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5.1 Essential Overview
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IEEE Standards Association (IEEE-SA): the IEEE is working on developing blockchain and distributed ledger standards through the P2418 working group. They focus on areas such as digital asset management, blockchain for supply chains, and Smart Contracts. There are multiple standardized distributed ledger technologies, each with its specific features and applications. The choice of DLT depends on the use case, such as financial services, supply chain, IoT, or decentralized applications. These DLTs are often developed under open-source projects or standardized by international bodies like ISO and IEEE, ensuring that they adhere to global standards for security, privacy, and interoperability.
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4.3.5.2 Terminology
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None.
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4.3.5.3 Chain of Trust
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The IEEE SA P2418 working group did not publish any document.
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4.4 Projects, Programs and Initiatives
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4.4.1 Digital Europe Program
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4.4.1.1 Essential Overview
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The Digital Europe Program (DIGITAL) is an EU initiative designed to accelerate the integration of digital technologies into businesses, public administrations, and society. DIGITAL aims to enhance Europe's digital resilience by supporting projects in key areas like supercomputing, artificial intelligence, cybersecurity, and digital skills. This program is instrumental in reducing Europe's dependence on external digital solutions and strengthening the EU's digital infrastructure and capabilities. DIGITAL supports industry, enterprises and fosters digital transformation across various sectors through initiatives. The program aligns with the EU's broader goals outlined in the 2030 Digital Compass and works in synergy with other EU funding mechanisms, including Horizon Europe and the Connecting Europe Facility, as part of the Multiannual Financial Framework 2021-2027. The Digital Europe Program funds several projects focused on acceleration of eIDAS, EUDI Wallet and related trust services but also distributed ledgers, and Smart Contracts ISO 22739 [i.3] used for several use cases e.g.: • Large Scale Pilots on EUDI Wallet • Projects on the European Blockchain e.g.: ETSI ETSI TR 119 540 V1.1.1 (2025-10) 22 - EBSI VECTOR - OnePass - EBSI-NE - TRACE4EU • Projects for support of Standardization: - Blockstand - Seeblock
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4.4.1.2 Terminology
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Smart Contracts and distributed ledgers as defined in ISO 22739 [i.3].
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4.4.1.3 Chain of Trust
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Digital Europe Program, as per the publication date of the present document, is agnostic with respect to the Chain of Trust. This can change in the future.
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4.4.2 EBSI
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4.4.2.1 Essential Overview
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The project, which was set up in 2018, aims to lay the foundation for future distributed ledger-based services within the EU and EFTA. The EBSI was transitioned into a new organizational entity for the operations of EBSI, named the European Digital Infrastructure Consortium (EDIC). The EBSI run by nodes operated by member states. Each country is expected to operate at least one node of EBSI at full scale. This approach aligns with the decentralized nature of blockchain technology and is suitable for multi-party cooperation. EBSI ensures a governmental trust anchor and so clear responsibility on the other hand this approach leads to the question on how such a network might be provided (QTSP for Electronic Ledger) or used (by EUDI Wallet Issuer or QTSP using DLT) by a certain provider. With the introduction of eIDAS2 and the concept of Qualified Electronic Ledgers, the EBSI could potentially not only evolve from an Electronic Ledger into a Qualified Electronic Ledger enhancing security and reliability of the network, but also providing legal certainty for use cases that build on the EDIC's Electronic Ledger. EBSI contains a comprehensive technical framework on: • Issuance, verification, revocation and presentations of verifiable credentials or attestations in terms of eIDAS • Interoperability of wallets • DID methods • Timestamps • API • Governance for issuers and verifier (relying parties) Currently there`s no possibility to implement and run Smart Contracts, as defined in ISO 22739 [i.3], on the EBSI infrastructure but this might change in future. The EBSI framework can automate processes like identity verification and product tracking, ensuring transparency and efficiency. For example, by using the Track and Trace API, it is possible to verify goods automatically at each stage, reducing manual checks and enhancing security across borders. The API might be extended to Smart Contracts in future. Recently (27 March 2025) it was announced that Smart Contracts, as defined in ISO 22739 [i.3], could be successfully deployed.
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4.4.2.2 Terminology
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Smart Contracts and distributed ledgers as defined in ISO 22739 [i.3]. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 23
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EBSI, as per the publication date of the present document, is agnostic with respect to the Chain of Trust. This can change in the future.
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4.4.3 EUDI Wallet
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4.4.3.1 Essential Overview
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The European Digital Identity Wallet (EUDI Wallet) is a key component of the eIDAS2 Regulation (EU) 2024/1183 [i.2]. The EUDI Wallet is designed as a secure and user-centric digital identity solution that allows citizens and residents of the European Union to authenticate their identity and access a wide range of online services, both public and private. The wallet can store and manage various forms of electronic attestations, including Person Identification Data (PID), Qualified Electronic Attestations of Attributes (QEAA), Electronic Attestations of Attributes (EAA) and Electronic Attestations of Attributes provided on behalf of the public sector bodies (EAA-Pub) like mobile Driving Licenses (mDLs). The EUDI Wallet prioritizes privacy and security by design, ensuring that users have control over their personal data. It supports high levels of assurance for identity verification, which is critical for accessing services that require strong authentication. The wallet can be used across borders within the EU, fostering interoperability and ensuring that it functions seamlessly in different member states. The Toolbox is a comprehensive set of technical specifications, standards, guidelines, and best practices developed to ensure the consistent implementation of the European Digital Identity Framework (eIDAS2) across the EU. The Toolbox serves as a reference for member states, helping them align their national digital identity systems with the European framework. The infrastructure component of the eIDAS2 refers to the underlying technical and organizational structures that support the operation and use of the EUDI Wallet across the EU. This includes the roles of various stakeholders, the systems they operate, and the interfaces between these systems: • EUDI Wallet Providers are entities, typically mandated by member states, responsible for providing and maintaining the EUDI Wallet solutions. They ensure that the wallets are compliant with the ARF's requirements and that they securely manage users' personal data and digital credentials. • Person Identification Data (PID) Providers - trusted entities that verify the identity of users and issue PIDs to be stored in the EUDI Wallet. These providers play a critical role in ensuring that the identities within the wallet are accurate and trustworthy. • Electronic Attestation of Attributes (QEAA, EAA-Pub, EAA) Providers - qualified and non-qualified Trust Service Providers (TSPs) that issue electronic attestations, such as diplomas or licenses, which can be stored in the EUDI Wallet. They ensure that the attributes linked to a user's identity are accurate and legally recognized. • Relying Parties - the entities that request and rely on the identity and attribute data stored in the EUDI Wallet to provide services. They interact with the wallet through secure interfaces to verify users' identities and attributes. The infrastructure also includes mechanisms for managing trust across the ecosystem, such as Trusted Lists and Certificate Authorities (CAs), which ensure that only authorized entities can issue and verify digital credentials. Smart Contracts can play a potentially transformative role in the EUDIW under eIDAS2 by automating and enhancing the security, privacy, roles, and trustworthiness of digital transactions.
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4.4.3.2 Terminology
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Smart Contracts, SC Provider, SC Publisher. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 24
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4.4.3.3 Chain of Trust
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EUDI Wallet, as per the publication date of the present document, is agnostic with respect to the Chain of Trust. This can change in the future.
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4.5 Others
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4.5.1 eIDAS Toolbox- Architecture and Reference Framework (ARF)
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4.5.1.1 Essential Overview
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Architecture and Reference Framework (ARF) for the European Digital Identity (EUDI) Wallet [i.17] is part of the European Union's initiative to create a standardized and secure digital identity system based on eIDAS2 regulation. The ARF is a draft prepared by the eIDAS Expert Group and provides the technical architecture, standards, and guidelines necessary for implementing the EUDI Wallet. It covers the roles and responsibilities of various stakeholders, including Wallet Providers, Person Identification Data (PID) Providers, and Qualified Electronic Attestation of Attributes (QEAA) Providers. The document also details the design principles, such as user-centricity, interoperability, privacy by design, and security by design, which are essential for the successful deployment of the EUDI Wallet.
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4.5.1.2 Terminology
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Smart Contracts, Electronic Ledger.
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ARF is agnostic with respect of the Chain of Trust.
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4.5.2 INATBA
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4.5.2.1 Essential Overview
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4.
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5.2.1 Essential Overview
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The International Association for Trusted Blockchain Applications (INATBA) offers public and private developers and users of DLT a global forum to interact with regulators and policymakers and bring blockchain technology to the next stage. INATBA facilitates positive change in the blockchain ecosystem. INATBA supports and promotes members to bridge public and private entities and promote global blockchain adoption across diverse fields such as law, finance and education.
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4.5.2.2 Terminology
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Smart Contracts and distributed ledgers as defined in ISO 22739 [i.3].
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4.5.2.3 Chain of Trust
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INATBA as per the publication date of the present document, is agnostic with respect to the Chain of Trust. This can change in the future.
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4.5.3 ENISA: Digital Identity Standards
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4.5.3.1 Essential Overview
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4.
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5.3.1 Essential Overview
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ENISA is an agency of the European Union. The ENISA Digital Identity Standards [i.18] publications serve as a comprehensive analysis of the various standardization requirements that support cybersecurity policies, particularly in the realm of digital identity. The standards discussed encompass a broad spectrum, including policies, services, formats, protocols, and security requirements necessary for managing digital identities. These standards are essential in ensuring the security, reliability, and cross-border recognition of digital identities, which have become increasingly crucial due to the rise of digital services and electronic transactions, especially accelerated by the COVID-19 pandemic. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 25 The documents outline the key areas covered by digital identity standards, which include identity management, trust services, authentication capabilities, and supporting services, and discuss the role of various standardization bodies, such as the European Telecommunications Standards Institute (ETSI), International Organization for Standardization (ISO), and national organizations like the National Institute of Standards and Technology (NIST) in developing these standards. Additionally, the documents highlight the evolution of digital identity standards from focusing on basic technical aspects like protocols and formats to addressing more complex issues such as cryptographic security, biometrics, and self-sovereign identities. The analysis within the documents also delves into specific standards used in identity management, such as the ISO/IEC 24760-1 [i.70] series, which provides a framework for identity management, and ISO/IEC 29115 [i.71], which offers guidelines for entity authentication assurance. They also further examine the standards related to trust services, such as ETSI's standards for trust service providers, which are crucial for ensuring that digital transactions are secure and that digital identities can be trusted across different platforms and borders. The documents also provide with a set of recommendations aimed at European policymakers, standardization organizations, and cybersecurity agencies like ENISA, advocating for the continued development and adoption of robust digital identity standards to support the evolving landscape of digital transactions and cybersecurity needs. Because of the intrinsic role of ENISA and the cruciality of having Smart Contracts secure, identity issues in Smart Contracts will be subject of study in the future.
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4.5.3.2 Terminology
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Smart Contracts, Electronic Ledger.
