The article deals with the position of blockchain within the framework of trust services defined by EU Regulation 2024/1183 known as eIDAS2. This regulation is a breakthrough that lays the legislative groundwork to bring the use of blockchain, beyond cryptocurrencies, into mainstream industrial and commercial practice. The article introduces trusted services and technologies, the current status of eIDAS2 implementation and the National Blockchain Registry platform, which is the first in the Czech Republic to provide commercial blockchain services as a trusted technology.
Blockchain Electronic indetity eIDAS2 Digital trust NABRE
Authority and trusted services
Ownership and exchange of property have existed since the dawn of civilization. While in small communities, transactions were based on personal trust and custom, the emergence of the first states brought rules to regulate ownership and commercial relations. Institutions arose to enable more secure commercial exchange—from the first codes in Mesopotamia to the standardization of currency.
As the number of business partners grew and direct personal acquaintance diminished, the need emerged for a trusted third party—an independent authority to ensure fairness and legal certainty in transactions. Thus, notaries appeared in ancient Egypt, China, and Mesopotamia. Notries, clerks, and commercial intermediaries were the trusted service providers of their time, sealing contracts and guaranteeing the validity of legal acts.
Initially, the credibility of authority in relation to the applicable law was ensured only indirectly. It was in ancient Rome that state-certified notaries began offering services similar to today's trusted services as defined in contemporary law, such as those outlined in the European eIDAS Regulation or eIDAS2.
Trusted technologies as a tool of authority
To perform trust services, authorities have historically used various technological tools to prevent fraud and strengthen the authenticity of documents and transactions. These technologies included signatures, seals, watermarks, and in modern times, electronic signatures and certificates. However, it is crucial to note that none of these technologies alone constitute a trusted service. Trust arises from the authority that uses the technology and guarantees its validity. For example, a seal only held value if it belonged to a recognized person or institution, just as an electronic signature is only meaningful if issued by a trusted certification authority.
From central authority to decentralised authority
Since antiquity, the provision of trusted services by authorities has had a central character. Whether they were individuals (notaries, scribes), institutions (temples, courts) or national and supranational bodies, these entities provided a guarantee of the authenticity, enforceability and integrity of transactions.
However, in the digital era, there is a shift. Blockchain is the first trusted technology that enables the provision of trusted services without a central authority. While the traditional model required a third party as a trust guarantor, blockchain allows transactions to be verified collectively, through a network of independent nodes. Thanks to this mechanism, it is referred to as a decentralised authority.
Again, it is important to note that blockchain does not provide a trusted service merely by being a trusted technology. Trust is ensured by the owners of the blockchain network's nodes, who verify transactions and maintain the integrity of the records. Blockchain technology enables a situation in which these node owners may not all be trustworthy, and may include fraudsters or criminals. Nevertheless, the blockchain can still provide a trusted service—the network as a whole resists fraud and manipulation. However, not every blockchain is automatically trustworthy. The ability to provide trusted services depends on meeting certain conditions. This requirement is reflected in EU law, which envisions the regulation of blockchain as a trust service.
New trusted services being introduced in the EU
The European Union is also responding to the emergence of decentralised authority and its application in trust services. Until recently, the most well-known trust service regulated by EC regulations was the electronic signature. However, as of May 2024, the new EU Regulation 2024/1183 (eIDAS2) is in force. eIDAS2 is a comprehensive regulation that establishes the framework and conditions for deploying trust services across the EU. Its flagship component is the Electronic Wallet for Digital Identity (EUDI Wallet), which allows citizens to prove their European civic identity and to authenticate and share related documents. Blockchain as a trusted technology was only introduced in eIDAS2 shortly before its adoption. It is first mentioned in paragraph 68 of the preamble. According to reports, the technology was included in response to persistent lobbying by technology companies.
The list of key trusted services and associated technologies defined by eIDAS2 includes:
- Electronic signature + electronic time stamp
The service of providing electronic signature remains unchanged from EU Regulation 910/2014 (eIDAS). - EUDI Wallet (Electronic Wallet for Digital Identity).
