance to GDPR [i.7] requirements). CEN/CLC/JTC 19 adopted ISO TC 307 vocabulary [i.3] directly into European Framework. CEN/CLC/JTC 19 considers ISO TC 307 documents [i.15], [i.19], and [i.21] as relevant basements for the CEN Project on Policy and security requirements for trust services providing ledger services and are so participating to a European standard framework for Electronic Ledgers. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.2.2 Terminology | Distributed ledgers and Smart Contracts as defined in ISO 22739 [i.3]. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.2.3 Chain of Trust | The technical body CEN/CENELEC/JTC 19 "Blockchain and Distributed Ledger Technologies" is agnostic with respect to the Chain of Trust. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.3 ETSI ISG PDL | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.3.1 Essential Overview | The ETSI Industry Specification Group on Permissioned Distributed Ledger (ETSI ISG PDL), at the time of the publication of the present document, conveyed into the new ETSI TC DATA, analyses and provides the foundations for the operation of permissioned distributed ledgers, with the ultimate purpose of creating an open ecosystem of industrial solutions to be deployed by different sectors, fostering the application of these technologies, and therefore contributing to consolidate the trust and dependability on information technologies supported by global, open telecommunications networks. The group puts its focus on addressing infrastructure and operational aspects that are not currently covered by previous or parallel standardization activities. In addition to that, ETSI ISG PDL fosters industry convergence towards shared standards with the intent of avoiding duplication and contradicting publications. The ETSI ISG PDL started from already available experiences in the field of permissioned distributed ledgers, seeking for the definition of open and well-known operational mechanisms to validate participant nodes, support the automation of the lifecycles of the ledger and individual nodes, publish and execute operations regarding the recorded transactions ETSI ETSI TR 119 540 V1.1.1 (2025-10) 20 through Smart Contracts, improve security of distributed ledgers during both their design and operation and establish trusted links among different distributed ledgers using these mechanisms. ETSI ISG PDL has been active since 2019 and has produced the following completed deliverables Group Report (GR) and Group Specifications (GS) to date ETSI TR 104 173 [i.22], ETSI TS 104 172 [i.23], ETSI GR PDL 001 [i.35], ETSI GR PDL 002 [i.36], ETSI GR PDL 003 [i.37], ETSI GR PDL 004 [i.38], ETSI GS PDL 005 [i.39], ETSI GR PDL 006 [i.40], ETSI GR PDL 008 [i.41], ETSI GR PDL 009 [i.42], ETSI GR PDL 010 [i.43], ETSI GS PDL 011 [i.44], ETSI GS PDL 012 [i.45], ETSI GS PDL 013 [i.46], ETSI GR PDL 014 [i.47], ETSI GS PDL 015 [i.48], ETSI GR PDL 017 [i.49], ETSI GR PDL 018 [i.50], ETSI GR PDL 019 [i.51], ETSI GR PDL 020 [i.52], ETSI GR PDL 021 [i.53], ETSI GS PDL 022 [i.54], ETSI GS PDL 023 [i.55], ETSI GS PDL 024 [i.56], ETSI GS PDL 025 [i.57], ETSI GS PDL 026 [i.58], ETSI GS PDL 027 [i.59], ETSI GS PDL 028 [i.60], ETSI GS PDL 029 [i.61], ETSI GS PDL 030 [i.62], ETSI GS PDL 031 [i.63], ETSI GS PDL 032 [i.64], ETSI GS PDL 033 [i.65]. Amongst the published documents, Smart Contracts were presented in ETSI GR PDL 004 [i.38], ETSI GS PDL 011 [i.44], ETSI GS PDL 033 [i.65], distributed ledgers and interoperability and all data issues in ETSI TR 104 173 [i.22], ETSI GR PDL 006 [i.40], ETSI GR PDL 009 [i.42], ETSI GR PDL 010 [i.43], ETSI GS PDL 012 [i.45], ETSI GS PDL 013 [i.46], ETSI GR PDL 018 [i.50]; trust, identity, and repudiation issues in ETSI GR PDL 014 [i.47], ETSI GR PDL 019 [i.51], ETSI GS PDL 023 [i.55], ETSI GS PDL 027 [i.59], ETSI GS PDL 030 [i.62], network issues in ETSI GR PDL 020 [i.52], ETSI GS PDL 022 [i.54] ETSI GS PDL 024 [i.56], ETSI GS PDL 025 [i.57], ETSI GS PDL 027 [i.59]; IoT, AI, and energy issues in ETSI GS PDL 028 [i.60], ETSI GS PDL 031 [i.63], ETSI GS PDL 032 [i.64]; reputation, settlement and Digital Autonomous Organizations in ETSI GS PDL 015 [i.48], ETSI GS PDL 026 [i.58], ETSI GS PDL 029 [i.61]. The guidelines for governance of Smart Contracts executed on a blockchain and distributed ledgers and in support for eIDAS2 [i.1] trust services were discussed in ETSI GR PDL 017 [i.49]. These publications provide a roadmap for how Smart Contracts can be used to automate and secure transactions, ensure compliance with European regulations and facilitate cross-border interoperability. The emphasis is on creating secure, scalable, and compliant Smart Contracts that can be used in a variety of industries, ranging from finance to healthcare, all within the highly controlled environments of permissioned ledgers. As per ETSI ISG rules, ISG PDL cannot produce normative recommendations, only surveys, reference architectures, proof of concepts, and can suggests guidance. The heritage of the produced documents will convey into normative recommendations within the new ETSI TC DATA (e.g. ETSI TR 104 173 [i.22] and ETSI TS 104 172 [i.23]). |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.3.2 Terminology | Electronic Ledgers, distributed ledgers and Smart Contracts as defined in ISO 22739 [i.3]. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.3.3 Chain of Trust | ETSI ISG PDL (at the time of the publication of the present document) is agnostic with respect to the Chain of Trust. This will change in the future within the new ETSI TC DATA. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.4 ITU-T X-Series Recommendations Study Group 17 | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.4.1 Essential Overview | ITU-T X is a series of standards from the Standardization Sector the International Telecommunication Union (ITU-T), written by ITU-T Study Group 17. The description of the X series is: "Data networks, open system communications and security". The group produced a number of documents. In a nutshell: • Recommendation ITU-T F.751.0 [i.29] Requirements for Distributed Ledger Systems. • Recommendation ITU-T F.751.8 [i.30] Technical framework for distributed ledger technology (DLT) to cope with regulation. • Recommendation ITU-T X.1401 [i.31] Security threats to distributed ledger technology. • Recommendation ITU-T X.1402 [i.32] Security framework for distributed ledger technology. • Recommendation ITU-T X.1403 [i.33] Security guidelines for using distributed ledger technology for decentralized identity management. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 21 • Recommendation ITU-T X.1412 [i.34] Security requirements for smart contract management based on the distributed ledger technology. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.4.2 Terminology | distributed ledgers as defined in Recommendation ITU-T F.751.0 [i.29], Smart Contracts as defined in Recommendation ITU-T X.1412 [i.34]. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.4.3 Chain of Trust | ITU-T X Study Group 17 is agnostic with respect to the Chain of Trust. However, Recommendation ITU-T X.1412 [i.34] contains some interesting intuitions on security requirements for Smart Contracts management based on the distributed ledger technology. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.5 IEEE SA P2418 | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.5.1 Essential Overview | 4.3. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.1 Essential Overview | IEEE Standards Association (IEEE-SA): the IEEE is working on developing blockchain and distributed ledger standards through the P2418 working group. They focus on areas such as digital asset management, blockchain for supply chains, and Smart Contracts. There are multiple standardized distributed ledger technologies, each with its specific features and applications. The choice of DLT depends on the use case, such as financial services, supply chain, IoT, or decentralized applications. These DLTs are often developed under open-source projects or standardized by international bodies like ISO and IEEE, ensuring that they adhere to global standards for security, privacy, and interoperability. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.5.2 Terminology | None. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.3.5.3 Chain of Trust | The IEEE SA P2418 working group did not publish any document. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.4 Projects, Programs and Initiatives | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.4.1 Digital Europe Program | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.4.1.1 Essential Overview | The Digital Europe Program (DIGITAL) is an EU initiative designed to accelerate the integration of digital technologies into businesses, public administrations, and society. DIGITAL aims to enhance Europe's digital resilience by supporting projects in key areas like supercomputing, artificial intelligence, cybersecurity, and digital skills. This program is instrumental in reducing Europe's dependence on external digital solutions and strengthening the EU's digital infrastructure and capabilities. DIGITAL supports industry, enterprises and fosters digital transformation across various sectors through initiatives. The program aligns with the EU's broader goals outlined in the 2030 Digital Compass and works in synergy with other EU funding mechanisms, including Horizon Europe and the Connecting Europe Facility, as part of the Multiannual Financial Framework 2021-2027. The Digital Europe Program funds several projects focused on acceleration of eIDAS, EUDI Wallet and related trust services but also distributed ledgers, and Smart Contracts ISO 22739 [i.3] used for several use cases e.g.: • Large Scale Pilots on EUDI Wallet • Projects on the European Blockchain e.g.: ETSI ETSI TR 119 540 V1.1.1 (2025-10) 22 - EBSI VECTOR - OnePass - EBSI-NE - TRACE4EU • Projects for support of Standardization: - Blockstand - Seeblock |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.4.1.2 Terminology | Smart Contracts and distributed ledgers as defined in ISO 22739 [i.3]. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.4.1.3 Chain of Trust | Digital Europe Program, as per the publication date of the present document, is agnostic with respect to the Chain of Trust. This can change in the future. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.4.2 EBSI | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.4.2.1 Essential Overview | The project, which was set up in 2018, aims to lay the foundation for future distributed ledger-based services within the EU and EFTA. The EBSI was transitioned into a new organizational entity for the operations of EBSI, named the European Digital Infrastructure Consortium (EDIC). The EBSI run by nodes operated by member states. Each country is expected to operate at least one node of EBSI at full scale. This approach aligns with the decentralized nature of blockchain technology and is suitable for multi-party cooperation. EBSI ensures a governmental trust anchor and so clear responsibility on the other hand this approach leads to the question on how such a network might be provided (QTSP for Electronic Ledger) or used (by EUDI Wallet Issuer or QTSP using DLT) by a certain provider. With the introduction of eIDAS2 and the concept of Qualified Electronic Ledgers, the EBSI could potentially not only evolve from an Electronic Ledger into a Qualified Electronic Ledger enhancing security and reliability of the network, but also providing legal certainty for use cases that build on the EDIC's Electronic Ledger. EBSI contains a comprehensive technical framework on: • Issuance, verification, revocation and presentations of verifiable credentials or attestations in terms of eIDAS • Interoperability of wallets • DID methods • Timestamps • API • Governance for issuers and verifier (relying parties) Currently there`s no possibility to implement and run Smart Contracts, as defined in ISO 22739 [i.3], on the EBSI infrastructure but this might change in future. The EBSI framework can automate processes like identity verification and product tracking, ensuring transparency and efficiency. For example, by using the Track and Trace API, it is possible to verify goods automatically at each stage, reducing manual checks and enhancing security across borders. The API might be extended to Smart Contracts in future. Recently (27 March 2025) it was announced that Smart Contracts, as defined in ISO 22739 [i.3], could be successfully deployed. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.4.2.2 Terminology | Smart Contracts and distributed ledgers as defined in ISO 22739 [i.3]. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 23 |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.4.2.3 Chain of Trust | EBSI, as per the publication date of the present document, is agnostic with respect to the Chain of Trust. This can change in the future. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.4.3 EUDI Wallet | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.4.3.1 Essential Overview | The European Digital Identity Wallet (EUDI Wallet) is a key component of the eIDAS2 Regulation (EU) 2024/1183 [i.2]. The EUDI Wallet is designed as a secure and user-centric digital identity solution that allows citizens and residents of the European Union to authenticate their identity and access a wide range of online services, both public and private. The wallet can store and manage various forms of electronic attestations, including Person Identification Data (PID), Qualified Electronic Attestations of Attributes (QEAA), Electronic Attestations of Attributes (EAA) and Electronic Attestations of Attributes provided on behalf of the public sector bodies (EAA-Pub) like mobile Driving Licenses (mDLs). The EUDI Wallet prioritizes privacy and security by design, ensuring that users have control over their personal data. It supports high levels of assurance for identity verification, which is critical for accessing services that require strong authentication. The wallet can be used across borders within the EU, fostering interoperability and ensuring that it functions seamlessly in different member states. The Toolbox is a comprehensive set of technical specifications, standards, guidelines, and best practices developed to ensure the consistent implementation of the European Digital Identity Framework (eIDAS2) across the EU. The Toolbox serves as a reference for member states, helping them align their national digital identity systems with the European framework. The infrastructure component of the eIDAS2 refers to the underlying technical and organizational structures that support the operation and use of the EUDI Wallet across the EU. This includes the roles of various stakeholders, the systems they operate, and the interfaces between these systems: • EUDI Wallet Providers are entities, typically mandated by member states, responsible for providing and maintaining the EUDI Wallet solutions. They ensure that the wallets are compliant with the ARF's requirements and that they securely manage users' personal data and digital credentials. • Person Identification Data (PID) Providers - trusted entities that verify the identity of users and issue PIDs to be stored in the EUDI Wallet. These providers play a critical role in ensuring that the identities within the wallet are accurate and trustworthy. • Electronic Attestation of Attributes (QEAA, EAA-Pub, EAA) Providers - qualified and non-qualified Trust Service Providers (TSPs) that issue electronic attestations, such as diplomas or licenses, which can be stored in the EUDI Wallet. They ensure that the attributes linked to a user's identity are accurate and legally recognized. • Relying Parties - the entities that request and rely on the identity and attribute data stored in the EUDI Wallet to provide services. They interact with the wallet through secure interfaces to verify users' identities and attributes. The infrastructure also includes mechanisms for managing trust across the ecosystem, such as Trusted Lists and Certificate Authorities (CAs), which ensure that only authorized entities can issue and verify digital credentials. Smart Contracts can play a potentially transformative role in the EUDIW under eIDAS2 by automating and enhancing the security, privacy, roles, and trustworthiness of digital transactions. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.4.3.2 Terminology | Smart Contracts, SC Provider, SC Publisher. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 24 |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.4.3.3 Chain of Trust | EUDI Wallet, as per the publication date of the present document, is agnostic with respect to the Chain of Trust. This can change in the future. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.5 Others | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.5.1 eIDAS Toolbox- Architecture and Reference Framework (ARF) | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.5.1.1 Essential Overview | Architecture and Reference Framework (ARF) for the European Digital Identity (EUDI) Wallet [i.17] is part of the European Union's initiative to create a standardized and secure digital identity system based on eIDAS2 regulation. The ARF is a draft prepared by the eIDAS Expert Group and provides the technical architecture, standards, and guidelines necessary for implementing the EUDI Wallet. It covers the roles and responsibilities of various stakeholders, including Wallet Providers, Person Identification Data (PID) Providers, and Qualified Electronic Attestation of Attributes (QEAA) Providers. The document also details the design principles, such as user-centricity, interoperability, privacy by design, and security by design, which are essential for the successful deployment of the EUDI Wallet. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.5.1.2 Terminology | Smart Contracts, Electronic Ledger. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.5.1.3 Chain of Trust | ARF is agnostic with respect of the Chain of Trust. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.5.2 INATBA | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.5.2.1 Essential Overview | 4. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.2.1 Essential Overview | The International Association for Trusted Blockchain Applications (INATBA) offers public and private developers and users of DLT a global forum to interact with regulators and policymakers and bring blockchain technology to the next stage. INATBA facilitates positive change in the blockchain ecosystem. INATBA supports and promotes members to bridge public and private entities and promote global blockchain adoption across diverse fields such as law, finance and education. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.5.2.2 Terminology | Smart Contracts and distributed ledgers as defined in ISO 22739 [i.3]. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.5.2.3 Chain of Trust | INATBA as per the publication date of the present document, is agnostic with respect to the Chain of Trust. This can change in the future. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.5.3 ENISA: Digital Identity Standards | |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.5.3.1 Essential Overview | 4. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.3.1 Essential Overview | ENISA is an agency of the European Union. The ENISA Digital Identity Standards [i.18] publications serve as a comprehensive analysis of the various standardization requirements that support cybersecurity policies, particularly in the realm of digital identity. The standards discussed encompass a broad spectrum, including policies, services, formats, protocols, and security requirements necessary for managing digital identities. These standards are essential in ensuring the security, reliability, and cross-border recognition of digital identities, which have become increasingly crucial due to the rise of digital services and electronic transactions, especially accelerated by the COVID-19 pandemic. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 25 The documents outline the key areas covered by digital identity standards, which include identity management, trust services, authentication capabilities, and supporting services, and discuss the role of various standardization bodies, such as the European Telecommunications Standards Institute (ETSI), International Organization for Standardization (ISO), and national organizations like the National Institute of Standards and Technology (NIST) in developing these standards. Additionally, the documents highlight the evolution of digital identity standards from focusing on basic technical aspects like protocols and formats to addressing more complex issues such as cryptographic security, biometrics, and self-sovereign identities. The analysis within the documents also delves into specific standards used in identity management, such as the ISO/IEC 24760-1 [i.70] series, which provides a framework for identity management, and ISO/IEC 29115 [i.71], which offers guidelines for entity authentication assurance. They also further examine the standards related to trust services, such as ETSI's standards for trust service providers, which are crucial for ensuring that digital transactions are secure and that digital identities can be trusted across different platforms and borders. The documents also provide with a set of recommendations aimed at European policymakers, standardization organizations, and cybersecurity agencies like ENISA, advocating for the continued development and adoption of robust digital identity standards to support the evolving landscape of digital transactions and cybersecurity needs. Because of the intrinsic role of ENISA and the cruciality of having Smart Contracts secure, identity issues in Smart Contracts will be subject of study in the future. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.5.3.2 Terminology | Smart Contracts, Electronic Ledger. |