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4.5.3.3 Chain of Trust
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ENISA, as per the publication date of the present document, is agnostic with respect to the Chain of Trust. This can change in the future. 5 A Chain of Trust in support of Smart Contracts and Electronic Ledgers 5.1 Essential Overview The present clause describes the processes involved in building, deploying, and executing a Smart Contract computer program on an Electronic Ledger. It formally identifies all the relevant actors, artifacts, hardware, networks and tools, emphasizing the critical points where governance, safety, security, and identity issues are required. This is done by means of a novel and as yet unpublished Chain of Trust, considering all involved entities. The security of Smart Contracts can be significantly compromised by an incomplete validation chain, which exposes users to various risks, including fraud and attacks. Ideally, the Chain of Trust occurs at many abstraction levels: • SC Language entities. Responsible to ensure that the design and the certification of a programming language used to encode the logic of a Smart Contract is not left to unknown not traceable communities. • SC Tools. Responsible to ensure that the encoding and the certification of software tools like, e.g. a SC Compiler and a SC Virtual machine is not left to unknown not traceable communities. • SC Legal entities. Responsible to ensure that the process of encoding and the certification of a Smart Contract will be clearly identified and traceable. • SC Published entities. Responsible to ensure that the process of making available a Smart Contract on the market will be clearly identified and traceable. • Electronic Ledger. Responsible to ensure that the process of running a Smart Contract on an Electronic Ledger will be clearly identified and traceable. • Underlying networks. Responsible to ensure that the network infrastructure where distributed data structures, like Electronic Ledgers, will be clearly identified and traceable. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 26 • Hardware. This point, although essential, is not treated in the present document. One of the main findings from the analysis of the Data Act [i.1] and eIDAS2 [i.2] and its consequences to the standardization of Smart Contracts and Electronic Ledgers is that in order to satisfy the European rules for transparency and accountability, the actors of Electronic Ledgers and Smart Contracts should be identifiable according to Data Act [i.1] and eIDAS2 [i.2], respectively. More precisely, Smart Contracts should be strictly governed to give legal value, as per Smart Legal Contract definition in Clause 3.1. The same considerations for governance apply for Electronic Ledgers, that should be permissioned. This governance issue is independent for an Electronic Ledger to be centralized, cloud-based, or distributed, or any other of future technological implementation. In parallel, eIDAS tools like Advanced Electronic Signatures (AdES) and Qualified Electronic Seals (QSeal) offer essential mechanisms for authenticating data and signing documents. AdES, which is uniquely linked to the signatory and created in a way that ensures their exclusive control, is fundamental in scenarios where Smart Contracts automate large-scale transactions. The use of AdES guarantees that each transaction is verifiably authentic and legally binding. These tools ensure traceability, authentication, and compliance with regulatory standards, providing a solid legal foundation for Smart Contracts in regulated environments. A primary requirement for the use of Smart Contracts in the EU is to give assurance that in the event of a dispute that the parties to the Smart Contracts can be identified. The eIDAS2 framework is an existing framework that offers these capabilities and the role of eIDAS in Smart Contracts is described in ETSI TS 119 542 [i.16]. A suitable quality measure would be the adoption of Common Criteria [i.5], with a focus on Evaluation Assurance Levels (EAL) and Protection Profiles. These levels range from EAL1, which represents basic security, to EAL7, which provides the highest level of security, suitable for systems operating in high-risk environments. Protection Profiles specify security requirements for particular categories of products or systems, such as Smart Contracts managing sensitive transactions. For instance, a Smart Contract designed to handle financial transactions might be evaluated at EAL4, at least, ensuring a high level of security through methodical testing and vulnerability assessments. This would mitigate risks such as unauthorized access or data manipulation. For the Chain of Trust, a proper validation, or at the very least, the identification of the tools used at each stage of the process, is essential. The toolchain identifies the following entities: Software: Validating or at least identifying the authors, is essential to guarantee that an algorithm can be designed, coupled with some legal enforcements, translated into runnable code by a certified compiler, deployed on a Qualified Electronic Ledger, and executed on the top of a certified virtual machine, using certified inputs. This concretizes the concept, not standardized yet, of Smart Legal Contract. Hardware: Validating or at least identifying the hardware (silicon) platforms involved is also crucial. However, deployment presents a more complex challenge, as validation or identification during the deployment phase often depends on the specific type of Electronic Ledger being used, and in some cases, it can be difficult or even impossible. Networks: Validating or at least identifying the underlying network providers at each stage is essential and should be practically feasible. A Smart Contract is a complex entity that has legal impact and which if compromised will seriously impact the relying parties. In recognizing this, the Smart Contract can be classified as requiring substantial or high-levels of assurance as defined in the Cyber Security Act [i.68], and this should be provided by conformance to an approved assurance scheme as defined by the Cyber Security Act, e.g. the EU Cybersecurity Certification Scheme on Common Criteria [i.69], managed by ENISA. Governance aspects of the overall security are given in ETSI TS 119 541 [i.12] that addresses the role of assurance schemes.
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5.2 SC main entities
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5.2.1 Essential Overview Table 1 summarizes the Chain of Trust, in its first version V1, as a numbered set of interactions between entities, results produced, identification and assurance needs. Each rule, represented as a line in the Table, defines a precise interaction between two or more entities. The intuitive meaning of each column is: • Entity: identifies each participating entity in the generation of a result which may be an object or a running Smart (Legal) Contracts on a (Qualified) Electronic Ledger. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 27 • Entities it interacts with: identifies the entities with which the former entity interacts with or uses (in the case that the entity is an object, a program for instance) for producing the mentioned result. • Result produced: identifies the result produced by the entities in the first and second column. • Identification needs: requirements for identification of legal/natural persons responsible for a process and requirements for assuring the identity using electronic signatures/seals and/or identity authentication. This is addressed in ETSI TS 119 542 [i.16] which is expected to specify the requirements for identification of the mentioned entities and the requirements for the signatures on the Smart Contracts. • Assurance needs: requirements for assuring the security and correct operation of a process. This is addressed in ETSI TS 119 541 [i.12] which is expected to specify the policies under which the required certification operations are carried out. NOTE 1: Entities in the Chain of Trust can overlap each other. NOTE 2: Rules in the Chain of Trust may be valid in any order. NOTE 3: Rules in the Chain of Trust should not contradict each other over the time. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 28 Table 1: The Chain of Trust V1 # Entity Entities it interacts with Result produced Identification needs Assurance needs SC Production 1 SC Language Specification Team SC Language Publisher SC Language Specification Signed by SC Language Publisher • Correctness of syntax and semantics of SC Language Specification. • Respect of SC Language Specification Policy. SC Language Specification Policy Signed by SC Language Publisher 2 SC Compiler Team SC Language Publisher SC Compiler Publisher SC Compiler Signed by SC Compiler Publisher • Semantic preservation of the SC Compiler against SC Language Specification. • Respect of SC Compiler Development Policy. SC Compiler Policy Signed by SC Compiler Publisher 3 SC Virtual Machine Team SC Language Publisher SC Virtual Machine Publisher SC Virtual Machine Signed by SC Virtual Machine Publisher • Semantic preservation of the SC Virtual Machine against SC Language Specification. • Respect of SC Virtual Machine Development Policy. SC Virtual Machine Policy Signed by SC Virtual Machine Publisher 4 SC Developers Team SC Legal Team SC Publisher SC Package including SC Byte Code, SC Source Code, SC Legal Text, and SC Documentation Signed by SC Publisher • Assurance that SC Source Code, SC Byte Code, SC Legal Text, and SC Documentation meets the SC Development Policy. • Assurance that the SC Source Code, SC Byte Code, SC Legal Text, and the SC Documentation are identified by SC Publisher. • Assurance that the employed SC Compiler and SC Virtual Machine comes from a SC Compiler Publisher and SC Virtual Machine Publisher respecting the SC Compiler Policy and SC Virtual Machine Policy. SC Development Policy Signed by SC Publisher SC Deployment 5 SC Publisher SC Provider SC Package including SC Byte Code, SC Source Code, SC Legal Text, and SC Documentation SC Provider and SC Publisher mutual identification • Assurance that SC Package comes from a SC Publisher. 6 SC Provider SC Deployer Evidence of legal terms of SC Deployer SC Provider and SC Deployer mutual identification • Assurance of legal terms of SC Deployer. 7 SC Deployer Electronic Ledger Electronic Transaction in a Electronic Ledger containing the SC Package SC Deployer identified by Electronic Ledger • Assurance that SC Package comes from a SC Deployer. SC Execution 8 SC User SC Provider • Evidence of SC Legal Text from a SC Package. • Evidence of legal terms of SC Provider. • SC User inputs. SC User and SC Provider mutual identification • Agreement of legal terms of SC Provider. • Agreement of SC Legal Text. 9 SC Provider Electronic Ledger Electronic Transaction in a Electronic Ledger SC Provider identified by Electronic Ledger • Assurance of the truthfulness of inputs from SC User and inputs from SC Oracles and transactions for the Electronic Ledger ETSI ETSI TR 119 540 V1.1.1 (2025-10) 29
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5.2.2 SC Language Specification
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The semantics of programming languages, especially for domain specific languages for writing Smart Contracts, is fundamental to understand the execution in Electronic Ledger. The semantic rules of a programming language determine how its syntax is interpreted into actions to be performed. In the context of Smart Contracts, where transactions and contractual obligations are executed automatically, the clarity and precision of these semantics are indispensable. They should be unambiguous and comprehensive to prevent errors and security breaches. The use of formal methods to specify semantics, helps verify the correctness and security of the code.
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5.2.3 SC Compiler
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The design and implementation of a SC Compiler play a critical role for the design and execution of a Smart Contract which is executed on the top of one or many SC Virtual Machines relying on a centralized or distributed Electronic Ledgers: as an explanatory example, different SC Compilers compile the same SC Source Code into different SC Byte Codes that, in turn, will be all executed on a distributed ledger ISO 22739 [i.3] using different SC Virtual Machines. Thus, a SC Compiler is responsible for translating a SC Source Code written using a particular version of a SC Language, into a SC Byte Code written on a particular version of a SC Byte Code Language that can run on different SC Virtual Machines, each of one capturing the semantic of a different SC Byte Code Language. This translation process is vital as it bridges the gap between human-readable code and machine-executable instructions. The compatibility between languages definitions, compilers, byte codes, and virtual machines is thus capital to ensure a coherent behavior in a centralized or distributed setting. The absence of European regulations can lead to discrepancies in how compilers interpret and translate code, potentially introducing bugs or vulnerabilities that are only evident once a SC Byte Code is deployed and executed on an Electronic Ledger, and as such, immutable. Without regulations and standardized specifications, SC Compiler developers might interpret the SC Language Specification and SC Language Specification Policy differently, leading to non-compatible, semantically different SC Byte Code and inconsistent Smart Contract behavior across platforms. As an explanatory example, in case of Smart Contracts [i.3] executed on distributed ledgers as defined in ISO 22739 [i.3], a special kind of Electronic Ledger [i.1], the decentralized nature of the blockchain technology means that a Smart Contract [i.3] might be executed on many different nodes around the world, each potentially using slightly different compiler versions or settings. This decentralization exacerbates the risk of discrepancies and highlights the importance of establishing more uniform compiler standards. It could be beneficial for the distributed ledgers community to consider frameworks that provide clearer guidelines and specifications for compiler development.