Is defined in the Regulation as a harmonised means of authenticating and sharing data associated with the identity of the wallet holder - Electronic Ledger
As defined by the Regulation, an electronic ledger is defined as a sequence of data records that ensures their integrity and the accuracy of their chronological order eIDAS2 does not use the word blockchain anywhere in its text. However, a technical and legal interpretation of this definition identifies blockchain technology with this definition.
Trusted services such as the electronic signature, EUDI Wallet, and blockchain are often mistakenly considered interchangeable. This is not the case. Each service is designed for a different purpose, though it is true that their purposes may occasionally overlap. In summary, the distinctions are as follows:
- Electronic Signature
Linked to a specific individual and their identity. The service guarantees that the individual confirms their relationship to a digital object (e.g., agreement) and the time it occurred. This is achieved by embedding a signature into the object, thereby altering it. This must be considered during signature verification. For this reason, electronic signatures are mostly used for digitized text documents and are digital equivalents of handwritten signatures. The provider of this service is typically a central authority - a provider of electronic signature certificates. - Electronic Wallet for Digital Identity
Also linked to the identity of the wallet owner. It guarantees that the referenced objects (e.g., personal documents, certificates) relate to the wallet holder. eIDAS2 does not specify the technical means of providing this guarantee, leaving it to providers, but it requires verification compatibility across the EU. This implies the involvement of a central authority. - Electronic Ledger
This service differs significantly from the other two. It is not linked to personal identity but rather to a digital object. The provider, which may be a distributed authority, guarantees the integrity and temporal continuity of the record with other entries in the electronic ledger.
Implementation Status of eIDAS2 in EU Member States
EU Regulation 2024/1183 (eIDAS2) is directly applicable across the EU as of its entry into force on 20 May 2024. It does not require transposition into national legislation but does require national implementation through
specific regulations. National implementation is guided by EC-issued implementing acts, which define the parameters of the services under eIDAS2, such as:
- Technical specifications
- Safety and interoperability requirements
- Certification procedures
As previously mentioned, the primary focus of eIDAS2 is the electronic wallet. On 28 November 2024, the EC adopted implementing acts mandating Member States to establish this service within two years (by the end of 2026). In most countries, this process is underway, with national or EU-level support for the development of necessary technologies and certification procedures. No implementing acts have yet been adopted for the electronic ledger. This may be due to the fundamental differences between distributed authority and the central authorities employed for the electronic signature (certificate providers) and the EUDI Wallet (originally planned to be based on the European EBSI blockchain, from which the EC has since retreated). The EC has left it to individual Member States to decide how and with what technology to certify the EUDI Wallet as a trusted service. Given the legal uncertainty surrounding blockchain, consensus on its nature is still evolving. Our company is actively monitoring these developments and preparing the NABRE National Blockchain Registry to meet the requirements of forthcoming implementing acts and national implementations.
NABRE National Blockchain Registry
NABRE is a blockchain platform based on consortium blockchain architecture. It is used to build applications that provide trusted services. It is being prepared for certification as a qualified trust service. However, the core vision of NABRE is broader. Trusted services are needed across government, industry, commerce, and other sectors. NABRE therefore offers more than basic document authentication. It enables the creation of specialized services for vertical markets, which is essential for the commercial success of trusted services.
NABRE offers not only blockchain but also accompanying services. We provide a payment gateway, plan secure storage for customer data, and are developing APIs for integration with AI models. We also aim to enable the use of 5G communication. These additions will help our partners and clients build successful applications.
Building NABRE as a qualified trusted service
As mentioned earlier, implementing acts for the electronic ledger service have not yet been issued, and the blockchain properties necessary for certification as a qualified trust service have not yet been defined. Nevertheless, we are preparing for this certification. We rely on available documents relating to eIDAS and eIDAS2, which highlight the main topics of the implementing acts, such as:
- Architecture and Reference Framework (ARF)
- Reference Implementation
- Security and privacy.