142241be1ea90643e055df0a41f4debe | 119 540 | 4.5.3.3 Chain of Trust | ENISA, as per the publication date of the present document, is agnostic with respect to the Chain of Trust. This can change in the future. 5 A Chain of Trust in support of Smart Contracts and Electronic Ledgers 5.1 Essential Overview The present clause describes the processes involved in building, deploying, and executing a Smart Contract computer program on an Electronic Ledger. It formally identifies all the relevant actors, artifacts, hardware, networks and tools, emphasizing the critical points where governance, safety, security, and identity issues are required. This is done by means of a novel and as yet unpublished Chain of Trust, considering all involved entities. The security of Smart Contracts can be significantly compromised by an incomplete validation chain, which exposes users to various risks, including fraud and attacks. Ideally, the Chain of Trust occurs at many abstraction levels: • SC Language entities. Responsible to ensure that the design and the certification of a programming language used to encode the logic of a Smart Contract is not left to unknown not traceable communities. • SC Tools. Responsible to ensure that the encoding and the certification of software tools like, e.g. a SC Compiler and a SC Virtual machine is not left to unknown not traceable communities. • SC Legal entities. Responsible to ensure that the process of encoding and the certification of a Smart Contract will be clearly identified and traceable. • SC Published entities. Responsible to ensure that the process of making available a Smart Contract on the market will be clearly identified and traceable. • Electronic Ledger. Responsible to ensure that the process of running a Smart Contract on an Electronic Ledger will be clearly identified and traceable. • Underlying networks. Responsible to ensure that the network infrastructure where distributed data structures, like Electronic Ledgers, will be clearly identified and traceable. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 26 • Hardware. This point, although essential, is not treated in the present document. One of the main findings from the analysis of the Data Act [i.1] and eIDAS2 [i.2] and its consequences to the standardization of Smart Contracts and Electronic Ledgers is that in order to satisfy the European rules for transparency and accountability, the actors of Electronic Ledgers and Smart Contracts should be identifiable according to Data Act [i.1] and eIDAS2 [i.2], respectively. More precisely, Smart Contracts should be strictly governed to give legal value, as per Smart Legal Contract definition in Clause 3.1. The same considerations for governance apply for Electronic Ledgers, that should be permissioned. This governance issue is independent for an Electronic Ledger to be centralized, cloud-based, or distributed, or any other of future technological implementation. In parallel, eIDAS tools like Advanced Electronic Signatures (AdES) and Qualified Electronic Seals (QSeal) offer essential mechanisms for authenticating data and signing documents. AdES, which is uniquely linked to the signatory and created in a way that ensures their exclusive control, is fundamental in scenarios where Smart Contracts automate large-scale transactions. The use of AdES guarantees that each transaction is verifiably authentic and legally binding. These tools ensure traceability, authentication, and compliance with regulatory standards, providing a solid legal foundation for Smart Contracts in regulated environments. A primary requirement for the use of Smart Contracts in the EU is to give assurance that in the event of a dispute that the parties to the Smart Contracts can be identified. The eIDAS2 framework is an existing framework that offers these capabilities and the role of eIDAS in Smart Contracts is described in ETSI TS 119 542 [i.16]. A suitable quality measure would be the adoption of Common Criteria [i.5], with a focus on Evaluation Assurance Levels (EAL) and Protection Profiles. These levels range from EAL1, which represents basic security, to EAL7, which provides the highest level of security, suitable for systems operating in high-risk environments. Protection Profiles specify security requirements for particular categories of products or systems, such as Smart Contracts managing sensitive transactions. For instance, a Smart Contract designed to handle financial transactions might be evaluated at EAL4, at least, ensuring a high level of security through methodical testing and vulnerability assessments. This would mitigate risks such as unauthorized access or data manipulation. For the Chain of Trust, a proper validation, or at the very least, the identification of the tools used at each stage of the process, is essential. The toolchain identifies the following entities: Software: Validating or at least identifying the authors, is essential to guarantee that an algorithm can be designed, coupled with some legal enforcements, translated into runnable code by a certified compiler, deployed on a Qualified Electronic Ledger, and executed on the top of a certified virtual machine, using certified inputs. This concretizes the concept, not standardized yet, of Smart Legal Contract. Hardware: Validating or at least identifying the hardware (silicon) platforms involved is also crucial. However, deployment presents a more complex challenge, as validation or identification during the deployment phase often depends on the specific type of Electronic Ledger being used, and in some cases, it can be difficult or even impossible. Networks: Validating or at least identifying the underlying network providers at each stage is essential and should be practically feasible. A Smart Contract is a complex entity that has legal impact and which if compromised will seriously impact the relying parties. In recognizing this, the Smart Contract can be classified as requiring substantial or high-levels of assurance as defined in the Cyber Security Act [i.68], and this should be provided by conformance to an approved assurance scheme as defined by the Cyber Security Act, e.g. the EU Cybersecurity Certification Scheme on Common Criteria [i.69], managed by ENISA. Governance aspects of the overall security are given in ETSI TS 119 541 [i.12] that addresses the role of assurance schemes. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.2 SC main entities | 5.2.1 Essential Overview Table 1 summarizes the Chain of Trust, in its first version V1, as a numbered set of interactions between entities, results produced, identification and assurance needs. Each rule, represented as a line in the Table, defines a precise interaction between two or more entities. The intuitive meaning of each column is: • Entity: identifies each participating entity in the generation of a result which may be an object or a running Smart (Legal) Contracts on a (Qualified) Electronic Ledger. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 27 • Entities it interacts with: identifies the entities with which the former entity interacts with or uses (in the case that the entity is an object, a program for instance) for producing the mentioned result. • Result produced: identifies the result produced by the entities in the first and second column. • Identification needs: requirements for identification of legal/natural persons responsible for a process and requirements for assuring the identity using electronic signatures/seals and/or identity authentication. This is addressed in ETSI TS 119 542 [i.16] which is expected to specify the requirements for identification of the mentioned entities and the requirements for the signatures on the Smart Contracts. • Assurance needs: requirements for assuring the security and correct operation of a process. This is addressed in ETSI TS 119 541 [i.12] which is expected to specify the policies under which the required certification operations are carried out. NOTE 1: Entities in the Chain of Trust can overlap each other. NOTE 2: Rules in the Chain of Trust may be valid in any order. NOTE 3: Rules in the Chain of Trust should not contradict each other over the time. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 28 Table 1: The Chain of Trust V1 # Entity Entities it interacts with Result produced Identification needs Assurance needs SC Production 1 SC Language Specification Team SC Language Publisher SC Language Specification Signed by SC Language Publisher • Correctness of syntax and semantics of SC Language Specification. • Respect of SC Language Specification Policy. SC Language Specification Policy Signed by SC Language Publisher 2 SC Compiler Team SC Language Publisher SC Compiler Publisher SC Compiler Signed by SC Compiler Publisher • Semantic preservation of the SC Compiler against SC Language Specification. • Respect of SC Compiler Development Policy. SC Compiler Policy Signed by SC Compiler Publisher 3 SC Virtual Machine Team SC Language Publisher SC Virtual Machine Publisher SC Virtual Machine Signed by SC Virtual Machine Publisher • Semantic preservation of the SC Virtual Machine against SC Language Specification. • Respect of SC Virtual Machine Development Policy. SC Virtual Machine Policy Signed by SC Virtual Machine Publisher 4 SC Developers Team SC Legal Team SC Publisher SC Package including SC Byte Code, SC Source Code, SC Legal Text, and SC Documentation Signed by SC Publisher • Assurance that SC Source Code, SC Byte Code, SC Legal Text, and SC Documentation meets the SC Development Policy. • Assurance that the SC Source Code, SC Byte Code, SC Legal Text, and the SC Documentation are identified by SC Publisher. • Assurance that the employed SC Compiler and SC Virtual Machine comes from a SC Compiler Publisher and SC Virtual Machine Publisher respecting the SC Compiler Policy and SC Virtual Machine Policy. SC Development Policy Signed by SC Publisher SC Deployment 5 SC Publisher SC Provider SC Package including SC Byte Code, SC Source Code, SC Legal Text, and SC Documentation SC Provider and SC Publisher mutual identification • Assurance that SC Package comes from a SC Publisher. 6 SC Provider SC Deployer Evidence of legal terms of SC Deployer SC Provider and SC Deployer mutual identification • Assurance of legal terms of SC Deployer. 7 SC Deployer Electronic Ledger Electronic Transaction in a Electronic Ledger containing the SC Package SC Deployer identified by Electronic Ledger • Assurance that SC Package comes from a SC Deployer. SC Execution 8 SC User SC Provider • Evidence of SC Legal Text from a SC Package. • Evidence of legal terms of SC Provider. • SC User inputs. SC User and SC Provider mutual identification • Agreement of legal terms of SC Provider. • Agreement of SC Legal Text. 9 SC Provider Electronic Ledger Electronic Transaction in a Electronic Ledger SC Provider identified by Electronic Ledger • Assurance of the truthfulness of inputs from SC User and inputs from SC Oracles and transactions for the Electronic Ledger ETSI ETSI TR 119 540 V1.1.1 (2025-10) 29 |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.2.2 SC Language Specification | The semantics of programming languages, especially for domain specific languages for writing Smart Contracts, is fundamental to understand the execution in Electronic Ledger. The semantic rules of a programming language determine how its syntax is interpreted into actions to be performed. In the context of Smart Contracts, where transactions and contractual obligations are executed automatically, the clarity and precision of these semantics are indispensable. They should be unambiguous and comprehensive to prevent errors and security breaches. The use of formal methods to specify semantics, helps verify the correctness and security of the code. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.2.3 SC Compiler | The design and implementation of a SC Compiler play a critical role for the design and execution of a Smart Contract which is executed on the top of one or many SC Virtual Machines relying on a centralized or distributed Electronic Ledgers: as an explanatory example, different SC Compilers compile the same SC Source Code into different SC Byte Codes that, in turn, will be all executed on a distributed ledger ISO 22739 [i.3] using different SC Virtual Machines. Thus, a SC Compiler is responsible for translating a SC Source Code written using a particular version of a SC Language, into a SC Byte Code written on a particular version of a SC Byte Code Language that can run on different SC Virtual Machines, each of one capturing the semantic of a different SC Byte Code Language. This translation process is vital as it bridges the gap between human-readable code and machine-executable instructions. The compatibility between languages definitions, compilers, byte codes, and virtual machines is thus capital to ensure a coherent behavior in a centralized or distributed setting. The absence of European regulations can lead to discrepancies in how compilers interpret and translate code, potentially introducing bugs or vulnerabilities that are only evident once a SC Byte Code is deployed and executed on an Electronic Ledger, and as such, immutable. Without regulations and standardized specifications, SC Compiler developers might interpret the SC Language Specification and SC Language Specification Policy differently, leading to non-compatible, semantically different SC Byte Code and inconsistent Smart Contract behavior across platforms. As an explanatory example, in case of Smart Contracts [i.3] executed on distributed ledgers as defined in ISO 22739 [i.3], a special kind of Electronic Ledger [i.1], the decentralized nature of the blockchain technology means that a Smart Contract [i.3] might be executed on many different nodes around the world, each potentially using slightly different compiler versions or settings. This decentralization exacerbates the risk of discrepancies and highlights the importance of establishing more uniform compiler standards. It could be beneficial for the distributed ledgers community to consider frameworks that provide clearer guidelines and specifications for compiler development. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.2.4 SC Virtual Machine | The design and implementation of SC Virtual Machines (VMs) are pivotal for the execution of Smart Contracts [i.3] across various blockchain platforms. These VMs translate the bytecode produced by compilers into executable actions within the blockchain's network. As explanatory examples: Ethereum's Ethereum Virtual Machine (EVM) and the Solana's Sealevel operate under different principles and architectures, tailored to their specific blockchain ecosystems. For instance, EVM is designed for Ethereum's account-based model and handles transactions and contract states differently from Sealevel, which is designed to execute thousands of Smart Contracts as defined in ISO 22739 [i.3] in parallel, in a distributed ledger as defined in ISO 22739 [i.3], all optimized for Solana's unique consensus mechanism and high throughput capabilities. 5.2.5 Computer assisted software tools to assess correctness, safety, and security In the development of Smart Contracts, ensuring the correctness, safety, and security of the software is paramount. To address these concerns, developers and researchers employ various computer-assisted software tools that aid in the formal verification and validation of SC Languages, SC Compilers, SC Virtual Machines, Electronic Ledgers and Smart Contracts. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 30 As examples of the most applied Formal Verification Tools, the present document mentions: 1) Rocq: Rocq (formerly Coq) [i.24] is an interactive theorem prover designed to develop mathematical proofs and to write formally verified software. It is widely used in academia and industry to ensure the correctness of algorithms and to formally prove properties of programs. Rocq's ability to construct proofs makes it an invaluable tool for verifying the SC Languages used for Smart Contracts. 2) Isabelle: Isabelle [i.25] is another powerful theorem proving environment, which supports a variety of logical formalisms. It is used for writing and checking detailed proofs, and can also serve as a platform for developing robust, formally verified software. Isabelle's frameworks are particularly useful in verifying the correctness and security of Electronic Ledgers and Smart Contract code. 3) Lean: Lean [i.26] is a theorem prover and programming language designed for formalizing mathematical theorems and programming logically. It is used with distributed ledgers as defined in ISO 22739 [i.3] and particularly for the formal verification of Smart Contracts, ensuring that they execute as intended without unwanted side effects or vulnerabilities. Application examples: • Smart Contract Verification: Tools like Rocq and Isabelle have been used to develop formal models of blockchain environments and programming languages for Smart Contracts as defined in ISO 22739 [i.3], such as Solidity, executed on a distributed ledger as defined in ISO 22739 [i.3]. For example, a project might use Isabelle to formalize the semantics of Solidity and prove certain security properties, such as the absence of reentrancy vulnerabilities. • SC Compiler and SC Virtual Machine Verification: The correctness of SC Compilers, which translate high- level SC Source Code into SC Byte Code, can be also verified using these tools. This is not new for usual programming languages. For instance, the CompCert [i.27] project uses the Rocq proof assistant to formally verify a compiler for the C programming language, ensuring that the compiler does not introduce any errors during the translation process. A similar approach can be adapted for SC Compilers and SC Virtual Machines. Formal Tools like Rocq, Isabelle, and Lean can formally check that the SC Source Code and the SC Byte Code accurately reflects algorithmic logic semantic underneath the Smart Contract. Implementation of Electronic Ledgers can be also formally checked. By utilizing formal verification methods, it is possible to ensure that the algorithm does not contains bugs or logical errors that could lead to vulnerabilities. Automated tools can handle large volumes of contracts more efficiently than a manual process, making it scalable for applications that require numerous or frequently updated Smart Contracts. Incorporating the Common Criteria (ISO/IEC 15408 [i.5]) in the use of these tools adds an additional layer of security assurance. The Common Criteria framework provides a structured process for evaluating the security and assurance of information technology products, which is directly applicable to Electronic Ledgers. By aligning the formal verification processes with Common Criteria standards, developers can certify the security and robustness of an Electronic Ledger and Smart Contracts running on the top of it, enhancing trust and compliance with international security standards. Recommendation ITU-T F.751.8 [i.30] advocates the use of formal methods to support the security of Smart Contracts running on DLT systems. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.2.6 SC Legal Text, Certification of Smart Contract, Agreements | |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.2.6.1 Essential Overview | 5.2. |
142241be1ea90643e055df0a41f4debe | 119 540 | 6.1 Essential Overview | Translating a certified SC Legal Text into a Smart Legal Contract is a detailed process. It ensures that the legal terms are precisely and securely translated into a SC Byte Code on a SC Virtual Machine using an Electronic Ledger. This is important to maintain the contract's integrity and enforceability. A task force consisting of both Lawyers and Software Engineers works collaboratively to interpret the legal terms and requirements of a contract and then implement these into a Smart Legal Contract. Lawyers, represented in the present document as SC Legal Team, ensures that the legal nuances, represented using a Deontic Logic, are respected and fully represented, while software engineers, represented in the present document as SC Development Team, focus on encoding these terms into a SC Source Code, written in a SC Language, that is in turn compiled into a SC Package containing, among other files, the SC Byte Code that will be executed within one or many SC Virtual Machines on an Electronic Ledger. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 31 Formal tools often have built-in libraries for reasoning with Deontic Logic: this would help SC Development Team and SC Legal Team to work together and converge to write a Smart Legal Contract that accurately reflects the stipulated legal terms and a formally proven executable code. By utilizing formal verification methods, it is possible to ensure that the contract does not have bugs or logical errors that could lead to disputes or vulnerabilities. Reversing the process, i.e. translating SC Byte Code back into a SC Legal Text, is important for legal review, compliance checks, and in situations where parties need to understand the executed terms without reading the code. This can be achieved by maintaining a comprehensive documentation and comments within the SC Source Code and the SC Package, that reflects the legal terms in a natural language. Observe that that in the Chain of Trust, the SC Package should be able to package at least SC Byte Code with SC Documentation, SC Source Code, and SC Legal Text. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.2.6.2 SC Legal Text | The legal basis for a Smart Contract is defined using SC Legal Text. This can include: a) Legal context in which the Smart Contract execution takes place such as European legislation, national legislation, or commercial agreements. b) Provisions to meet the requirements for data protection of any personal data. c) Requirements on SC Deployer Policy. d) Requirements for SC Provider including: i) Use of SC Language tools including SC Compiler and SC Virtual Machine. ii) Use of Electronic Ledgers. iii) Verification of SC User identities. e) License terms and conditions to be agreed by the SC User. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.2.6.3 Certification of Smart Contract by SC Publisher | The elements of a Smart Contract and a Smart Legal Contract (SC Legal Text, SC Source Code, SC Byte Code, and other SC Documentation) should be certified by the SC Publisher which has overall responsibility for the Smart Contract. The certification should be based on conformance to the SC Publisher's SC Development Policy. The certification should be provided by the SC Publisher which has overall responsibility for the Smart Contract. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.2.6.4 Verification of legal agreement | a) Deployment of a Smart Contract Before deploying a Smart Contract (a SC Byte Code), the SC Deployer should ensure that all the elements of the Smart Contract have been certified together by an identified SC Publisher. In addition to making the SC Byte Code available on the Electronic Ledger, the SC Deployer should provide a successful validation report for SC Publisher signature against all the elements of the Smart Contract. Elements other than the SC Byte Code can be held outside the ledger but should include binding information (e.g. location reference and hash) alongside the validation report in the ledger. The SC Deployer should also record a confirmation that its SC Deployer Policy meets the requirements for deployment in the SC Legal Text. b) Provision of a Smart Contract Before executing a Smart Contract (a SC Byte Code) on the top of a SC Virtual Machine, the SC Provider should: i) Validate the SC Publisher signature at least against the SC Byte Code and record the validation report in the Electronic Ledger. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 32 ii) Confirm that SC Provider Policy, including use of an Electronic Ledger and SC Language tools, meets the requirements in the SC Legal Text and record this in the Electronic Ledger. c) User license terms and conditions d) Execution of a Smart Contract Before executing a Smart Contract (a SC Byte Code) on the top of a SC Virtual Machine, the SC Provider should provide the SC User with a copy of the license: i) The SC Provider should record in the Electronic Ledger information on the validation of the SC User identity along with a confirmation of the acceptance of the license terms and conditions which should be part of or bound to the SC Legal Text for the Smart Contract. After executing a Smart Contract (a SC Byte Code), the SC Provider should provide a SC Execution Report. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.3 Distributed ledger technology (DLT) | 5.3.1 Essential Overview Although Regulation (EU) 2023/2854 [i.1] and Regulation (EU) 2024/1183 [i.2] provide a normative framework for Smart Contracts and Electronic Ledgers, the present clause highlights the significant increase in the use of distributed ledgers as defined in ISO 22739 [i.3] over the past decade, operating on various distributed ledger technologies. As such, the present clause presents key information to outline the state of the art in distributed ledgers. The present clause has also basis in documents produced by ISO TC 307, and ETSI ISG PDL (at time of publication of the present document now part of ETSI TC DATA) and ITU-T. The aim is to understand the gap existing between Electronic Ledger and Smart Contracts, as defined by European regulations, and the existing distributed ledgers and Smart Contracts standard, as defined in Standard Organizations documents, and the de facto real solutions emerged and used by far. The Chain of Trust should fill this gap. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.3.2 Permissioned or permissionless | Permissioned distributed ledgers restrict network access to authorized participants only. In this model, each participant is explicitly allowed to join the network, typically by a network administrator or through a consensus of existing participants. Selected participants are allowed to validate and persist transactions. This setup is favoured by private organizations and consortiums where privacy, security, and control are priorities. Since participants are known and verified, it is easier to maintain confidentiality over transactions. Permissionless distributed ledgers allow anyone to join and participate in the network without prior authorization. Every participant is allowed to validate and persist transactions. This type of ledger underpins cryptocurrencies like Bitcoin and Ethereum, supporting a fully decentralized environment. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.3.3 Public or Private | Public distributed ledgers allow everybody to access all transactions and data so there is full transparency. Private distributed ledgers allow to access only authorized users: similar conditions concerning execution of transactions can apply. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.3.4 Data structures used to implement a distributed ledger | Electronic Ledgers, as defined in eIDAS2 regulation, can be implemented using either centralized or distributed technology, and as such a distributed ledger, as defined in ISO 22739 [i.3]. In both cases the used data structure is important to understand how the Chain of Trust can be applied. The present clause recaps the state of the art of all data structures for distributed ledgers as described in ISO and ETSI and ITU-T documents. In a distributed ledger - subset of an Electronic Ledger - various data structures are used to ensure security, efficiency, and immutability. These data structures serve different purposes, such as storing transaction ETSI ETSI TR 119 540 V1.1.1 (2025-10) 33 records, maintaining integrity, and managing nodes and states. Below are some of the key data structures that can be used to implement distributed ledgers, also summarized in Table 2. For each data structure one list usage, structure and components, advantages, and a simple example of distributed ledger, commonly referred as blockchain. The present clause is important in order to understand which data structure can be adapted or extended with lesser effort to the Chain of Trust without sacrificing backward compatibility with existing distributed ledgers and what it is described in Regulation (EU) 2024/1183 [i.2] and in its forthcoming Implementing Acts. Each data structure plays a crucial role in the functioning, efficiency, and security of a distributed ledger: 1) Linked List: - Usage: a distributed ledger itself can be seen as a linked list where each block is linked to the previous one using cryptographic hashes. Each block contains a reference (hash) to the previous block, forming a chain. - Advantages: Simple structure, easy to traverse. - Example: Used in Bitcoin or Ethereum. 2) Merkle Tree (Hash Tree): - Usage: Merkle trees are used to efficiently and securely verify the integrity of large sets of data. A Merkle tree allows nodes to verify the consistency and validity of the transactions in a block without needing the entire data. - Structure: A binary tree where each leaf node is a hash of a data block, and non-leaf nodes are hashes of their child nodes. - Advantages: Efficient proof of data integrity, scalable, and reduces the amount of data stored by light clients (SPV nodes). - Example: Used in Bitcoin and Ethereum for efficient transaction verification. 3) DAG (Directed Acyclic Graph): - Usage: Some distributed ledger systems, like IOTA and Hedera Hashgraph, use DAG structures to manage transactions and consensus differently from traditional chains. Instead of linear blocks, transactions are stored in a graph where each transaction points to one or more previous transactions. - Advantages: Higher scalability, no need for mining, low latency. - Example: IOTA's Tangle, Hedera Hashgraph. 4) Patricia Trie (Radix Trie or Prefix Trie): - Usage: Patricia tries are used in Ethereum to efficiently store key-value pairs and ensure quick retrieval and verification of data. It is a form of a Merkle Trie that combines a tree and a Merkle Trie. - Structure: A compact and ordered data structure that stores a mapping from arbitrary-length binary strings to values. - Advantages: Space-efficient, allows for fast lookups, insertions, and deletions. - Example: Used in Ethereum for account storage and world state representation. 5) Heap: - Usage: Heaps are used to manage priority queues, especially for mining operations and transaction selection. For example, miners may use heaps to select transactions with the highest fees. - Advantages: Efficient handling of dynamic data, fast access to the highest-priority element. - Example: May be used in Bitcoin and Ethereum for transaction prioritization. 6) Bloom Filter: ETSI ETSI TR 119 540 V1.1.1 (2025-10) 34 - Usage: A probabilistic data structure used to test whether an element is part of a set or not. It is used in lightweight nodes (SPV nodes) to filter transactions and blocks relevant to them without having the full blockchain. - Advantages: Space-efficient, fast, low false positives. - Example: Bitcoin's SPV nodes use Bloom filters to query full nodes for relevant transactions. 7) Block Structure: - Usage: Each block in a blockchain contains data like transactions, timestamps, the hash of the previous block, and a nonce. - Components: - Header: Contains metadata like the hash of the previous block, Merkle root, timestamp, and nonce. - Body: Contains transaction details, including the sender, receiver, and amount. - Example: Every blockchain uses this structure with some variations. For instance, Bitcoin has a simple structure, whereas Ethereum's blocks contain additional information for Smart Contracts and state transitions. 8) Account Trie: - Usage: In Ethereum, each account is stored in a trie structure. The account trie maps the address to account details like nonce, balance, storage root, and code hash. - Advantages: Efficient access and storage of account states, helps in keeping track of changes in accounts over time. - Example: Used in Ethereum for improve efficiency. 9) Unspent Transaction Output (UTXO) Set: - Usage: UTXO represents the set of unspent transaction outputs that are used to determine the available balance for a wallet. - Structure: A database of all unspent outputs, where each output is indexed by its transaction ID and output index. - Advantages: Enables stateless transactions, simplifies validation. - Example: Used in Bitcoin, Litecoin, and other UTXO-based blockchains. 10) State Trie: - Usage: The State Trie represents the global state of the distributed ledger, which includes all accounts and contracts in Ethereum. It is a critical part of Ethereum's world state. - Structure: A Merkle Patricia Trie structure that stores the state of each account, including balances, nonces, and contract storage. - Advantages: Enables efficient state verification and validation. - Example: Core to Ethereum's execution model. 11) Transaction Pool: - Usage: This is a temporary storage area for transactions that have been broadcast to the network but have not yet been included in a block. The pool is often managed as a priority queue. - Advantages: Helps miners select transactions based on fees and ensures that pending transactions are accessible to the network. - Example: Both Bitcoin and Ethereum use a transaction pool to store unconfirmed transactions. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 35 12) Sparse Merkle Trie: - Usage: Sparse Merkle Tries are used in systems where most entries are empty, such as in proof-of-stake systems for proof generation. These trees allow the blockchain to verify the existence or non-existence of data efficiently. - Advantages: Compact, verifiable, ideal for systems with sparse data. - Example: Used in various proof-of-stake protocols and newer blockchain projects. Table 2: Summary of data structure management Data Structure Purpose Examples Linked List Chain of blocks Bitcoin Merkle Tree Efficient transaction verification Bitcoin, Ethereum DAG Transaction verification without mining IOTA, Hedera-Hashgraph Patricia Trie Efficient key-value pair storage Ethereum Heap Transaction prioritization Bitcoin (mining), Ethereum Bloom Filter Lightweight transaction queries Bitcoin SPV Nodes Block Structure Block metadata and transactions All blockchains Account Tree Storage of account details Ethereum UTXO Set Unspent transaction outputs Bitcoin, Litecoin State Tree Global state of the blockchain Ethereum Transaction Pool Unconfirmed transaction storage Bitcoin, Ethereum Sparse Merkle Tree Proof generation in sparse systems Proof-of-stake protocols |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.3.5 On-chain and off-chain transaction data solutions | On-chain data refers to any information that is stored directly on a distributed ledger as defined in ISO 22739 [i.3]. This includes transaction records, Smart Contracts as defined in ISO 22739 [i.3], and any other data that needs to be immutable, transparent, and verifiable by all network participants. As an explanatory example, the Ethereum Virtual Machine stores all transactions, including the ones generated