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eIDAS 2 is more than a legal update. Regulation (EU) 2024/1183 extends the European trust-services framework and introduces Electronic Archiving as a trust service in its own right. It also creates a common European basis for Qualified Electronic Archiving.
This article explains what changed, what the new legal effect means and how the Regulation, the implementing rules and technical standards fit together.
Last reviewed: July 2026.
From eIDAS 1 to eIDAS 2
Regulation (EU) No 910/2014, commonly called eIDAS 1, established a harmonised legal framework for electronic identification and trust services across the European Union. It covered services such as electronic signatures, electronic seals, timestamps, registered delivery and website authentication.
It also established the principle that an electronic document cannot be denied legal effect or admissibility as evidence solely because it is electronic.
The first framework did not fully address every aspect of long-term digital trust. Organisations still faced fragmented identity schemes, limited cross-border adoption and uncertainty about preserving digital records and signature evidence over long periods.
Regulation (EU) 2024/1183, commonly called eIDAS 2, expands the framework. Among other changes, it introduces:
- the European Digital Identity Wallet;
- Electronic Attestation of Attributes;
- Electronic Archiving services;
- Electronic Ledgers;
- additional rules for remote signature and seal creation devices.
Electronic Archiving under eIDAS 2
Electronic Archiving is defined as a service for the receipt, storage, retrieval and deletion of electronic data and documents to ensure durability and legibility, while preserving integrity, confidentiality and proof of origin throughout the preservation period.
The framework distinguishes between electronic archiving services and qualified electronic archiving services.
Legal effect
Article 45i states that electronic data and documents cannot be denied legal effect or admissibility as evidence solely because they are electronic or are not preserved using a qualified service.
Data and documents preserved using a Qualified Electronic Archiving service benefit from a presumption of integrity and origin for the preservation period managed by the Qualified Trust Service Provider.
This distinction is important. A non-qualified archive may still provide useful evidence, but a qualified service operates under regulated requirements and provides the legal presumption defined by eIDAS.
The three layers of the framework
1. The Regulation defines the legal outcome
Regulation (EU) 2024/1183 introduces the trust service and defines the required legal effect and high-level obligations. It is deliberately technology-neutral: it states what must be achieved rather than prescribing one implementation.
2. The implementing rules identify reference standards
Commission Implementing Regulation (EU) 2025/2532 sets reference standards and specifications for Qualified Electronic Archiving services. It also addresses documents containing Qualified Electronic Signatures or Qualified Electronic Seals.
When such documents are archived, their trustworthiness must be maintained beyond the technological validity period of the signature or seal, at least until the end of the legal or contractual preservation period. A Qualified Electronic Archiving provider may rely on a qualified preservation service for qualified signatures or seals.
3. Standards translate the obligations into auditable controls
The European framework refers to standards and specifications including CEN/TS 18170:2025, ETSI EN 319 401 and ISO 14721, the OAIS reference model.
These sources serve different purposes:
- OAIS (ISO 14721) provides the conceptual model and vocabulary for long-term digital preservation, including Submission, Archival and Dissemination Information Packages.
- CEN/TS 18170:2025 defines archiving-specific functional, operational and procedural requirements for Electronic Archiving Trust Services.
- ETSI EN 319 401 provides general policy and security requirements for Trust Service Providers.
- ETSI TS 119 511 defines policy and security requirements for trust service providers offering long-term preservation of digital signatures or seals.
- ETSI TS 119 512 defines protocols for long-term preservation services for digital signatures and seals.
Together, these layers connect legal outcomes, trust-service governance and preservation operations.
Electronic Archiving and signature preservation
Electronic Archiving and preservation of electronic signatures are related, but they are not identical.
Signature preservation maintains the evidence required to verify Qualified Electronic Signatures and Qualified Electronic Seals beyond the lifetime of certificates, algorithms and trust infrastructure.
Electronic Archiving governs the broader record lifecycle: receipt, metadata, integrity, confidentiality, access, retention, retrieval and deletion. A qualified archive containing signed documents may use a qualified signature-preservation service to maintain the trustworthiness of those signatures or seals.
What organisations should do now
Organisations do not need to wait for an archive problem to become an audit problem. A practical preparation programme should:
- identify records that must remain trustworthy beyond the lifetime of their source systems;
- map legal, contractual and sector-specific retention obligations;
- determine which records contain signatures, seals or other time-sensitive evidence;
- assess whether the current archive preserves integrity, origin, metadata and long-term readability;
- verify how retention, legal hold, retrieval and controlled deletion are evidenced;
- evaluate when a qualified service and its legal presumptions are required;
- require providers to substantiate qualification status and scope through current Trust List evidence.
What eIDAS 2 means in practice
The direction is now clear: long-term electronic evidence is moving from a patchwork of national approaches towards a harmonised European trust-service framework.
For regulated organisations, this affects archive strategy, application retirement, signed records and the evidence required for audits or disputes. The question is no longer whether electronic records need active preservation, but which records require qualified assurance and how the archive will demonstrate compliance over time.
Read the technical follow-up: How eIDAS 2, the Implementing Act and CEN/TS 18170:2025 Fit Together.
Explore Qualified Electronic Archiving and preservation of electronic signatures and seals.