- Interoperability and cross-border use
- Certification and notification
As the implementing acts mostly refer to ISO standards, we have based the design of NABRE and all our blockchain platforms on these standards. Fortunately, ELA Blockchain Services has joined the Technical Standards Committee TNK 754 Working Group on ISO/IEC 307 Blockchain and Distributed Ledger Technology, which is developing standards for DLT. This allows us to stay up to date with emerging standards. We also provide Czech translations of selected standards for the Czech Standards Agency (CSA).
We consider ISO 23257:2022 on blockchain reference architecture, and supporting technical reports such as ISO/ TR 23244:2020 on privacy, to be key standards for certification. We anticipate that the forthcoming implementing acts for eIDAS2 will also be based on these. Other standards and reports tend to focus on specific blockchain applications and are heavily influenced by the world of cryptocurrency and NFTs. We are preparing the NABRE platform for use in industrial, commercial, and service sectors rather than finance. We also consider EC Regulation 2023/2854 (Data Act), effective from January 2024, to be important as it regulates data storage outside the EU. For this reason, NABRE is a consortium blockchain with designated node owners who manage the physical location of the blockchain hardware.
NABRE Architecture
As mentioned, the architecture is based on ISO 23257:2022 and implemented as a consortium blockchain built on Hyperledger Fabric technology. Hyperledger Fabric is designed with ISO standards in mind. ISO 23257:2022 outlines the internal and external service architecture of a blockchain node. We follow the same layered model in NABRE but present it in a more user-friendly way, as shown in the following figures.
Layer model
The software layer model of a blockchain node as shown on fig. 1 includes all the service groups required by ISO 23257:2022. Smart contracts in Hyperledger Fabric are managed within a secure chaincode layer, typically written in the Go language. Unlike the scripting used in public blockchain smart contracts, chaincode allows for easier implementation of non-financial applications. We frequently use finite-state machines to control systems on the blockchain.
Features across layers
Many features described in ISO 23257:2022 are already partially implemented in the Hyperledger Fabric core. For example, strong consortium management is built-in. In platforms derived from cryptocurrency blockchains, consortium management is more complex due to their origin in public networks with anonymous node owners and independent developers. Hyperledger Fabric includes a powerful policy management tool that allows consortium members to enforce immutable rules for lifecycle management.
Services Beyond the DLT
Other functions beyond blockchain as defined by ISO 23257:2022 are provided in NABRE by the infrastructure our company has built behind the blockchain platform (fig. 2) In coordination with policies, it provides installation, update and upgrade of the nodes' software. It also includes tools for non-participatory network management, which we will discuss later.
Fig. 2: EBS infrastructure to support the blockchain platform
Services outside the DLT
ISO standards also define other services beyond the DLT core. Typically, these include oracles. Hyperledger Fabric handles such external services differently. In the NABRE model, these are mainly support services for partner applications on the platform. These include a payment gateway for customer transactions, various identity login options, secure data storage under development, APIs for AI model integration, and future 5G communication options. These services support the development of market-specific applications and are critical to the commercialization of trusted services for small and medium-sized enterprises. This approach mirrors the commercial deployment of AI following initial experimentation.
Building decentralised authority
Architecture alone does not guarantee the trustworthiness of the service. As previously mentioned, authenticity and integrity in blockchain records under eIDAS2 depend on node owners, their conduct, and the technical mechanisms that establish distributed authority. Unlike centralized authorities, whose trustworthiness is often evaluated subjectively (e.g., reputation), distributed authority can be assessed objectively using specific parameters. A detailed analysis of trust in public (permissionless) and consortium (permissioned) blockchains is beyond this paper's scope. In brief, public blockchain trust relies on mathematical probability and a large number of anonymous node owners. Consortium blockchains, with fewer nodes, must deliberately build and maintain their distributed trust. Hyperledger Fabric provides the necessary tools, such as blockchain policies. We at ELA Blockchain Services have long developed technologies and processes to build high-trust distributed systems. Our concepts include BaAC (Blockchain as Assisted Consortium) and nAA (Non-Aligned Administration), which help achieve a level of trust in permissioned blockchains comparable to large global public blockchains.
We believe that the NABRE platform, together with our existing certifications (ISO 9001:2015, EN ISO/IEC 27001:2017), will meet the standards required to be certified as a qualified trusted service.