by the execution of a Smart Contract, on-chain. For example, a crowdfunding contract can record all contributions and funding thresholds directly on the Ethereum blockchain, ensuring transparency and immutability. Another example in Ethereum is the ERC-721 [i.72], dealing with Non-Fungible Tokens (NFTs): all information related to the ownership and transfer of an NFT is stored on-chain, ensuring the traceability and uniqueness of the token. Off-chain data refers to any data that is stored outside of the distributed ledger as defined in ISO 22739 [i.3] but can interact with it when needed. This includes large files, databases, and other forms of data that do not need to be stored on-chain for every transaction. Some explanatory examples are listed below: • IPFS is a decentralized storage protocol that allows large amounts of data to be stored off-chain while only a reference hash is stored on-chain. For example, in a digital content management system, multimedia files can be stored on IPFS, with the file hash preserved on the distributed ledger to verify integrity and origin. • Layer 2 Solution, such as Lightning Network, is an off-chain scaling solution for the Layer 1 distributed ledger that allows fast and low-cost transactions. Transactions are recorded off-chain, with only the final balance reported on-chain. • Plasma is a scaling solution that uses sidechains to process off-chain transactions, with the ability to anchor critical data on-chain. This reduces the load on the main distributed ledger while maintaining security and verification through the Ethereum MainNet. • Optimistic Rollups on Ethereum, a scaling solution that allows Smart Contracts as defined in [i.3] to be executed off-chain with only the final results reported on-chain. This technique improves scalability and reduces costs while maintaining transaction integrity through fraud proofs. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 36 |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.4 Digital trust elements in Smart Contracts | |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.4.1 Essential Overview | The aim of the present clause is to understand the gap existing between Electronic Ledgers and Smart Contracts, as defined by European regulations, and distributed ledgers and Smart Contracts, as defined by Standard Organization documents, and the de facto real solutions emerging and used by far. The Chain of Trust should fill this gap. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.4.2 Identification, authentication | Identity and Access Control: • Every actor during a Smart Contract and Smart Legal Contracts execution is assigned a unique identity and corresponding access control rights. The governance is responsible for ensuring that all actors have appropriate and unique access rights. • Access to Smart Contracts and Smart Legal Contracts is strictly controlled through mechanisms that enforce time-bound and role-based access, ensuring that only authorized parties can interact with the Smart Contract and Smart Legal Contracts at any given time. Lifecycle Management: • The lifecycle of a Smart Contract and Smart Legal Contracts includes proper planning, design, coding, deployment, and management. This includes defining the ownership and access control strategies during the planning phase to prevent future disputes. Security and Privacy: • Smart Contracts and Smart Legal Contracts ensure that identity information and access rights are securely managed. This includes using a trusted execution environment to prevent unauthorized access and ensures that only authenticated and authorized transactions occur within the Smart Contract and Smart Legal Contracts. • Privacy concerns are addressed by implementing private chains or channels where necessary, allowing certain contractual details to remain confidential from other participants in the network. Auditable Libraries and Verification: • Developers are required to use auditable libraries for building Smart Contracts and Smart Legal Contracts. These libraries should be verifiable and approved by governance to ensure the integrity and security of the SC Source Code and SC Byte Code. Enforceability: • Smart Contracts and Smart Legal Contracts are designed to be self-executable upon the fulfilment of predefined conditions, and they should be enforceable across different jurisdictions. The governance should ensure that Smart Contracts and Smart Legal Contracts are aligned with the legal and regulatory frameworks of the participating entities. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.4.3 Electronic signatures and seals | A digital signature as described in ETSI TR 119 001 [i.4] is a cryptographic transformation of a data unit that allows a recipient to prove the source and integrity of the data and to protect against forgery by the recipient. This involves appending data or transforming the original data in such a way that the origin of the data can be verified, ensuring its authenticity and integrity. A digital signature is a mechanism, based on public key cryptography, which can be used to provide the legal equivalent of a handwritten signatures, commonly referred to in EU legislation as an electronic signature. In the context of Smart Contracts, electronic signatures are crucial because they ensure that the actions and transactions recorded in the Smart Contract are authorized and verifiable by all parties involved. It protects the integrity of the ETSI ETSI TR 119 540 V1.1.1 (2025-10) 37 transaction and guarantees that the signatory cannot deny their involvement, thereby enabling trust and legal enforceability of the contract. Under European legislation, electronic signatures, and the equivalent when applied by an organization (referred to as a legal person) called electronic seal, can come in several forms: • Electronic Signature: An electronic signature is a data in electronic form that is attached to or logically associated with other electronic data and used by the signatory to sign. It is a broad term that encompasses various types of signatures used to confirm the authenticity of the signer and the integrity of the data. Under Regulation (EU) 2024/1183 [i.2] and Regulation (EU) No 910/2014 [i.6], it is a legal concept that ensures the authenticity and integrity of signed electronic documents. • Advanced Electronic Signature: An advanced electronic signature is a specific type of electronic signature that meets certain requirements under Regulation (EU) 2024/1183 [i.2] and Regulation (EU) No 910/2014 [i.6]. It should be uniquely linked to the signatory, capable of identifying the signatory, created using electronic signature creation data that the signatory can use under their sole control, and linked to the data signed in such a way that any subsequent change in the data is detectable. • Qualified Electronic Signature: A qualified electronic signature is an advanced electronic signature that is created using a qualified electronic signature creation device and is based on a qualified certificate for electronic signatures. This type of signature has the highest level of legal acceptance under EU law and is equivalent to a handwritten signature. • Electronic Seal: An electronic seal is similar to an electronic signature but is used by a legal person (such as a company or organization) rather than a natural person. It serves as evidence that the electronic document or data has originated from a specific legal entity and ensures its authenticity and integrity. • Advanced Electronic Seal: An advanced electronic seal is a type of electronic seal that, like an advanced electronic signature, meets certain criteria under Regulation (EU) 2024/1183 [i.2] and Regulation (EU) No 910/2014 [i.6]. It should be uniquely linked to the creator of the seal, capable of identifying the creator, created using electronic seal creation data that the creator can use under their sole control, and linked to the data to which it relates in such a manner that any subsequent change in the data is detectable. • Qualified Electronic Seal: A qualified electronic seal is an advanced electronic seal that is created using a qualified electronic seal creation device and is based on a qualified certificate for electronic seals. Like the qualified electronic signature, it carries the highest level of legal recognition and provides a greater level of trust in the origin and integrity of the sealed document. The key difference between an electronic signature and an electronic seal lies in their intended use and the type of entity applying them. An electronic signature is used by a natural person, acting under their control to perform a declaration of intent, often in the form of signing a contract or executing another legal act attributed solely to the individual. This natural person may act on their own behalf or on behalf of a legal person. When acting on behalf of a legal person, the electronic signature is applied based on a legal mandate or authorized representation. The electronic signature confirms both the identity of the natural person and their intent to bind themselves or the legal person they represent to a specific transaction or legal act. An electronic seal, however, serves a different purpose. It is used primarily by a legal person to ensure the authenticity and integrity of documents. Unlike an electronic signature, it does not express intent but functions as a security measure to guarantee that the document's content has not been altered and originates from a verified legal person. While an electronic seal cannot directly replace an electronic signature, as it does not convey personal intent, it can fulfil the same business function in certain legal contexts. For example, after a contract has been signed, subsequent orders related to that contract can be automatically validated with an electronic seal, ensuring the document's origin and integrity without further action from a natural person. Electronic seals are especially important in trust services and are legally supported by the eIDAS regulation as a basis for their use. In the context of Smart Contracts, an electronic signature is essential for confirming that the relevant documents and data entering the Smart Contracts, particularly those related to contract formation, obligations, or verification data, are validated by the natural persons who are parties to the agreement. In this way, the electronic signature serves as both a tool for identifying natural persons and for confirming the commitments they make within the Smart Contract. On the other hand, an electronic seal can greatly support Smart Contracts by verifying the authenticity of the data input, particularly when acting as a source (or oracle). Moreover, if a Smart Contract generates data that is to be used outside of the ledger, the electronic seal can safeguard the authenticity, integrity, and origin of that data, ensuring it results from ETSI ETSI TR 119 540 V1.1.1 (2025-10) 38 the proper execution of the Smart Contract. This makes electronic seals a vital tool for maintaining trust and security in transactions involving Smart Contracts, especially for legal persons. Below are the main methods and steps involved in generating digital signatures: Digital signatures, which are a specific type of electronic signature that use cryptographic techniques for enhanced security, are typically generated using public key cryptography. Below are the main methods and steps involved in generating digital signatures: 1) Public Key Infrastructure (PKI): PKI is the most common and secure way of generating digital signatures. It involves the use of a cryptographic key pair, where a private key used to generate the digital signature (kept secret by the signer); and a public key used by recipients to verify the signature (shared with others). 