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5.2.4 SC Virtual Machine
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The design and implementation of SC Virtual Machines (VMs) are pivotal for the execution of Smart Contracts [i.3] across various blockchain platforms. These VMs translate the bytecode produced by compilers into executable actions within the blockchain's network. As explanatory examples: Ethereum's Ethereum Virtual Machine (EVM) and the Solana's Sealevel operate under different principles and architectures, tailored to their specific blockchain ecosystems. For instance, EVM is designed for Ethereum's account-based model and handles transactions and contract states differently from Sealevel, which is designed to execute thousands of Smart Contracts as defined in ISO 22739 [i.3] in parallel, in a distributed ledger as defined in ISO 22739 [i.3], all optimized for Solana's unique consensus mechanism and high throughput capabilities. 5.2.5 Computer assisted software tools to assess correctness, safety, and security In the development of Smart Contracts, ensuring the correctness, safety, and security of the software is paramount. To address these concerns, developers and researchers employ various computer-assisted software tools that aid in the formal verification and validation of SC Languages, SC Compilers, SC Virtual Machines, Electronic Ledgers and Smart Contracts. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 30 As examples of the most applied Formal Verification Tools, the present document mentions: 1) Rocq: Rocq (formerly Coq) [i.24] is an interactive theorem prover designed to develop mathematical proofs and to write formally verified software. It is widely used in academia and industry to ensure the correctness of algorithms and to formally prove properties of programs. Rocq's ability to construct proofs makes it an invaluable tool for verifying the SC Languages used for Smart Contracts. 2) Isabelle: Isabelle [i.25] is another powerful theorem proving environment, which supports a variety of logical formalisms. It is used for writing and checking detailed proofs, and can also serve as a platform for developing robust, formally verified software. Isabelle's frameworks are particularly useful in verifying the correctness and security of Electronic Ledgers and Smart Contract code. 3) Lean: Lean [i.26] is a theorem prover and programming language designed for formalizing mathematical theorems and programming logically. It is used with distributed ledgers as defined in ISO 22739 [i.3] and particularly for the formal verification of Smart Contracts, ensuring that they execute as intended without unwanted side effects or vulnerabilities. Application examples: • Smart Contract Verification: Tools like Rocq and Isabelle have been used to develop formal models of blockchain environments and programming languages for Smart Contracts as defined in ISO 22739 [i.3], such as Solidity, executed on a distributed ledger as defined in ISO 22739 [i.3]. For example, a project might use Isabelle to formalize the semantics of Solidity and prove certain security properties, such as the absence of reentrancy vulnerabilities. • SC Compiler and SC Virtual Machine Verification: The correctness of SC Compilers, which translate high- level SC Source Code into SC Byte Code, can be also verified using these tools. This is not new for usual programming languages. For instance, the CompCert [i.27] project uses the Rocq proof assistant to formally verify a compiler for the C programming language, ensuring that the compiler does not introduce any errors during the translation process. A similar approach can be adapted for SC Compilers and SC Virtual Machines. Formal Tools like Rocq, Isabelle, and Lean can formally check that the SC Source Code and the SC Byte Code accurately reflects algorithmic logic semantic underneath the Smart Contract. Implementation of Electronic Ledgers can be also formally checked. By utilizing formal verification methods, it is possible to ensure that the algorithm does not contains bugs or logical errors that could lead to vulnerabilities. Automated tools can handle large volumes of contracts more efficiently than a manual process, making it scalable for applications that require numerous or frequently updated Smart Contracts. Incorporating the Common Criteria (ISO/IEC 15408 [i.5]) in the use of these tools adds an additional layer of security assurance. The Common Criteria framework provides a structured process for evaluating the security and assurance of information technology products, which is directly applicable to Electronic Ledgers. By aligning the formal verification processes with Common Criteria standards, developers can certify the security and robustness of an Electronic Ledger and Smart Contracts running on the top of it, enhancing trust and compliance with international security standards. Recommendation ITU-T F.751.8 [i.30] advocates the use of formal methods to support the security of Smart Contracts running on DLT systems.
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5.2.6 SC Legal Text, Certification of Smart Contract, Agreements
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5.2.6.1 Essential Overview
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5.2.
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6.1 Essential Overview
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Translating a certified SC Legal Text into a Smart Legal Contract is a detailed process. It ensures that the legal terms are precisely and securely translated into a SC Byte Code on a SC Virtual Machine using an Electronic Ledger. This is important to maintain the contract's integrity and enforceability. A task force consisting of both Lawyers and Software Engineers works collaboratively to interpret the legal terms and requirements of a contract and then implement these into a Smart Legal Contract. Lawyers, represented in the present document as SC Legal Team, ensures that the legal nuances, represented using a Deontic Logic, are respected and fully represented, while software engineers, represented in the present document as SC Development Team, focus on encoding these terms into a SC Source Code, written in a SC Language, that is in turn compiled into a SC Package containing, among other files, the SC Byte Code that will be executed within one or many SC Virtual Machines on an Electronic Ledger. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 31 Formal tools often have built-in libraries for reasoning with Deontic Logic: this would help SC Development Team and SC Legal Team to work together and converge to write a Smart Legal Contract that accurately reflects the stipulated legal terms and a formally proven executable code. By utilizing formal verification methods, it is possible to ensure that the contract does not have bugs or logical errors that could lead to disputes or vulnerabilities. Reversing the process, i.e. translating SC Byte Code back into a SC Legal Text, is important for legal review, compliance checks, and in situations where parties need to understand the executed terms without reading the code. This can be achieved by maintaining a comprehensive documentation and comments within the SC Source Code and the SC Package, that reflects the legal terms in a natural language. Observe that that in the Chain of Trust, the SC Package should be able to package at least SC Byte Code with SC Documentation, SC Source Code, and SC Legal Text.
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5.2.6.2 SC Legal Text
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The legal basis for a Smart Contract is defined using SC Legal Text. This can include: a) Legal context in which the Smart Contract execution takes place such as European legislation, national legislation, or commercial agreements. b) Provisions to meet the requirements for data protection of any personal data. c) Requirements on SC Deployer Policy. d) Requirements for SC Provider including: i) Use of SC Language tools including SC Compiler and SC Virtual Machine. ii) Use of Electronic Ledgers. iii) Verification of SC User identities. e) License terms and conditions to be agreed by the SC User.
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5.2.6.3 Certification of Smart Contract by SC Publisher
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The elements of a Smart Contract and a Smart Legal Contract (SC Legal Text, SC Source Code, SC Byte Code, and other SC Documentation) should be certified by the SC Publisher which has overall responsibility for the Smart Contract. The certification should be based on conformance to the SC Publisher's SC Development Policy. The certification should be provided by the SC Publisher which has overall responsibility for the Smart Contract.
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5.2.6.4 Verification of legal agreement
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a) Deployment of a Smart Contract Before deploying a Smart Contract (a SC Byte Code), the SC Deployer should ensure that all the elements of the Smart Contract have been certified together by an identified SC Publisher. In addition to making the SC Byte Code available on the Electronic Ledger, the SC Deployer should provide a successful validation report for SC Publisher signature against all the elements of the Smart Contract. Elements other than the SC Byte Code can be held outside the ledger but should include binding information (e.g. location reference and hash) alongside the validation report in the ledger. The SC Deployer should also record a confirmation that its SC Deployer Policy meets the requirements for deployment in the SC Legal Text. b) Provision of a Smart Contract Before executing a Smart Contract (a SC Byte Code) on the top of a SC Virtual Machine, the SC Provider should: i) Validate the SC Publisher signature at least against the SC Byte Code and record the validation report in the Electronic Ledger. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 32 ii) Confirm that SC Provider Policy, including use of an Electronic Ledger and SC Language tools, meets the requirements in the SC Legal Text and record this in the Electronic Ledger. c) User license terms and conditions d) Execution of a Smart Contract Before executing a Smart Contract (a SC Byte Code) on the top of a SC Virtual Machine, the SC Provider should provide the SC User with a copy of the license: i) The SC Provider should record in the Electronic Ledger information on the validation of the SC User identity along with a confirmation of the acceptance of the license terms and conditions which should be part of or bound to the SC Legal Text for the Smart Contract. After executing a Smart Contract (a SC Byte Code), the SC Provider should provide a SC Execution Report.
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5.3 Distributed ledger technology (DLT)
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5.3.1 Essential Overview Although Regulation (EU) 2023/2854 [i.1] and Regulation (EU) 2024/1183 [i.2] provide a normative framework for Smart Contracts and Electronic Ledgers, the present clause highlights the significant increase in the use of distributed ledgers as defined in ISO 22739 [i.3] over the past decade, operating on various distributed ledger technologies. As such, the present clause presents key information to outline the state of the art in distributed ledgers. The present clause has also basis in documents produced by ISO TC 307, and ETSI ISG PDL (at time of publication of the present document now part of ETSI TC DATA) and ITU-T. The aim is to understand the gap existing between Electronic Ledger and Smart Contracts, as defined by European regulations, and the existing distributed ledgers and Smart Contracts standard, as defined in Standard Organizations documents, and the de facto real solutions emerged and used by far. The Chain of Trust should fill this gap.
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5.3.2 Permissioned or permissionless
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Permissioned distributed ledgers restrict network access to authorized participants only. In this model, each participant is explicitly allowed to join the network, typically by a network administrator or through a consensus of existing participants. Selected participants are allowed to validate and persist transactions. This setup is favoured by private organizations and consortiums where privacy, security, and control are priorities. Since participants are known and verified, it is easier to maintain confidentiality over transactions. Permissionless distributed ledgers allow anyone to join and participate in the network without prior authorization. Every participant is allowed to validate and persist transactions. This type of ledger underpins cryptocurrencies like Bitcoin and Ethereum, supporting a fully decentralized environment.
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5.3.3 Public or Private
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Public distributed ledgers allow everybody to access all transactions and data so there is full transparency. Private distributed ledgers allow to access only authorized users: similar conditions concerning execution of transactions can apply.
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5.3.4 Data structures used to implement a distributed ledger
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Electronic Ledgers, as defined in eIDAS2 regulation, can be implemented using either centralized or distributed technology, and as such a distributed ledger, as defined in ISO 22739 [i.3]. In both cases the used data structure is important to understand how the Chain of Trust can be applied. The present clause recaps the state of the art of all data structures for distributed ledgers as described in ISO and ETSI and ITU-T documents. In a distributed ledger - subset of an Electronic Ledger - various data structures are used to ensure security, efficiency, and immutability. These data structures serve different purposes, such as storing transaction ETSI ETSI TR 119 540 V1.1.1 (2025-10) 33 records, maintaining integrity, and managing nodes and states. Below are some of the key data structures that can be used to implement distributed ledgers, also summarized in Table 2. For each data structure one list usage, structure and components, advantages, and a simple example of distributed ledger, commonly referred as blockchain. The present clause is important in order to understand which data structure can be adapted or extended with lesser effort to the Chain of Trust without sacrificing backward compatibility with existing distributed ledgers and what it is described in Regulation (EU) 2024/1183 [i.2] and in its forthcoming Implementing Acts. Each data structure plays a crucial role in the functioning, efficiency, and security of a distributed ledger: 1) Linked List: - Usage: a distributed ledger itself can be seen as a linked list where each block is linked to the previous one using cryptographic hashes. Each block contains a reference (hash) to the previous block, forming a chain. - Advantages: Simple structure, easy to traverse. - Example: Used in Bitcoin or Ethereum. 2) Merkle Tree (Hash Tree): - Usage: Merkle trees are used to efficiently and securely verify the integrity of large sets of data. A Merkle tree allows nodes to verify the consistency and validity of the transactions in a block without needing the entire data. - Structure: A binary tree where each leaf node is a hash of a data block, and non-leaf nodes are hashes of their child nodes. - Advantages: Efficient proof of data integrity, scalable, and reduces the amount of data stored by light clients (SPV nodes). - Example: Used in Bitcoin and Ethereum for efficient transaction verification. 3) DAG (Directed Acyclic Graph): - Usage: Some distributed ledger systems, like IOTA and Hedera Hashgraph, use DAG structures to manage transactions and consensus differently from traditional chains. Instead of linear blocks, transactions are stored in a graph where each transaction points to one or more previous transactions. - Advantages: Higher scalability, no need for mining, low latency. - Example: IOTA's Tangle, Hedera Hashgraph. 4) Patricia Trie (Radix Trie or Prefix Trie): - Usage: Patricia tries are used in Ethereum to efficiently store key-value pairs and ensure quick retrieval and verification of data. It is a form of a Merkle Trie that combines a tree and a Merkle Trie. - Structure: A compact and ordered data structure that stores a mapping from arbitrary-length binary strings to values. - Advantages: Space-efficient, allows for fast lookups, insertions, and deletions. - Example: Used in Ethereum for account storage and world state representation. 5) Heap: - Usage: Heaps are used to manage priority queues, especially for mining operations and transaction selection. For example, miners may use heaps to select transactions with the highest fees. - Advantages: Efficient handling of dynamic data, fast access to the highest-priority element. - Example: May be used in Bitcoin and Ethereum for transaction prioritization. 6) Bloom Filter: ETSI ETSI TR 119 540 V1.1.1 (2025-10) 34 - Usage: A probabilistic data structure used to test whether an element is part of a set or not. It is used in lightweight nodes (SPV nodes) to filter transactions and blocks relevant to them without having the full blockchain. - Advantages: Space-efficient, fast, low false positives. - Example: Bitcoin's SPV nodes use Bloom filters to query full nodes for relevant transactions. 