By Harald Zwingelberg and Jan Schallaböck

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Within the research project Attribute based Credentials for Trust (ABC4Trust) the legal research task concentrated on requirements, concepts and further aspects for privacy-preserving methods for identification and authentication. The European Commission proposed a Regulation on electronic identification and trust services for electronic transactions in the internal market (eIDAS). The Authors like to use the opportunity to provide insights from a privacy and data protection perspective to for the legislative process based on the expertise gained within the ABC4Trust project. The three core aspects addressed herein are: I. Emphasize the concept of authentication instead of identification II. Remove barriers for privacy-preserving eID solutions III. Clarify applicability of data protection requirements also for eID services The findings leading to this document has been used to discuss the position with stakeholders in the European parliament and the European Commission.