2) Hardware Security Module (HSM): HSM is a physical device that securely stores private keys and performs cryptographic operations, including digital signature generation. The digital signature is returned from the HSM, which can be appended to the document. This method is common in high-security environments, such as banking, government, and large enterprises, where strict key management policies are required. 3) Smart Card or SIM card-Based Digital Signature: Smart Cards or SIM cards, which securely store cryptographic keys, can be used to generate digital signatures. The card performs the cryptographic operation to sign the hash of the document using the stored private key. Examples of using this method include systems like Mobile ID (e.g. in Estonia, Finland) or smart card-based authentication in organizations. 4) Digital Signature Software (e.g. AdobeSign®, DocuSign®): Digital signature software automates the process of key generation, signing, and verification. These platforms often integrate PKI under the hood, allowing users to sign documents digitally. The platform hashes the document and uses the user's private key to generate the digital signature. 5) Mobile Digital Signatures (mobile-ID): In some mobile digital signature schemes, the private keys are stored securely on a mobile device's SIM card or secure element, and signing happens via the mobile network. A user uses a mobile app that supports digital signatures (like mobile-ID). The app sends the digital signature, which can be verified by recipients using the public key. Digital signatures provide strong security and integrity by using cryptographic algorithms, and the exact method for generating them can range from simple software-based solutions to high-security hardware-based systems. Depending on the use case (e.g. legal contracts, mobile signing, blockchain transactions), different approaches can be used, with PKI being the most widely used and secure. Whenever an entity in the Chain of Trust relies on the validity of a digital signature the successful validation of the signature should be recorded to avoid later claim against of the origin and integrity of the signed data. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.4.4 Electronic identity | |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.4.4.1 Essential overview | In the context of the eIDAS2 regulation [i.2], electronic identification is defined as the process of using person identification data in electronic form that uniquely represents either a natural person, a legal person, or a natural person representing a legal person. This process is crucial for authentication in online and offline services, ensuring that the identity of the individual or entity is accurately and securely confirmed during digital transactions. The regulation lays out specific criteria and requirements for electronic identification schemes to be recognized and utilized across the European Union. This includes the issuance of electronic identification means (such as European Digital Identity Wallets), which contain the identification data necessary for authentication and are used to securely access services. The regulation also emphasizes that electronic identification should meet certain assurance levels (low, substantial, or high) depending on the level of confidence required in the claimed identity, and it should be recognized and interoperable across different European member states. Thus, in this context, electronic identity refers to a digitally represented identity that enables secure and trusted interactions across digital platforms, meeting specific legal and technical standards as outlined in the regulation. Whenever the identity of a SC User invoking a SC Contract is verified the successful validation of the identity should be recorded to avoid later claim against of the user invoking a Smart Contract. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 39 |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.4.4.2 Electronic identity in a mobile network | Mobile network operators also play a key role in providing secure identity services because they control SIM cards, which can store cryptographic keys and securely authenticate users. This concept is often referred to as mobile ID or Mobile Signature. A SC User can be identified when he/she is connected to the SC Provider using its mobile phone, and a particular mobile network. See also Clause 5.8. Key Components of Electronic Identity in a mobile network: 1) SIM and eSIM card as a secure storage: SIM cards are tamper-resistant hardware used to store the user's private key securely. The private key is used to generate digital signatures or authenticate the user. Similarly, eSIM is a hardware module where the user's secret key can be programmed with software in the hardware module instead of plugging in a physical card. SIM cards and eSIM can perform cryptographic operations like generating digital signatures or encrypting data without exposing the private key. 2) Mobile device: the mobile device acts as the interface through which users authenticate or sign documents. It interacts with the SIM card or secure element for cryptographic operations. It also serves as a trusted device that can be used in multi-factor authentication systems (combining something the user "has", e.g. the phone or SIM, with something the user "knows", e.g. a PIN). Benefits of mobile-based electronic identity are as follows: 1) Convenience: Users can authenticate or sign documents anywhere using their mobile phones without the need for additional hardware. No need for physical smart cards or separate hardware tokens. 2) Security: Strong two-factor authentication: combining "something you have" (the SIM card or phone) with "something you know" (a PIN or password). The private key is securely stored in the SIM card and never leaves it, reducing the risk of key compromise. 3) Widespread adoption: Mobile phones are ubiquitous, making it easy for users to adopt mobile ID services. Many mobile network operators are trusted entities with the infrastructure needed for secure identity management. 4) Legal validity: In many countries, digital signatures generated using mobile-ID systems are legally equivalent to handwritten signatures. Qualified Electronic Signatures (QES), which are generated using a secure device like a SIM card and a qualified certificate, have the highest level of legal recognition in regions like the EU under the eIDAS2 regulation. Currently the electronic identity scheme employed by mobile network operators in standards is still far away from complying with eIDAS2 and Data Act. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.4.5 Distributed ledgers | Distributed ledgers are a special kind of Electronic Ledgers in presence of network facilities. There are several Distributed Ledger Technologies (DLTs), not necessarily aligned with ISO 22739 [i.3] that provide frameworks and protocols for building decentralized systems, enabling secure and transparent transactions without relying on a central authority. DLTs offer different features, such as consensus mechanisms, and governance structures, but they generally conform to some level of global standards or industry best practices. The Chain of Trust should be applied also on distributed ledgers. Below are some of the most prominent examples of distributed ledger technologies at time of publication of the present document: 1) Hyperledger Fabric™ (by Linux Foundation®): Part of the Hyperledger project under the Linux Foundation, which is a collaborative effort to create open-source DLT frameworks for enterprise use cases. Consensus Mechanism: Pluggable consensus (supports various consensus algorithms, including Practical Byzantine Fault Tolerance and Raft). Key Features: - Permissioned Ledger: Designed for enterprise use, it operates on a permissioned network, meaning only authorized participants can join. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 40 - Smart Contracts as defined in ISO 22739 [i.3]: Supports on-chain code, enabling automation of business logic. - Privacy and Confidentiality: Offers private channels for confidential transactions between specific parties. - Use Cases: Supply chain management, finance, healthcare, and government services. - Standards Compliance: Follows industry best practices for data privacy, identity management, and cryptographic security. Some implementations also comply with regulatory standards like GDPR [i.7]. 2) Corda® (by R3): developed by R3, a consortium of financial institutions, Corda is an open-source blockchain platform optimized for business and regulatory use cases. Consensus Mechanism: Corda does not use a traditional blockchain structure or consensus mechanism like Proof of Work. Instead, it uses a notary service that ensures transaction uniqueness and validation. Key Features: - Permissioned Network: Like Hyperledger Fabric, Corda is designed for permissioned networks with a strong focus on privacy and security. - Legal Contracts: Supports legal contracts that can be directly mapped into Smart Contracts as defined in ISO 22739 [i.3] and try to capture Smart Legal Contract definitions. - Interoperability: Focuses on interoperability between various systems and across regulatory frameworks. - Use Cases: Financial services (trade finance, payments, insurance), digital identity, and healthcare. - Standards Compliance: Corda is designed with compliance in mind, especially for industries like finance that require adherence to legal and regulatory standards (e.g. GDPR [i.7], ISO standards). 3) Quorum® (by JPMorgan): Standardization: A permissioned blockchain based on Ethereum, but with modifications for enterprise use. Initially developed by JPMorgan, it's now part of ConsenSys. Consensus Mechanism: Supports multiple consensus algorithms, including Raft and Istanbul Byzantine Fault Tolerance. Key Features: - Private Transactions: Quorum allows for private transactions and contracts, making it suitable for businesses that need to keep certain data confidential. - Performance: Enhanced transaction speed compared to the public Ethereum network. - Compatibility: Since it is Ethereum-based, Quorum can run Ethereum Smart Contracts as defined in ISO 22739 [i.3] and leverage existing Ethereum tools. - Use Cases: Banking, supply chain, insurance, and capital markets. - Standards Compliance: Quorum aligns with enterprise-grade security and privacy standards. It can be adapted to meet specific regulatory frameworks like Basel III for banking. 4) Ethereum® (Public Network and Enterprise Ethereum): Ethereum is a well-known public blockchain network that follows decentralized standards but also has an enterprise-focused version known as Enterprise Ethereum under the Enterprise Ethereum Alliance. Consensus Mechanism: Ethereum has moved from Proof of Work (PoW) to Proof of Stake (PoS) with Ethereum 2.0. Key Features: - Smart Contracts, as defined in ISO 22739 [i.3]: Ethereum pioneered the concept of Smart Contracts as defined in ISO 22739 [i.3], enabling decentralized applications and Decentralized Finance (DeFi) projects. - Enterprise Ethereum: Provides privacy, permissioning, and scalability features needed for business use cases. - Use Cases: Public Ethereum is widely used for decentralized applications, NFTs, and DeFi, while Enterprise Ethereum is used in industries like supply chain, healthcare, and finance. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 41 - Standards Compliance: The Enterprise Ethereum Alliance works on creating standards for enterprise use, ensuring compatibility with global industry and regulatory standards (such as ISO standards). 5) Ripple (for XRP® Ledger): Ripple provides a distributed ledger aimed at facilitating fast and cheap cross- border payments and settlements, particularly in the financial industry. Consensus Mechanism: Uses the Ripple Protocol Consensus Algorithm (RPCA), which is different from PoW or PoS. It focuses on agreement between trusted nodes (validators) for transaction validation. Key Features: - High Throughput: Ripple is designed for fast settlement of payments with low transaction fees. - Interledger Protocol: Allows for interoperability between different payment networks. - Use Cases: Cross-border payments, remittances, and currency exchange. - Standards Compliance: Ripple is focused on compliance with financial regulations like know-your- customer, anti-money-laundering, and ISO 20022 [i.73] (a multi part International Standard prepared by ISO Technical Committee TC68 Financial Services) messaging standards. 6) IOTA®: IOTA uses a Directed Acyclic Graph (DAG) structure called Tangle rather than a traditional blockchain. It's focused on IoT (Internet of Things) applications. Consensus Mechanism: There is no traditional consensus mechanism like PoW. Instead, each participant in the network confirms two previous transactions, making it a decentralized and scalable system. Key Features: - Zero-fee transactions: IOTA is designed to enable feeless microtransactions, ideal for IoT devices. - Scalability: The DAG structure allows for theoretically infinite scalability without traditional bottlenecks. - Use Cases: IoT, smart cities, machine-to-machine communication, supply chain management. - Standards Compliance: IOTA is working toward compliance with ISO 9001 [i.8] and ISO/IEC 27001 [i.9] standards for quality management and information security. It is also involved in the Industrial Internet Consortium (IIC) for standardizing IoT solutions. 7) EOSIO®: EOSIO is an open-source blockchain platform known for scalability and speed. It uses a Delegated Proof-of-Stake (DPoS) consensus mechanism. Consensus Mechanism: Delegated Proof of Stake (DPoS), where block producers are voted in by stakeholders. Key Features: - High Performance: EOSIO is designed for high throughput, supporting thousands of transactions per second. Governance: Built-in governance mechanisms allow for dispute resolution and upgrades. - Use Cases: Decentralized applications, enterprise solutions, social networks, and gaming. - Standards Compliance: EOSIO is designed for enterprise use and can be customized to meet various regulatory standards. It supports compliance with GDPR [i.7] and offers built-in mechanisms for on- chain governance. 8) Stellar®: Stellar is an open-source distributed ledger optimized for fast cross-border payments, similar to Ripple. Consensus Mechanism: Stellar Consensus Protocol (SCP), which relies on a quorum of trusted nodes for consensus rather than a traditional mining or staking process. Key Features: - Low Cost: Transactions on the Stellar network is low-cost and settle quickly. - Multi-Currency Transactions: Stellar supports multi-currency transactions and allows for the issuance of digital assets. - Use Cases: Cross-border payments, remittances, microfinance, and tokenization of assets. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 42 - Standards Compliance: Stellar works to comply with global financial regulations like AML®, KYC®, and ISO 20022 [i.73], making it suitable for regulated financial institutions. 9) EBSI: See Clause 4.4.2. 5.5 Deployment and Execution of Smart Contracts and Smart Legal Contracts |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.5.1 Essential Overview | The present clause is about different kind of deployment and execution. Regulation (EU) 2023/2854 [i.1] and Regulation (EU) 2024/1183 [i.2] are rather liberal on those points. • An Electronic Ledger "can be centralized or decentralized". This corresponds to give someone a "free hand" to different kind of deployment and execution environments. • A Smart Contract is "a piece of code". This corresponds to give someone a "free hand" to map a Smart Contract into a SC Source Code or a SC Byte Code, or both, with or without SC Legal Text, with or without identification of publishers of SC Compiler or SC Virtual Machine, or any combination of the above components. • Smart Legal Contract, as defined in the present document, is undefined. However, Regulation (EU) 2023/2854 [i.1] introduces the figure of "vendor of Smart Contracts" that trade Smart Contracts, and introduce a legal responsibility for the behavior of the contract he/she is trading for. The Chain of Trust should fill this gap. The present clause is kept voluntarily short because technical material can be retrieved almost everywhere on academia, web sites, encyclopedias, standardization organizations et al. involved in Computer Science and Data Science. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.5.2 Centralized systems | Centralized data structure and centralized computing are the simplest way to store and execute. They represent the cornerstone of Computer Science and Data Science. Centralized data structures and centralized computing are, by its nature, compatible with the Chain of Trust. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.5.3 Decentralized systems | Decentralized data structure and decentralized computing raised in the '70 in opposition to pure centralized solutions: this non-constructive approach (all that is "not" centralized) make impossible to formally characterize with a single unambiguous definition. Because of the too wide definition of decentralized data structure and decentralized computing, one does not have formal evidences that all decentralized data structure and decentralized computing are compatible with the Chain of Trust. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.5.4 Distributed systems | Distributed data structures and distributed computing raised with the arrival of the network facilities (i.e. Internet) that allows system to communicate each other's. Control is not decentralized. Distributed data structures and distributed computing can be compatible with the Chain of Trust. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.5.5 Peer-to-peer systems | Peer-to-systems raised as an evolution of decentralized systems where data and control are completely distributed. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 43 One does not have evidences that peer-to-peer data structures and peer-to-peer computing can/cannot be compatible with the Chain of Trust. This can change in the future. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.5.6 Cloud systems | According to ISO/IEC 22123-2 [i.66], Cloud is a paradigm for enabling network access to a scalable and elastic pool of shareable physical or virtual resources with self-service provisioning and administration on-demand. Cloud data structures and cloud computing can be compatible with the Chain of Trust. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.5.7 Fog systems | Fog is an improvement of Cloud. Fog was standardized in IEEE 1934 [i.67]. Fog extends Cloud in order to cope with huge number of IoT devices and big data volumes for real-time low-latency applications. Fog data structures and Fog computing can be compatible with the Chain of Trust. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.6 Legal issues in Smart Legal Contracts | |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.6.1 Essential Overview | The present clause is about the concept of Smart Legal Contract (a Smart Contract with legal relevance), in terms of evidence of the script/contract itself: it is relevant to bring the Smart Contract, considered as a simple code script with only technological relevance, into the legal context drawn by both EU Regulations [i.1] and [i.2]. When the computer code, therefore, also acquires legal relevance, it is necessary to validate it through the typical legal-tech tools, read SC Legal Text in the Chain of Trust. Legal systems agree to the, so called, freedom of form principle, namely, requirement that the agreement be made in a specific form in order for it to be valid between the parties. Therefore, smart legal contract can and will count as legal contracts. The present clause contributes to fix some definitions and technical issues that are important to understand the European regulations, fit the future standards and the de facto standards all together. The Chain of Trust should fill this gap. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.6.2 Legal parties | Before thinking the logical flow and surely before the writing the code, the present document discusses legal issues related to the rendering of parties legal will and intensions. For a Smart Legal Contract this analysis is even more critical than a traditional paper or an electronic contract: in fact, Smart Contracts are mostly deployed in a public environment and theoretically usable by anyone: standards are needed to drive the coder, SC Development Team, and the lawyer, SC Legal Team, in order to map all the correct stakeholders. |
142241be1ea90643e055df0a41f4debe | 119 540 | 5.6.3 Certified code translation and evidences | The present document discusses about logical/legal algorithmic faults detected by a TechLawyer, namely a Lawyer with Computer Science skills, able to work in Computer Forensics and able to render legal aspects into logical/diagram flows. The TechLawyer should be able to discern between computer code with no legal relevance and annotated computer code with legal relevance (i.e. a Smart Legal Contract). In a Smart Legal Contract, the legal contract, written in plain English and the contract execution written in computer code cohabitate in the same file stored in the Electronic Ledger. The Chain of Trust can be summarized as follows: • "Plain English" Smart Contract: Smart Legal Contract is - also - a translation of a plain English contract. Standards are needed to grant that this operation is made reducing the risk of misinterpretation of parties' will. • "Flow chart" Smart Contract Logic: while translating the parties' will, standards are needed to decant the plain English logic to a specific script/program. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 44 • "Annotations and Code" Smart Contract: in order to grant the coherence and interpretation of the code, annotation ("comments") can be used directly inside the code. This approach, which needs standardization, is useful to grant interoperability and interpretation of the code itself, from a legal point of view. • Evidence generation and long-term preservation: ledgers and (qualified) archiving are two useful tools to grant resiliency of evidences related to the Smart Legal Contract. They need to be used in this context to facilitate digital forensics to enforce Smart Legal Contracts, even in Courts. |
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