7) Block Structure: - Usage: Each block in a blockchain contains data like transactions, timestamps, the hash of the previous block, and a nonce. - Components: - Header: Contains metadata like the hash of the previous block, Merkle root, timestamp, and nonce. - Body: Contains transaction details, including the sender, receiver, and amount. - Example: Every blockchain uses this structure with some variations. For instance, Bitcoin has a simple structure, whereas Ethereum's blocks contain additional information for Smart Contracts and state transitions. 8) Account Trie: - Usage: In Ethereum, each account is stored in a trie structure. The account trie maps the address to account details like nonce, balance, storage root, and code hash. - Advantages: Efficient access and storage of account states, helps in keeping track of changes in accounts over time. - Example: Used in Ethereum for improve efficiency. 9) Unspent Transaction Output (UTXO) Set: - Usage: UTXO represents the set of unspent transaction outputs that are used to determine the available balance for a wallet. - Structure: A database of all unspent outputs, where each output is indexed by its transaction ID and output index. - Advantages: Enables stateless transactions, simplifies validation. - Example: Used in Bitcoin, Litecoin, and other UTXO-based blockchains. 10) State Trie: - Usage: The State Trie represents the global state of the distributed ledger, which includes all accounts and contracts in Ethereum. It is a critical part of Ethereum's world state. - Structure: A Merkle Patricia Trie structure that stores the state of each account, including balances, nonces, and contract storage. - Advantages: Enables efficient state verification and validation. - Example: Core to Ethereum's execution model. 11) Transaction Pool: - Usage: This is a temporary storage area for transactions that have been broadcast to the network but have not yet been included in a block. The pool is often managed as a priority queue. - Advantages: Helps miners select transactions based on fees and ensures that pending transactions are accessible to the network. - Example: Both Bitcoin and Ethereum use a transaction pool to store unconfirmed transactions. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 35 12) Sparse Merkle Trie: - Usage: Sparse Merkle Tries are used in systems where most entries are empty, such as in proof-of-stake systems for proof generation. These trees allow the blockchain to verify the existence or non-existence of data efficiently. - Advantages: Compact, verifiable, ideal for systems with sparse data. - Example: Used in various proof-of-stake protocols and newer blockchain projects. Table 2: Summary of data structure management Data Structure Purpose Examples Linked List Chain of blocks Bitcoin Merkle Tree Efficient transaction verification Bitcoin, Ethereum DAG Transaction verification without mining IOTA, Hedera-Hashgraph Patricia Trie Efficient key-value pair storage Ethereum Heap Transaction prioritization Bitcoin (mining), Ethereum Bloom Filter Lightweight transaction queries Bitcoin SPV Nodes Block Structure Block metadata and transactions All blockchains Account Tree Storage of account details Ethereum UTXO Set Unspent transaction outputs Bitcoin, Litecoin State Tree Global state of the blockchain Ethereum Transaction Pool Unconfirmed transaction storage Bitcoin, Ethereum Sparse Merkle Tree Proof generation in sparse systems Proof-of-stake protocols
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5.3.5 On-chain and off-chain transaction data solutions
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On-chain data refers to any information that is stored directly on a distributed ledger as defined in ISO 22739 [i.3]. This includes transaction records, Smart Contracts as defined in ISO 22739 [i.3], and any other data that needs to be immutable, transparent, and verifiable by all network participants. As an explanatory example, the Ethereum Virtual Machine stores all transactions, including the ones generated by the execution of a Smart Contract, on-chain. For example, a crowdfunding contract can record all contributions and funding thresholds directly on the Ethereum blockchain, ensuring transparency and immutability. Another example in Ethereum is the ERC-721 [i.72], dealing with Non-Fungible Tokens (NFTs): all information related to the ownership and transfer of an NFT is stored on-chain, ensuring the traceability and uniqueness of the token. Off-chain data refers to any data that is stored outside of the distributed ledger as defined in ISO 22739 [i.3] but can interact with it when needed. This includes large files, databases, and other forms of data that do not need to be stored on-chain for every transaction. Some explanatory examples are listed below: • IPFS is a decentralized storage protocol that allows large amounts of data to be stored off-chain while only a reference hash is stored on-chain. For example, in a digital content management system, multimedia files can be stored on IPFS, with the file hash preserved on the distributed ledger to verify integrity and origin. • Layer 2 Solution, such as Lightning Network, is an off-chain scaling solution for the Layer 1 distributed ledger that allows fast and low-cost transactions. Transactions are recorded off-chain, with only the final balance reported on-chain. • Plasma is a scaling solution that uses sidechains to process off-chain transactions, with the ability to anchor critical data on-chain. This reduces the load on the main distributed ledger while maintaining security and verification through the Ethereum MainNet. • Optimistic Rollups on Ethereum, a scaling solution that allows Smart Contracts as defined in [i.3] to be executed off-chain with only the final results reported on-chain. This technique improves scalability and reduces costs while maintaining transaction integrity through fraud proofs. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 36
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5.4 Digital trust elements in Smart Contracts
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5.4.1 Essential Overview
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The aim of the present clause is to understand the gap existing between Electronic Ledgers and Smart Contracts, as defined by European regulations, and distributed ledgers and Smart Contracts, as defined by Standard Organization documents, and the de facto real solutions emerging and used by far. The Chain of Trust should fill this gap.
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5.4.2 Identification, authentication
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Identity and Access Control: • Every actor during a Smart Contract and Smart Legal Contracts execution is assigned a unique identity and corresponding access control rights. The governance is responsible for ensuring that all actors have appropriate and unique access rights. • Access to Smart Contracts and Smart Legal Contracts is strictly controlled through mechanisms that enforce time-bound and role-based access, ensuring that only authorized parties can interact with the Smart Contract and Smart Legal Contracts at any given time. Lifecycle Management: • The lifecycle of a Smart Contract and Smart Legal Contracts includes proper planning, design, coding, deployment, and management. This includes defining the ownership and access control strategies during the planning phase to prevent future disputes. Security and Privacy: • Smart Contracts and Smart Legal Contracts ensure that identity information and access rights are securely managed. This includes using a trusted execution environment to prevent unauthorized access and ensures that only authenticated and authorized transactions occur within the Smart Contract and Smart Legal Contracts. • Privacy concerns are addressed by implementing private chains or channels where necessary, allowing certain contractual details to remain confidential from other participants in the network. Auditable Libraries and Verification: • Developers are required to use auditable libraries for building Smart Contracts and Smart Legal Contracts. These libraries should be verifiable and approved by governance to ensure the integrity and security of the SC Source Code and SC Byte Code. Enforceability: • Smart Contracts and Smart Legal Contracts are designed to be self-executable upon the fulfilment of predefined conditions, and they should be enforceable across different jurisdictions. The governance should ensure that Smart Contracts and Smart Legal Contracts are aligned with the legal and regulatory frameworks of the participating entities.
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5.4.3 Electronic signatures and seals
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A digital signature as described in ETSI TR 119 001 [i.4] is a cryptographic transformation of a data unit that allows a recipient to prove the source and integrity of the data and to protect against forgery by the recipient. This involves appending data or transforming the original data in such a way that the origin of the data can be verified, ensuring its authenticity and integrity. A digital signature is a mechanism, based on public key cryptography, which can be used to provide the legal equivalent of a handwritten signatures, commonly referred to in EU legislation as an electronic signature. In the context of Smart Contracts, electronic signatures are crucial because they ensure that the actions and transactions recorded in the Smart Contract are authorized and verifiable by all parties involved. It protects the integrity of the ETSI ETSI TR 119 540 V1.1.1 (2025-10) 37 transaction and guarantees that the signatory cannot deny their involvement, thereby enabling trust and legal enforceability of the contract. Under European legislation, electronic signatures, and the equivalent when applied by an organization (referred to as a legal person) called electronic seal, can come in several forms: • Electronic Signature: An electronic signature is a data in electronic form that is attached to or logically associated with other electronic data and used by the signatory to sign. It is a broad term that encompasses various types of signatures used to confirm the authenticity of the signer and the integrity of the data. Under Regulation (EU) 2024/1183 [i.2] and Regulation (EU) No 910/2014 [i.6], it is a legal concept that ensures the authenticity and integrity of signed electronic documents. • Advanced Electronic Signature: An advanced electronic signature is a specific type of electronic signature that meets certain requirements under Regulation (EU) 2024/1183 [i.2] and Regulation (EU) No 910/2014 [i.6]. It should be uniquely linked to the signatory, capable of identifying the signatory, created using electronic signature creation data that the signatory can use under their sole control, and linked to the data signed in such a way that any subsequent change in the data is detectable. • Qualified Electronic Signature: A qualified electronic signature is an advanced electronic signature that is created using a qualified electronic signature creation device and is based on a qualified certificate for electronic signatures. This type of signature has the highest level of legal acceptance under EU law and is equivalent to a handwritten signature. • Electronic Seal: An electronic seal is similar to an electronic signature but is used by a legal person (such as a company or organization) rather than a natural person. It serves as evidence that the electronic document or data has originated from a specific legal entity and ensures its authenticity and integrity. • Advanced Electronic Seal: An advanced electronic seal is a type of electronic seal that, like an advanced electronic signature, meets certain criteria under Regulation (EU) 2024/1183 [i.2] and Regulation (EU) No 910/2014 [i.6]. It should be uniquely linked to the creator of the seal, capable of identifying the creator, created using electronic seal creation data that the creator can use under their sole control, and linked to the data to which it relates in such a manner that any subsequent change in the data is detectable. • Qualified Electronic Seal: A qualified electronic seal is an advanced electronic seal that is created using a qualified electronic seal creation device and is based on a qualified certificate for electronic seals. Like the qualified electronic signature, it carries the highest level of legal recognition and provides a greater level of trust in the origin and integrity of the sealed document. The key difference between an electronic signature and an electronic seal lies in their intended use and the type of entity applying them. An electronic signature is used by a natural person, acting under their control to perform a declaration of intent, often in the form of signing a contract or executing another legal act attributed solely to the individual. This natural person may act on their own behalf or on behalf of a legal person. When acting on behalf of a legal person, the electronic signature is applied based on a legal mandate or authorized representation. The electronic signature confirms both the identity of the natural person and their intent to bind themselves or the legal person they represent to a specific transaction or legal act. An electronic seal, however, serves a different purpose. It is used primarily by a legal person to ensure the authenticity and integrity of documents. Unlike an electronic signature, it does not express intent but functions as a security measure to guarantee that the document's content has not been altered and originates from a verified legal person. While an electronic seal cannot directly replace an electronic signature, as it does not convey personal intent, it can fulfil the same business function in certain legal contexts. For example, after a contract has been signed, subsequent orders related to that contract can be automatically validated with an electronic seal, ensuring the document's origin and integrity without further action from a natural person. Electronic seals are especially important in trust services and are legally supported by the eIDAS regulation as a basis for their use. In the context of Smart Contracts, an electronic signature is essential for confirming that the relevant documents and data entering the Smart Contracts, particularly those related to contract formation, obligations, or verification data, are validated by the natural persons who are parties to the agreement. In this way, the electronic signature serves as both a tool for identifying natural persons and for confirming the commitments they make within the Smart Contract. On the other hand, an electronic seal can greatly support Smart Contracts by verifying the authenticity of the data input, particularly when acting as a source (or oracle). Moreover, if a Smart Contract generates data that is to be used outside of the ledger, the electronic seal can safeguard the authenticity, integrity, and origin of that data, ensuring it results from ETSI ETSI TR 119 540 V1.1.1 (2025-10) 38 the proper execution of the Smart Contract. This makes electronic seals a vital tool for maintaining trust and security in transactions involving Smart Contracts, especially for legal persons. Below are the main methods and steps involved in generating digital signatures: Digital signatures, which are a specific type of electronic signature that use cryptographic techniques for enhanced security, are typically generated using public key cryptography. Below are the main methods and steps involved in generating digital signatures: 1) Public Key Infrastructure (PKI): PKI is the most common and secure way of generating digital signatures. It involves the use of a cryptographic key pair, where a private key used to generate the digital signature (kept secret by the signer); and a public key used by recipients to verify the signature (shared with others). 2) Hardware Security Module (HSM): HSM is a physical device that securely stores private keys and performs cryptographic operations, including digital signature generation. The digital signature is returned from the HSM, which can be appended to the document. This method is common in high-security environments, such as banking, government, and large enterprises, where strict key management policies are required. 3) Smart Card or SIM card-Based Digital Signature: Smart Cards or SIM cards, which securely store cryptographic keys, can be used to generate digital signatures. The card performs the cryptographic operation to sign the hash of the document using the stored private key. Examples of using this method include systems like Mobile ID (e.g. in Estonia, Finland) or smart card-based authentication in organizations. 4) Digital Signature Software (e.g. AdobeSign®, DocuSign®): Digital signature software automates the process of key generation, signing, and verification. These platforms often integrate PKI under the hood, allowing users to sign documents digitally. The platform hashes the document and uses the user's private key to generate the digital signature. 5) Mobile Digital Signatures (mobile-ID): In some mobile digital signature schemes, the private keys are stored securely on a mobile device's SIM card or secure element, and signing happens via the mobile network. A user uses a mobile app that supports digital signatures (like mobile-ID). The app sends the digital signature, which can be verified by recipients using the public key. Digital signatures provide strong security and integrity by using cryptographic algorithms, and the exact method for generating them can range from simple software-based solutions to high-security hardware-based systems. Depending on the use case (e.g. legal contracts, mobile signing, blockchain transactions), different approaches can be used, with PKI being the most widely used and secure. Whenever an entity in the Chain of Trust relies on the validity of a digital signature the successful validation of the signature should be recorded to avoid later claim against of the origin and integrity of the signed data.