Fig. 3: NABRE platform business model
NABRE platform business model
It combines the NABRE blockchain with a client-facing environment where applications are hosted as shown on Fig. 3 Consortium members, found at the top left of thecNABRE structure, act as trust providers. They own the nodes of the blockchain network and establish the distributed authority used by:
- Direct B2B users who use it for internal purposes and have no end customers
- B2C application providers who create trusted services for commercial applications targeting end users
The platform includes a single payment gateway, used by both direct users and end customers to pay for services. A unified credit system allows any user to access any application. For companies preferring other payment methods, we provide debit accounts for invoiced transactions.
The payment process operates via smart contracts that track credit consumption in each provider's application. Based on preset parameters, the smart contract calculates how payments are split between the application provider, the node owner, and our company as the platform administrator. At month’s end, the smart contract issues a clearing statement, which the administrator uses to distribute payments. Because these calculations are performed within smart contracts, the administrator cannot alter them. Any changes to smart contracts must be approved by the consortium, and without this approval, no software updates can be made. This ensures that the consortium retains full control over the business model. We believe this transparent and tamper-proof method is the future of application governance in industry and commerce.
Fig. 4: Gartner Hype Cycle for Industrial Blockchain
Current applications at NABRE
Several applications developed by our clients are already operational on the NABRE platform, primarily for authenticating issued declarations, certificates, or attestations.
Direct User Applications with Distributed Authority:
- A group of companies importing medical equipment authenticates the certificates of the equipment sold at NABRE. Each customer can check at any time whether the certificate belonging to the purchased device is genuine and valid.
- The Czech Accreditation Institute o.p.s. (CAI) authenticates in a similar way the Certificates of Accreditation issued by NABRE to accredited conformity assessment bodies (laboratories, certification and inspection bodies), which thus prove their competence for activities within the scope of accreditation. In the future, the possibility of linked authentication of the outputs of conformity assessment bodies with CIA accreditation is planned, so that customers can also verify whether the body had accreditation when issuing this output (protocol, certificate, report). For this service, the CAI will develop and then offer its own application to clients.
- The Electrical Association of the Czech Republic is launching a pilot project using NABRE to authenticate inspection reports for electrical equipment, again linked to the certificate of the inspection engineer who carried out the inspection. The authenticity of the inspection report will be publicly verifiable.
Applications by ELA Blockchain Services:
- A digital delegate is an application that authenticates video recordings of important processes, replacing a supervising commissioner to check its progress. An interesting application is the authenticated video recording of the packing and sealing of a shipment to one of the problematic regions where fraud and unauthorized claims occur. One of our customers used this to put an end to constant disputes with the consignee over alleged discrepancies between the contents and the bill of lading. Just having authenticated video footage that can be used in a potential lawsuit deters fraud attempts. The digital delegate can also be used, for example, to record certification tests (e.g., on simulators), for regulated or otherwise important professions, the handover process of important technical equipment by a supplier, and in many other cases.
- At NABRE, we also run a voting application that ensures anonymity and full auditability of the voting process.
Conclusion
We consider the release of the eIDAS2 regulation to be a pivotal moment accelerating the integration of blockchain into daily life. It enables innovation and opens new business and investment opportunities. The release coincides with blockchain's ascent in the Gartner Hype Cycle toward real productivity. ELA Blockchain Services was founded during the peak of inflated expectations, when major projects such as MAERSK TradeLens and Australia BeefLedger were emerging. After a decline in industrial blockchain interest, attention shifted to cryptocurrencies and NFTs.
We believe several factors are now steepening blockchain’s rise:
- The adoption of eIDAS2, establishing a legal framework for industrial and commercial blockchain use
- The decline of NFTs, leading crypto companies to explore alternative markets
- Rising demand for data authentication in the age of AI and cybersecurity
Based on our experience, we launched the NABRE project last year. Developments at the turn of this year indicate a high likelihood of success. We continue to seek major players in trust technologies to join the NABRE consortium. The current landscape presents an exciting new business opportunity.
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