Open vilmosa opened 2 months ago
Thank you for your input. We believe there are some misunderstandings regarding the role of status lists:
Please let us know if this answers your questions.
"a verification of a status list ensures that the Attestation Provider did not revoke the attestation." True, this is the main purpose of the Status List. But if the List is not accessible there is no way to verify the validity of the attestation. RPs have the right/obligation to perform such a check. If this requirement cannot be met the regulation is not fulfilled.
"Status lists, like standard CRLs for certificates, can (and will) be cached by Relying Parties" This is an unrealistic assumption and nowhere stated. Wallets are foreseen to be used cross border. No one can expect RPs to download status list(s) of multiple countries. Furthermore private persons will be RPs as well in P2P transactions. They definitively will not store in their smart phones 27+ Status Lists.
It just should be realized that Status Lists were not intended for such purposes which these should serve now.
A status list could be provided from any Attestation Issuer, thus it could be Attestation Provider = separate status list, it's not stated otherwise in ARF.
According to the eIDAS 2 regulation "Relying Parties shall be responsible for carrying out the procedure for authenticating and validating person identification data and electronic attestation of attributes requested from European Digital Identity Wallets". According to the ARF there are status list which will facilitate the validation. However these lists cannot be reached if RPs are offline, therefore in such transactions the technical conditions for validation are missing. The use of status lists does not comply with the legal requirements. Alternative methods should be used which can better guarantee the validity and integrity of PIDs and attestations. A trust chain from provider through user to verifier would be a more suitable solution.