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5.4.4 Electronic identity
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5.4.4.1 Essential overview
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In the context of the eIDAS2 regulation [i.2], electronic identification is defined as the process of using person identification data in electronic form that uniquely represents either a natural person, a legal person, or a natural person representing a legal person. This process is crucial for authentication in online and offline services, ensuring that the identity of the individual or entity is accurately and securely confirmed during digital transactions. The regulation lays out specific criteria and requirements for electronic identification schemes to be recognized and utilized across the European Union. This includes the issuance of electronic identification means (such as European Digital Identity Wallets), which contain the identification data necessary for authentication and are used to securely access services. The regulation also emphasizes that electronic identification should meet certain assurance levels (low, substantial, or high) depending on the level of confidence required in the claimed identity, and it should be recognized and interoperable across different European member states. Thus, in this context, electronic identity refers to a digitally represented identity that enables secure and trusted interactions across digital platforms, meeting specific legal and technical standards as outlined in the regulation. Whenever the identity of a SC User invoking a SC Contract is verified the successful validation of the identity should be recorded to avoid later claim against of the user invoking a Smart Contract. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 39
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5.4.4.2 Electronic identity in a mobile network
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Mobile network operators also play a key role in providing secure identity services because they control SIM cards, which can store cryptographic keys and securely authenticate users. This concept is often referred to as mobile ID or Mobile Signature. A SC User can be identified when he/she is connected to the SC Provider using its mobile phone, and a particular mobile network. See also Clause 5.8. Key Components of Electronic Identity in a mobile network: 1) SIM and eSIM card as a secure storage: SIM cards are tamper-resistant hardware used to store the user's private key securely. The private key is used to generate digital signatures or authenticate the user. Similarly, eSIM is a hardware module where the user's secret key can be programmed with software in the hardware module instead of plugging in a physical card. SIM cards and eSIM can perform cryptographic operations like generating digital signatures or encrypting data without exposing the private key. 2) Mobile device: the mobile device acts as the interface through which users authenticate or sign documents. It interacts with the SIM card or secure element for cryptographic operations. It also serves as a trusted device that can be used in multi-factor authentication systems (combining something the user "has", e.g. the phone or SIM, with something the user "knows", e.g. a PIN). Benefits of mobile-based electronic identity are as follows: 1) Convenience: Users can authenticate or sign documents anywhere using their mobile phones without the need for additional hardware. No need for physical smart cards or separate hardware tokens. 2) Security: Strong two-factor authentication: combining "something you have" (the SIM card or phone) with "something you know" (a PIN or password). The private key is securely stored in the SIM card and never leaves it, reducing the risk of key compromise. 3) Widespread adoption: Mobile phones are ubiquitous, making it easy for users to adopt mobile ID services. Many mobile network operators are trusted entities with the infrastructure needed for secure identity management. 4) Legal validity: In many countries, digital signatures generated using mobile-ID systems are legally equivalent to handwritten signatures. Qualified Electronic Signatures (QES), which are generated using a secure device like a SIM card and a qualified certificate, have the highest level of legal recognition in regions like the EU under the eIDAS2 regulation. Currently the electronic identity scheme employed by mobile network operators in standards is still far away from complying with eIDAS2 and Data Act.
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5.4.5 Distributed ledgers
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Distributed ledgers are a special kind of Electronic Ledgers in presence of network facilities. There are several Distributed Ledger Technologies (DLTs), not necessarily aligned with ISO 22739 [i.3] that provide frameworks and protocols for building decentralized systems, enabling secure and transparent transactions without relying on a central authority. DLTs offer different features, such as consensus mechanisms, and governance structures, but they generally conform to some level of global standards or industry best practices. The Chain of Trust should be applied also on distributed ledgers. Below are some of the most prominent examples of distributed ledger technologies at time of publication of the present document: 1) Hyperledger Fabric™ (by Linux Foundation®): Part of the Hyperledger project under the Linux Foundation, which is a collaborative effort to create open-source DLT frameworks for enterprise use cases. Consensus Mechanism: Pluggable consensus (supports various consensus algorithms, including Practical Byzantine Fault Tolerance and Raft). Key Features: - Permissioned Ledger: Designed for enterprise use, it operates on a permissioned network, meaning only authorized participants can join. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 40 - Smart Contracts as defined in ISO 22739 [i.3]: Supports on-chain code, enabling automation of business logic. - Privacy and Confidentiality: Offers private channels for confidential transactions between specific parties. - Use Cases: Supply chain management, finance, healthcare, and government services. - Standards Compliance: Follows industry best practices for data privacy, identity management, and cryptographic security. Some implementations also comply with regulatory standards like GDPR [i.7]. 2) Corda® (by R3): developed by R3, a consortium of financial institutions, Corda is an open-source blockchain platform optimized for business and regulatory use cases. Consensus Mechanism: Corda does not use a traditional blockchain structure or consensus mechanism like Proof of Work. Instead, it uses a notary service that ensures transaction uniqueness and validation. Key Features: - Permissioned Network: Like Hyperledger Fabric, Corda is designed for permissioned networks with a strong focus on privacy and security. - Legal Contracts: Supports legal contracts that can be directly mapped into Smart Contracts as defined in ISO 22739 [i.3] and try to capture Smart Legal Contract definitions. - Interoperability: Focuses on interoperability between various systems and across regulatory frameworks. - Use Cases: Financial services (trade finance, payments, insurance), digital identity, and healthcare. - Standards Compliance: Corda is designed with compliance in mind, especially for industries like finance that require adherence to legal and regulatory standards (e.g. GDPR [i.7], ISO standards). 3) Quorum® (by JPMorgan): Standardization: A permissioned blockchain based on Ethereum, but with modifications for enterprise use. Initially developed by JPMorgan, it's now part of ConsenSys. Consensus Mechanism: Supports multiple consensus algorithms, including Raft and Istanbul Byzantine Fault Tolerance. Key Features: - Private Transactions: Quorum allows for private transactions and contracts, making it suitable for businesses that need to keep certain data confidential. - Performance: Enhanced transaction speed compared to the public Ethereum network. - Compatibility: Since it is Ethereum-based, Quorum can run Ethereum Smart Contracts as defined in ISO 22739 [i.3] and leverage existing Ethereum tools. - Use Cases: Banking, supply chain, insurance, and capital markets. - Standards Compliance: Quorum aligns with enterprise-grade security and privacy standards. It can be adapted to meet specific regulatory frameworks like Basel III for banking. 4) Ethereum® (Public Network and Enterprise Ethereum): Ethereum is a well-known public blockchain network that follows decentralized standards but also has an enterprise-focused version known as Enterprise Ethereum under the Enterprise Ethereum Alliance. Consensus Mechanism: Ethereum has moved from Proof of Work (PoW) to Proof of Stake (PoS) with Ethereum 2.0. Key Features: - Smart Contracts, as defined in ISO 22739 [i.3]: Ethereum pioneered the concept of Smart Contracts as defined in ISO 22739 [i.3], enabling decentralized applications and Decentralized Finance (DeFi) projects. - Enterprise Ethereum: Provides privacy, permissioning, and scalability features needed for business use cases. - Use Cases: Public Ethereum is widely used for decentralized applications, NFTs, and DeFi, while Enterprise Ethereum is used in industries like supply chain, healthcare, and finance. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 41 - Standards Compliance: The Enterprise Ethereum Alliance works on creating standards for enterprise use, ensuring compatibility with global industry and regulatory standards (such as ISO standards). 5) Ripple (for XRP® Ledger): Ripple provides a distributed ledger aimed at facilitating fast and cheap cross- border payments and settlements, particularly in the financial industry. Consensus Mechanism: Uses the Ripple Protocol Consensus Algorithm (RPCA), which is different from PoW or PoS. It focuses on agreement between trusted nodes (validators) for transaction validation. Key Features: - High Throughput: Ripple is designed for fast settlement of payments with low transaction fees. - Interledger Protocol: Allows for interoperability between different payment networks. - Use Cases: Cross-border payments, remittances, and currency exchange. - Standards Compliance: Ripple is focused on compliance with financial regulations like know-your- customer, anti-money-laundering, and ISO 20022 [i.73] (a multi part International Standard prepared by ISO Technical Committee TC68 Financial Services) messaging standards. 6) IOTA®: IOTA uses a Directed Acyclic Graph (DAG) structure called Tangle rather than a traditional blockchain. It's focused on IoT (Internet of Things) applications. Consensus Mechanism: There is no traditional consensus mechanism like PoW. Instead, each participant in the network confirms two previous transactions, making it a decentralized and scalable system. Key Features: - Zero-fee transactions: IOTA is designed to enable feeless microtransactions, ideal for IoT devices. - Scalability: The DAG structure allows for theoretically infinite scalability without traditional bottlenecks. - Use Cases: IoT, smart cities, machine-to-machine communication, supply chain management. - Standards Compliance: IOTA is working toward compliance with ISO 9001 [i.8] and ISO/IEC 27001 [i.9] standards for quality management and information security. It is also involved in the Industrial Internet Consortium (IIC) for standardizing IoT solutions. 7) EOSIO®: EOSIO is an open-source blockchain platform known for scalability and speed. It uses a Delegated Proof-of-Stake (DPoS) consensus mechanism. Consensus Mechanism: Delegated Proof of Stake (DPoS), where block producers are voted in by stakeholders. Key Features: - High Performance: EOSIO is designed for high throughput, supporting thousands of transactions per second. Governance: Built-in governance mechanisms allow for dispute resolution and upgrades. - Use Cases: Decentralized applications, enterprise solutions, social networks, and gaming. - Standards Compliance: EOSIO is designed for enterprise use and can be customized to meet various regulatory standards. It supports compliance with GDPR [i.7] and offers built-in mechanisms for on- chain governance. 8) Stellar®: Stellar is an open-source distributed ledger optimized for fast cross-border payments, similar to Ripple. Consensus Mechanism: Stellar Consensus Protocol (SCP), which relies on a quorum of trusted nodes for consensus rather than a traditional mining or staking process. Key Features: - Low Cost: Transactions on the Stellar network is low-cost and settle quickly. - Multi-Currency Transactions: Stellar supports multi-currency transactions and allows for the issuance of digital assets. - Use Cases: Cross-border payments, remittances, microfinance, and tokenization of assets. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 42 - Standards Compliance: Stellar works to comply with global financial regulations like AML®, KYC®, and ISO 20022 [i.73], making it suitable for regulated financial institutions. 9) EBSI: See Clause 4.4.2. 5.5 Deployment and Execution of Smart Contracts and Smart Legal Contracts
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5.5.1 Essential Overview
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The present clause is about different kind of deployment and execution. Regulation (EU) 2023/2854 [i.1] and Regulation (EU) 2024/1183 [i.2] are rather liberal on those points. • An Electronic Ledger "can be centralized or decentralized". This corresponds to give someone a "free hand" to different kind of deployment and execution environments. • A Smart Contract is "a piece of code". This corresponds to give someone a "free hand" to map a Smart Contract into a SC Source Code or a SC Byte Code, or both, with or without SC Legal Text, with or without identification of publishers of SC Compiler or SC Virtual Machine, or any combination of the above components. • Smart Legal Contract, as defined in the present document, is undefined. However, Regulation (EU) 2023/2854 [i.1] introduces the figure of "vendor of Smart Contracts" that trade Smart Contracts, and introduce a legal responsibility for the behavior of the contract he/she is trading for. The Chain of Trust should fill this gap. The present clause is kept voluntarily short because technical material can be retrieved almost everywhere on academia, web sites, encyclopedias, standardization organizations et al. involved in Computer Science and Data Science.
