Consultation on the proposal for the new e-ID law

The Federal Council opened the consultation on the proposal for a new e-ID law. digitalswitzerland notes that the proposal for a new e-ID law resonates broadly with our members by setting the framework for a trust infrastructure whose core element is a government-issued e-ID. digitalswitzerland welcomes the strategic direction of the preliminary draft.

However, we are convinced that electronic identity can only become widely accepted in Switzerland if it is embedded in an inclusive ecosystem of electronic credentials. We consider it essential to include this aspect in the purpose article of the law. We also consider the regular audit of state-operated infrastructure, a vehicle for expert input on technological law implementation, fee structure according to international standards, and regulation of private confirmation mechanisms to be useful.

A brief summary of the key proposals:

1. Equal status for e-ID and e-ID ecosystem.
   Ensure that the e-ID, as the main credential of the ecosystem, thrives in a broad ecosystem that includes the private sector. The law should express this intention more clearly.
2. Expert input on the technological implementation of the law
   Create an instrument that allows for the involvement of experts from academia and industry in the implementation of the law (e.g. UX, security).
3. Fee structure according to international standards
   Follow internationally accepted principles for connectivity of SSI networks and make them free of charge for users (e.g. Sovrin Foundation rulebook).
4. Regulate private confirmation mechanisms
   Ensure that sector-specific trusted third parties or organisations can continue to perform their function in the digital ecosystem (e.g. swissuniversities).
5. Cybersecurity from the very beginning
   Check the structure of the Fedpol system for issuing E-IDs technically and procedurally for security issues. This should be anchored in the law.

The full statement can be found here in German and French.