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5.5.2 Centralized systems
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Centralized data structure and centralized computing are the simplest way to store and execute. They represent the cornerstone of Computer Science and Data Science. Centralized data structures and centralized computing are, by its nature, compatible with the Chain of Trust.
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5.5.3 Decentralized systems
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Decentralized data structure and decentralized computing raised in the '70 in opposition to pure centralized solutions: this non-constructive approach (all that is "not" centralized) make impossible to formally characterize with a single unambiguous definition. Because of the too wide definition of decentralized data structure and decentralized computing, one does not have formal evidences that all decentralized data structure and decentralized computing are compatible with the Chain of Trust.
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5.5.4 Distributed systems
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Distributed data structures and distributed computing raised with the arrival of the network facilities (i.e. Internet) that allows system to communicate each other's. Control is not decentralized. Distributed data structures and distributed computing can be compatible with the Chain of Trust.
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5.5.5 Peer-to-peer systems
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Peer-to-systems raised as an evolution of decentralized systems where data and control are completely distributed. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 43 One does not have evidences that peer-to-peer data structures and peer-to-peer computing can/cannot be compatible with the Chain of Trust. This can change in the future.
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5.5.6 Cloud systems
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According to ISO/IEC 22123-2 [i.66], Cloud is a paradigm for enabling network access to a scalable and elastic pool of shareable physical or virtual resources with self-service provisioning and administration on-demand. Cloud data structures and cloud computing can be compatible with the Chain of Trust.
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5.5.7 Fog systems
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Fog is an improvement of Cloud. Fog was standardized in IEEE 1934 [i.67]. Fog extends Cloud in order to cope with huge number of IoT devices and big data volumes for real-time low-latency applications. Fog data structures and Fog computing can be compatible with the Chain of Trust.
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5.6 Legal issues in Smart Legal Contracts
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5.6.1 Essential Overview
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The present clause is about the concept of Smart Legal Contract (a Smart Contract with legal relevance), in terms of evidence of the script/contract itself: it is relevant to bring the Smart Contract, considered as a simple code script with only technological relevance, into the legal context drawn by both EU Regulations [i.1] and [i.2]. When the computer code, therefore, also acquires legal relevance, it is necessary to validate it through the typical legal-tech tools, read SC Legal Text in the Chain of Trust. Legal systems agree to the, so called, freedom of form principle, namely, requirement that the agreement be made in a specific form in order for it to be valid between the parties. Therefore, smart legal contract can and will count as legal contracts. The present clause contributes to fix some definitions and technical issues that are important to understand the European regulations, fit the future standards and the de facto standards all together. The Chain of Trust should fill this gap.
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5.6.2 Legal parties
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Before thinking the logical flow and surely before the writing the code, the present document discusses legal issues related to the rendering of parties legal will and intensions. For a Smart Legal Contract this analysis is even more critical than a traditional paper or an electronic contract: in fact, Smart Contracts are mostly deployed in a public environment and theoretically usable by anyone: standards are needed to drive the coder, SC Development Team, and the lawyer, SC Legal Team, in order to map all the correct stakeholders.
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5.6.3 Certified code translation and evidences
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The present document discusses about logical/legal algorithmic faults detected by a TechLawyer, namely a Lawyer with Computer Science skills, able to work in Computer Forensics and able to render legal aspects into logical/diagram flows. The TechLawyer should be able to discern between computer code with no legal relevance and annotated computer code with legal relevance (i.e. a Smart Legal Contract). In a Smart Legal Contract, the legal contract, written in plain English and the contract execution written in computer code cohabitate in the same file stored in the Electronic Ledger. The Chain of Trust can be summarized as follows: • "Plain English" Smart Contract: Smart Legal Contract is - also - a translation of a plain English contract. Standards are needed to grant that this operation is made reducing the risk of misinterpretation of parties' will. • "Flow chart" Smart Contract Logic: while translating the parties' will, standards are needed to decant the plain English logic to a specific script/program. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 44 • "Annotations and Code" Smart Contract: in order to grant the coherence and interpretation of the code, annotation ("comments") can be used directly inside the code. This approach, which needs standardization, is useful to grant interoperability and interpretation of the code itself, from a legal point of view. • Evidence generation and long-term preservation: ledgers and (qualified) archiving are two useful tools to grant resiliency of evidences related to the Smart Legal Contract. They need to be used in this context to facilitate digital forensics to enforce Smart Legal Contracts, even in Courts.
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5.7 Environmental and sustainability models of Smart Contracts
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This topic, although essential, is not treated in the present document. 5.8 Underlying networks to support the deployment and execution of Smart Contracts As cited from eIDAS2 [i.2]: "(49) To ensure the proper functioning of European Digital Identity Wallets, European Digital Identity Wallet providers need effective interoperability and fair, reasonable and non-discriminatory conditions for the European Digital Identity Wallets to access specific hardware and software features of mobile devices. Those components could include, in particular, near field communication antennas and secure elements, including universal integrated circuit cards, embedded secure elements, microSD cards and Bluetooth Low Energy. Access to those components could be under the control of mobile network operators and equipment manufacturers. Therefore, where needed to provide the services of European Digital Identity Wallets, original equipment manufacturers of mobile devices or providers of electronic communication services should not refuse access to such components. In addition, the undertakings that are designated as gatekeepers for core platform services as listed by the Commission pursuant to Regulation (EU) 2022/1925 of the European Parliament and of the Council should remain subject to the specific provisions of that Regulation, building on Article 6(7) thereof". Though Smart Contracts can be provided as an overlay service on top of a network infrastructure, the elements as well as the whole underlying networks will need to be considered when deploying the services. As the article (49) of eIDAS2 requires, EUDIW should be treated equally when accessing the underlying networks. Particularly, components on mobile devices (e.g. NFC, SIM card and eSIM) should fully support functioning EUDIW; in addition, for accessing the Smart Contracts over the mobile devices should be supported and operated by the mobile networks. In sum, both mobile device manufacturers, component vendors (e.g. card vendors) and network equipment vendors should fully support EUDIW and Smart Contract services. The role of the underlying networks matters to the adoption of Smart Contracts. On the one hand, some nationwide/worldwide network infrastructures directly decide the accessibility and coverage of the deployed dAPPs offering reachability to EUDIW. Without the underlying networks' participation, especially nationwide mobile network infrastructure, the service range will be quite limited. On the other hand, underlying networks usually are usually built and operated by large operators (e.g. mobile network operators), thus a large number of subscribers are already gathered. Therefore, behind the underlying networks, the nature of the trusts from them plays a big role when offering dAPPs based on Electronic Ledger. As a result, underlying networks such as critical network infrastructures should stake their reputation to become a QTSP thus make the Smart Contracts highly trustworthy. 6 Synthetizing the Chain of Trust as a roadmap for ETSI TS 119 541 and ETSI TS 119 542 6.1 Essential Overview The present clause synthetizes all the issues raised by the Chain of Trust presented in Clause 5. Ideally, it passes the baton to technical specifications ETSI TS 119 541 [i.12] and ETSI TS 119 542 [i.16] that will translate in formal requirements. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 45 Some remarks are in order to understand the next two ETSI Technical Specifications [i.12] and [i.16]: • They should specify whether there is the need for the mentioned specification to be certified or not, and in case yes, by whom and under which schema this certification should be carried out. • They should specify whether there is the need for the mentioned SC Compiler and SC Virtual Machine to be certified or not, and in case yes, by whom and under which schemas these certifications should be carried out. • They should specify the requirements for identification of the SC Compiler and the requirements for the seals on the SC Byte Code. • They should specify the requirements for identification of the mentioned entities and the requirements for the signatures on the Smart Contract and of the Electronic Ledger. • They should specify the requirements for identification of the Smart Contract caller and the requirements for this signed declaration. The present clause will proceed by collecting potential issues worth of study by the following categories: • Electronic identity issues. • Cybersecurity issues. • Privacy issues. • Governance issues. • Programming tools issues. • Legal issues. • Data sharing issues. • Centralized and decentralized execution issues. • Interoperability issues. • Network issues. • Open-source issues.
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6.2 Electronic identity issues
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Based on the evaluation of electronic identity issues, a family of electronic identity schemes should be selected as standardized schemes for Smart Contracts. In addition, for those that could not fulfil the EU Regulations, clear guidance should be suggested for electronic identity scheme migration (especially for legacy information and communication technology systems). The Chain of Trust lies in a fundamental usage of electronic identity.
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6.3 Cybersecurity issues
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Trust service providers for Electronic Ledgers and Smart Contracts are required to meet the requirements of the NIS2 Directive [i.11]. Moreover, ETSI EN 319 401 [i.13] defines general policy and requirements for the security of trust service providers aimed at meeting the requirements of NIS2 [i.11]. At the time of writing of the present document, hackers have maliciously substituted some Smart Contracts code with another (refers as the "Bybit hack 2025"): it is difficult to fully understand what happened and all involved actors. The Bybit hack 2025 would not be possible using entities and interactions as in Chain of Trust. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 46
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6.4 Privacy issues
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Privacy is an important factor to be taken into account for identification applied to Smart Contracts, in particular with regards to identification of the contracting parties. eIDAS signatures and eIDAS2 wallets support a number of features which support privacy. eIDAS electronic signatures and seals allow for the use of pseudonyms when identifying a natural or legal person. This allows for the full identity of the person to be replaced with some other unique reference which does not directly identify the person. However, this still allows for a degree of traceability / linkability of a person's activity. eIDAS2 identities support a number of features which assure privacy. If particular, through use of selective disclosure of attributes (see ETSI TR 119 476 [i.10]) it is possible using EU Regulation on Digital Identity Wallets to reveal only selected attribute of the person without revealing their full identity. In considering the application of privacy measures, such as described above, the requirement that contracting parties cannot later deny in a court of law having agreed to the Smart Legal Contract based on Electronic Ledgers needs to be taken into account. Further security may be afforded through security measure applied to the Electronic Ledger (e.g. use of secure records held off-chain referenced from the ledger) may be used to ensure the privacy of identities recorded in an Electronic Ledger. Privacy issues are clearly described in the Chain of Trust.
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6.5 Governance and Audit issues
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Governance and audit issues are fundamental in the Chain of Trust. Three areas of issues need to be taken into account in considering the governance of systems supporting Smart Contracts: 1) eIDAS2 [i.2] Requirements for Electronic Ledgers i) Under definition for Electronic Ledgers as specified in eIDAS2 [i.2] Article 3 (53) the integrity and the accuracy of their chronological ordering of electronic data records which form the ledger needs to be ensured. ii) Under eIDAS2 [i.2] Article 45i: Requirements for Qualified Electronic Ledgers they following specific requirements apply to Qualified Electronic Ledgers: a) they are created and managed by one or more Qualified Trust Service Provider (QTSP) or providers; b) they establish the origin of data records in the ledger; c) they ensure the unique sequential chronological ordering of data records in the ledger; d) they record data in such a way that any subsequent change to the data is immediately detectable, ensuring their integrity over time. iii) Under eIDAS2 each QTSP is required to be supervised and audited under eIDAS [i.2] Article 20 and 21 and Article 24.2 including the requirements of NIS 2 [i.11]. 2) Requirements for eIDAS2 Electronic Ledgers involving Multiple QTSPs - Where more than one QTSP is involved in the creation and management of an Electronic Ledger the overall trust service, as provided by a community of QTSPs, needs to meet the requirements i) and ii) above in a common way. In addition, each QTSP needs to meet the requirement of iii) above. 3) Requirements of Smart Contracts - The additional requirement of Smart Contracts, as specified in the definition given Data Act Article 2(39), in addition to use of an electric ledger, is "the computer program used for the automated execution of an agreement or part thereof". ETSI ETSI TR 119 540 V1.1.1 (2025-10) 47 - Firstly, the execution environment needs to be secure. If this is in a QTSP then this would be addressed by the general requirements of eIDAS2. Otherwise, similar NIS2 based controls can be used to ensure general security of the execution environment. If a cloud-based execution environment is used it might be sufficient to use a cloud environment certified under the EU Regulation on certification scheme. However, further analysis is required to ensure that any specific concerns for Smart Contracts are met the whichever approach is taken. - Secondly, the "computer program" used needs to be considered trustworthy. This aspect needs specific consideration, because is very generic. The main role of the governance regime is to assure the trustworthiness of Smart Contracts and the underlying system infrastructure. Governance of an individual QTSP is provided through the eIDAS2 [i.2] supervision and audit regime. Governance of a community of QTSPs providing an Electronic Ledger requires governance through a previsioning regime whereby not only the QTSPs are accepted under [i.2] supervision and audit regime, but also it is demonstrated that they apply a common Electronic Ledger policy for achieving the requirements of an eIDAS ledger in a collaborative manner. This permissioning regime requires a community governance permissioning system which issues its "trusted" information (e.g. trusted list) based on the results of an eIDAS audit including the audit against the requirements of the common Electronic Ledger policy. Assurance that a computer program used for the automated execution of an agreement or part thereof needs its own governance regime. It can use eIDAS signing certificates but also the CA/Browser Baseline Requirements for the Issuance and Management of Publicly Trusted Code Signing Certificates should be taken into account. Additional requirements need to be placed on the origin of the computer program to ensure that the code is developed in a trustworthy manner and allows the parties agreeing to a contract to understand the basis of the agreement. ISO, ETSI, CEN, and ITU-T X are quite active in governance issues concerning Smart Contracts, Electronic Ledgers, and distributed ledgers. Because of the rapid growth of use and development standards sometimes overlap, become obsolete, or have conflicts. At the time of publication of the present document, the text below reflects the status of affairs in governance and audit issues that are fundamental in the Chain of Trust. ETSI TC ESI provides general security controls aimed at meeting the requirements of Regulation (EU) 2024/1183 [i.2] TSPs including the requirements of NIS 2 [i.11]: • ETSI TS 119 541 [i.12] specifies the policy and security requirements for Smart Contracts using Electronic Ledgers as defined in eIDAS2 [i.2], and with other trustworthy tools, taking into account the framework of requirements identified in the present document. • ETSI TS 119 542 [i.16] specifies the use of EU Regulation on Digital Identity Wallets, and advanced or Qualified Electronic Signatures and Seals conforming to the requirements of eIDAS2 [i.2]. The Advanced or Qualified Electronic Signatures and Seals in the present document are implemented using digital signatures. • An audit of an individual QTSP that meets the specific requirements for Smart Contracts using Electronic Ledgers can be based on trust service policy and security requirements in line with the general audit and cyber security framework for trust services presented in ETSI EN 319 401 [i.13] and ETSI EN 319 403-1 [i.14]. ETSI GR PDL 017 [i.49] describes the features of a distributed ledger to be applicable as a Qualified Electronic Ledger and in support for eIDAS2 [i.2] trust services: it analyses the properties that a PDL can have to be an enabler for eIDAS regulation for electronic identification, authentication and signatures, and also for using eIDAS2 [i.2] in other areas of the Digital Economy. ETSI ISG PDL, at the time of publication of the present document, is merged in ETSI TC DATA. The ETSI TS 104 172 [i.23] will distill, among others, formal recommendations from ETSI GR PDL 017 [i.49] respecting compatibility and avoiding overlapping with ETSI TS 119 541 [i.12], ETSI TS 119 542 [i.16]. CEN JTC 19, at the time of the publication of the present document, is working on a specification for policy and security requirements for trust service providers providing Electronic Ledger services, following ETSI EN 319 401 [i.13] respecting compatibility and avoiding overlapping with ETSI TS 119 541 [i.12] and ETSI TS 119 542 [i.16]. ISO provides principles on which a community governance regime may be based ISO/TS 23635 [i.15]. Recommendation ITU-T X.1403 [i.33] provides telecom-specific privacy and security considerations for using distributed ledgers data in identity management. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 48
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6.6 Programming tools issues
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SC Language Specification Team, SC Compiler Team, SC Virtual Machine Team, SC Language Publisher, SC Compiler Publisher, SC Virtual Machine Publisher, should cooperate in the production of the SC Compiler and a SC Virtual Machine. SC Developer Team and SC Legal Team and SC Publisher should cooperate to write a Smart Legal Contract. The entity(ies) identified in the Smart Contract as either the entity originating the Smart Contract, or the entities that agree to be bound by the Smart Contract, should also sign it. The SC Byte Code, generated by the SC Compiler, should be sealed by the SC Language Publisher. In case that the caller is not one of the entities identified in the Smart Contract but another entity who accepts to be bound by its terms and conditions, there is the need of a signed declaration of acceptance of these terms and conditions of the mentioned Smart Contract. ETSI TS 119 542 [i.16] should specify the requirements for identification of the Smart Contract caller and the requirements for this signed declaration. Formal Verification: The SC Language Publisher, SC Compiler Publisher, and SC Virtual Machine Publisher may (at the highest level of security) include formal verification tools to ensure that Smart Contracts are mathematically proven to be correct, secure, and free from vulnerabilities: • SC Compiler and SC Virtual Machine Consistency: The Language Publisher, SC Compiler Publisher, and SC Virtual Machine Publisher should ensure that the SC Compiler translates code consistently and accurately across different environments, with no discrepancies in the generated SC Byte Code. They should ensure that the SC Virtual Machine execute SC Byte Code consistently and accurately, even across different environments, with no discrepancies. • Automated Testing: The Language Publisher, SC Compiler Publisher, and SC Virtual Machine Publisher should support automated testing frameworks that can run unit tests, integration tests, and stress tests to validate the behavior of the Smart Contract. • Error Reporting: The Language Publisher, SC Compiler Publisher, and SC Virtual Machine Publisher should provide detailed error reporting and debugging tools to identify and resolve issues during the development process. • Security Audits: The Language Publisher, SC Compiler Publisher, and SC Virtual Machine Publisher should integrate security auditing tools that can analyse Smart Contracts for common vulnerabilities like reentrancy, overflow, and underflow.
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6.7 (Smart) legal issues
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• Legal Compliance: The SC Publisher should ensure that Smart Contracts comply with relevant legal frameworks and can be validated against legal standards. • Contract-to-Code Translation: The SC Publisher should provide mechanisms to accurately translate Legal Contracts into executable Smart Legal Contracts, ensuring that all legal terms are faithfully represented in the SC Byte Code. • Audit: The SC Publisher should maintain an immutable audit that documents every change made to the Smart Contract, ensuring transparency and traceability. • Reverse Engineering: The SC Publisher should allow for the extraction of legal documents from Smart Contracts to ensure they can be reviewed and understood in legal contexts. • Dispute Resolution Integration: The SC Publisher should include tools for integrating dispute resolution mechanisms within Smart Contracts to handle legal disputes automatically or semi-automatically.
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6.8 Data sharing issues
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• Data Privacy: The (Qualified) Electronic Ledger should ensure that all shared data is encrypted and access- controlled to protect sensitive information from unauthorized access. • Data Integrity: The (Qualified) Electronic Ledger should implement mechanisms to verify that data has not been tampered with during transmission or storage. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 49 • Interoperability: The (Qualified) Electronic Ledger should support standard data formats and protocols to enable seamless sharing of data across different systems and platforms. • Scalability: The (Qualified) Electronic Ledger should be able to handle large volumes of data efficiently without compromising performance. • Compliance: The (Qualified) Electronic Ledger should ensure that data sharing practices comply with relevant regulations, such as GDPR [i.7], to protect user privacy and rights.
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6.9 Decentralized execution issues
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• Performance: The SC Publisher and the (Qualified) Electronic Ledger should execute efficiently, with minimal latency and resource consumption to ensure smooth operation across the network. • Reliability: The SC Publisher and the (Qualified) Electronic Ledger should ensure that Smart Contracts execute reliably under all conditions, including network congestion or high transaction volumes. • Scalability: The SC Publisher and the (Qualified) Electronic Ledger should support scaling, allowing Smart Contracts to handle increased loads without degrading performance. • Fail-Safe Mechanisms: The SC Publisher and the (Qualified) Electronic Ledger should include fail-safe mechanisms to gracefully handle execution failures, should ensure that contracts can recover or roll back in case of errors. • Auditability: The SC Publisher and the (Qualified) Electronic Ledger should provide tools to audit the execution of Smart Contracts, should ensure that every action taken by the contract can be traced and verified.
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6.10 Interoperability issues
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• Cross-Platform Compatibility: The (Qualified) Electronic Ledger should ensure that Smart Contracts can interact with other blockchains or systems, using standardized protocols and interfaces. • Data Standardization: The (Qualified) Electronic Ledger should use standardized data formats to ensure that information can be shared and understood across different platforms. • Protocol Support: The (Qualified) Electronic Ledger should support multiple communication protocols to enable interoperability between various networks and external systems. • API Integration: The (Qualified) Electronic Ledger should provide robust APIs that allow external systems to interact with Smart Contracts, facilitating integration with other services and platforms. • Security: The (Qualified) Electronic Ledger should ensure that interoperability does not compromise the security of the Smart Contracts or the connected systems.
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6.11 Networks issues
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• Pervasiveness: The network should support the users to access to the Smart Contracts with high availability and ubiquity (e.g. across urban and rural areas, fixed or mobile coverage). • Reliability: The network should support the users to access to the Smart Contracts with high service continuity (e.g. the reliable connectivity either wired or wireless). • Trustworthiness endorsement: The networks should contribute to maintain the high trustworthiness of the provided Smart Contract. • Security: The network should ensure security from attacks, including distributed denial of service, sybil, and other common network-based threats. • Decentralization: The network should be sufficiently decentralized to prevent any single entity from gaining control over the system. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 50 • Scalability: The network should support scalability to handle a growing number of nodes and transactions without performance degradation. • Redundancy: The network should implement redundancy and fault-tolerant mechanisms to ensure network reliability even if some nodes fail. • Low Latency: The network should offer low-latency communication to ensure timely execution of Smart Contracts and transactions.
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6.12 Open-source vs. Closed-source issues
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Open-source may be a model to assess code during the software construction and maintenance: in this model Governance is distributed with a (un)limited number of participants (for example: Linux kernel™, GNU C-compiler). Open-source is also used by Governments as an extra non legal service to official services. As an example, the Etalab initiative of the French government. Closed-source model may be also a possible model to assess code, but it should be assessed ex ante, using possibly Governance(s) that fund the software construction and validation.
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7 Conclusions
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The Chain of Trust V1, at the time of the publication of the present document, represent a first attempt to list a sufficient set of interactions between entities, results produced, identification and assurance needs. A precise interaction between two or more entities is shown. The Chain of Trust V1 is translated in formal requirements in ETSI TS 119 541 [i.12] and ETSI TS 119 542 [i.16]. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 51 Annex A: An example of the Chain of Trust A.1 Essential Overview This annex provides an explanatory example of the processes involved in designing, assigning a legal value, deploying and executing a Smart Legal Contract in an Electronic Ledger. The example is presented by means of four figures. The particular case of a deployment and execution of a Smart Legal Contract on a distributed ledger as defined in ISO 22739 [i.3] solution is presented. The figures identify all the relevant actors, artifacts, hardware, networks and tools, emphasizing the critical points where security and identity issues are paramount. This description is described by means of the Chain of Trust introduced in Clause 5, considering all involved entities and their relations. The Chain of Trust occurs at many abstraction levels: in the particular case of a distributed environment, extra difficulties arise. The security of deploying and executing Smart Legal Contracts can be significantly compromised by an incomplete validation chain, which exposes users to various risks, including fraud and attacks. Summarizing, the entities involved in the Chain of Trust in a distributed setting are defined in Clause 3.1 and described in Clause 5. A.2 Figures as an example of the Chain of Trust Figure A.1, Figure A.2, Figure A.3 and Figure A.4 present the "fine-grained" implementation of the Chain of Trust as suggested in Table 1, instantiated to distributed ledgers as defined in ISO 22739 [i.3]: entities, their relations participating in the production, deployment, and execution of Smart Legal Contracts and the design of the SC Languages are represented. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 52 Figure A.1: Chain of Trust: SC Language design ETSI ETSI TR 119 540 V1.1.1 (2025-10) 53 Figure A.2: Chain of Trust: Smart Legal Contract design ETSI ETSI TR 119 540 V1.1.1 (2025-10) 54 Figure A.3: Chain of Trust: Smart Contract deployment on a distributed ledger ETSI ETSI TR 119 540 V1.1.1 (2025-10) 55 Figure A.4: Chain of Trust: Smart Contract execution on a distributed ledger ETSI ETSI TR 119 540 V1.1.1 (2025-10) 56 Annex B: Chain of Trust: Architectural Elements (schematic) Figure B.1 ETSI ETSI TR 119 540 V1.1.1 (2025-10) 57 Annex C: Comparative overview of definitions Legal definitions are technology-neutral and designed to support regulatory enforceability. ETSI TS 119 541 [i.12] and ETSI TS 119 542 [i.16] rely on the legal definitions to address legal compliance, and when it is the case, can reference ETSI or other standard definitions for implementation guidance. Table C.1: Legal Definitions Term Source Definition Comment Smart Contract Regulation (EU) 2023/2854 [i.1], Article 2(39) (Data Act) "A computer program used for the automated execution of an agreement or part thereof, using a sequence of electronic data records and ensuring their integrity and the accuracy of their chronological ordering." Legal basis under the Data Act EU Law [i.1]. Smart Contract as per [i.1], are referred as SC Byte Code in the present document. The definition of Smart Contract in [i.1] and in the present document is more general than the definition of smart contract in ISO 22739 [i.3]. Electronic Ledger Regulation (EU) 2024/1183 [i.2], Article 3(52) (eIDAS2) "Electronic ledgers are a sequence of electronic data records which should ensure their integrity and the accuracy of their chronological ordering. Electronic ledgers should establish a chronological sequence of data records […] The process of creating and updating an electronic ledger depends on the type of ledger used, namely whether it is centralized or distributed. This Regulation should ensure technological neutrality, namely neither favoring, nor discriminating against, any technology used to implement the new trust service for electronic ledgers […]" Legal basis under eIDAS2 EU Law [i.2]. Because an Electronic Ledger can be centralized or distributed, the definition of Electronic Ledger in [i.2] and in the present document is more general than a distributed ledger in ISO 22739 [i.3]. Table C.2: Technical Definitions Term Source Definition Comment smart contract ISO 22739[i.3] Computer program stored in a distributed ledger technology (DLT) system wherein the outcome of any execution of the program is recorded on the distributed ledger DLT-specific; may not align with legally neutral approach. Because of the specificity of the input of the computer program to be defined only with a DLT, the definition of the output of the computer program can be undefined in case of centralized Electronic Ledgers. The definition of Smart Contract in [i.1] diverges with the definition of smart contract in ISO 22739 [i.3]. distributed ledger ISO 22739 [i.3] Ledger that is shared across a set of distributed ledger technology (DLT) nodes and synchronized between the DLT nodes using a consensus mechanism Contrasts with broader legal definition of "Electronic Ledger". Because an Electronic Ledger can be centralized or distributed, the definition of Electronic Ledger in [i.2] is more general definition that a distributed ledger in ISO 22739 [i.3]. ETSI ETSI TR 119 540 V1.1.1 (2025-10) 58 Annex D: Change history Date Version Information about changes February 2024 0.0.1a Bootstrapping of the present document and few Editor annotations in RED (Inria) March 2024 0.0.1b Some Sections names proposals and more editor annotations in RED taken from the STF 655 contract (Inria) 23 April 2024 0.0.1c Fix TR name according to the STF 655 contract. Discuss the first ToC V0 (Inria) and modify to ToC V1 (Inria, INFOCERT, UPC, Observatorium, Nokia) 30 April 2024 0.0.1d Improve ToC according to the STF 655 contract, by Inria, INFOCERT and Nokia 30 April 2024 0.0.1e Formatting (Inria) 7 Mai 2024 0.0.1f Set up Clauses 1, 2, 3, References, Introduction. Simplifying and clustering ToC (Inria, Huawei, INFOCERT). Adding Editor annotations in RED 21 Mai 2024 0.0.1g Refactoring of all Clauses keeping the contents (Inria, SSA, UPC, INFOCERT, Observatorium, Huawei). Adding Editor annotations in RED 28 Mai 2024 0.0.1h Last review of all Clauses (SSA, Inria, InfoCert, CCC, Huawei). Adding Editor annotations in RED 11 Juin 2024 0.0.1i Adding Editor annotations on Clauses 5 and 6 (SSA, UPC, Inria, Huawei) in RED 11 September 2024 0.0.1l Including all Experts contributions, with a minimal formatting (Inria) 3 October 2024 0.0.1m Expanding and including all Experts contributions, with formatting (Inria) 7 October 2024 0.0.2a Clause 4 and clause 5 stabilized (Inria, UPC, INFOCERT) 17 October 2024 0.0.2b Clause 5 moved to Clause 3 (Terms), including discussions on terms, rearranging Clause 5 (formerly 6), and Claude 6 (formerly 7), and inclusion all Huawei and Inria contributions (Inria) 17 October 2024 0.0.2c Inclusions of all comments of the last meeting and few sanity checks (Inria) 17 October 2024 0.0.2c Added bibliography and better Table 1 fitting Chain of Trust figures (Inria, SSA) 17 October 2024 0.0.2d Drawing Chain of Trust figures, harmonizing Clause 4 (Inria) 22 October 2024 0.0.2d Harmonizing Clause 5 and 6 (Inria) 30 October 2024 0.0.2d Final pass (Inria) 20 November 2024 0.0.2e NEW HANDY TABLE (See CR Meeting 19 November Inria) 3 December 2024 0.0.2f Actual status of the Table 1 as per SSA/INFOCERT/Inria is Installed in Clause 5.1, Terms are installed in Clause 3.1, Clause 5.10 is deleted, and Figures are now in Appendix. Prose in Clause 5 is unstable 20 December 2024 0.0.3a The Inria inspired and tuned by SSA and INFOCERT "Chain of Trust", agreed by ALL in the last two weekly meeting (3/12 and 10/12) is installed in Clause 5.2. A NEW Clause 3.1 (Terms) according to Table 5.2 is installed in RED. The Chain of Trust and its Terminology will be synchronized in the TS x541 and TS x542 7 January 2025 0.0.3b Fixing Clause 3.1 (Terms) respecting UE terminology, and taking into account SSA and JTC19 comments (Inria) 14 January 2025 0.0.3c Clause 4 (INFOCERT and Inria) 21 January 2025 0.0.3d Merging and implementing dispositions (Inria) 23-25 January 2025 0.0.3e Alignment with SSA and JTC19 on Terminology and on the "Chain of Trust" (Inria) 31 January 2025 0.0.4a General improvements according to ETSI rules (Inria) 3 February 2025 0.0.5a General last-minute improvements (Inria) 3 February 2025 0.0.6a General last-minute improvements (ETSI) April 2025 0.0.7a Implementation of dispositions of comments for v0.0.6 producing a major new version (Inria) April 2025 0.0.7b Implementation of ETSI suggestions (ETSI) May 2025 0.0.7c Implementation of disposition of comments (Inria) Juin 2025 0.0.8a Various alignments with x541 and x542 and implementation of ETSI suggestions July 2025 0.0.8b Various alignments with x541 and x542 and implementation of C3L July 2025 0.0.8c Various alignments with x541 and x542 and implementation of C3L & UPC suggestions during the 10/07/25 meeting September 2025 0.0.9a Wrapping up and final tuning (Inria) September 2025 0.0.9b UPC last comment resolution (Inria) September 2025 0.0.10a Implementation of ETSI suggestions September 2025 0.0.11a Implementation of ETSI suggestions September 2025 0.0.12a Implementation of ETSI suggestions ETSI ETSI TR 119 540 V1.1.1 (2025-10) 59 History Document history V1.1.1 October 2025 Publication
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1 Scope
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The present document supports the preparation of the answer to C(2025)4135 - Standardisation Request M/614 [i.3] further on called "SReq" in the present document. The present document is based on the input from ETSI TR 104 409 [i.1]. Both reports (the present document and ETSI TR 104 409 [i.1]) will prepare the normative work to satisfy the SReq [i.3]. The present document is structured as follows: • Clauses 1 to 3 set the scene and provide references as well as definitions of terms, symbols and abbreviations, which are used in the present document. • Clause 4 provides a summary of the findings highlighted in ETSI TR 104 409 [i.1] about how oneM2M fulfils the EU Data Act [i.2] with particular reference to Article 33 and the SReq [i.3]. It presents guidelines about how oneM2M can be used to fulfil as much as possible the standardization requirements of these two documents without the need for changes to oneM2M specifications. Additionally, this clause lists potential Change Requests (CRs) that would enable oneM2M to fulfil some of the aspects of these two documents (i.e. ETSI TR 104 409 [i.1] and the present document) that are currently not covered. The content focuses on improvements that can be implemented in a reasonable manner according with the timing available to make oneM2M compliant with the EU Data Act [i.2] with particular reference to Article 33 and the SReq [i.3]. Some requirements of the two documents fall outside the scope of oneM2M specifications. Where possible, this clause provides clarification of such boundaries together with additional guidelines that may help define a clear positioning for oneM2M in the context of the two documents. • Clause 5 provides a summary of the findings highlighted in ETSI TR 104 409 [i.1] about how SAREF fulfils the EU Data Act [i.2] with particular reference to Article 33 and the SReq [i.3]. It lists feasible improvements that would enable SAREF [i.4] to fulfil the standardization requirements of these two documents. The content focuses on improvements that can be implemented in a reasonable manner according with the timing available to make SAREF compliant with the two documents. Clause 5 provides possible additional guidelines for aligning SAREF with the EU Data Act [i.2] with particular reference to Article 33 and the SReq [i.3]. • Clause 6 provides a summary of the findings highlighted in ETSI TR 104 409 [i.1] about how NGSI-LD fulfils the EU Data Act [i.2] with particular reference to Article 33 and the SReq [i.3]. It provides guidelines about how NGSI-LD can be used to fulfil as much as possible the two documents without carrying out changes within the NGSI-LD methodology. Clause 6 lists feasible improvements that would enable NGSI-LD to fulfil the standardization requirements of these two documents. The content focuses on improvements that can be implemented in a reasonable manner according with the timing available to make NGSI-LD compliant with the EU Data Act [i.2] with particular reference to Article 33 and the EU Standardisation Request, e.g. the definition of the mappings between NGSI-LD and DCAT-AP provided in [i.7]. • Clause 7 provides insights about if the union of the three assets enables the fulfilment of the EU Data Act [i.2] with particular reference to Article 33 and the SReq [i.3]. • Clause 8 provides a summary of conclusions from the standardization suggestions.
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2 References
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2.1 Normative references
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Normative references are not applicable in the present document. ETSI ETSI TR 104 410 V1.1.1 (2025-10) 7
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2.2 Informative references
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References are either specific (identified by date of publication and/or edition number or version number) or non-specific. For specific references, only the cited version applies. For non-specific references, the latest version of the referenced document (including any amendments) applies. NOTE: While any hyperlinks included in this clause were valid at the time of publication, ETSI cannot guarantee their long-term validity. The following referenced documents may be useful in implementing an ETSI deliverable or add to the reader's understanding, but are not required for conformance to the present document. [i.1] ETSI TR 104 409: "Data Solutions (DATA); Data Act (art. 33) requirement and references analysis". [i.2] Regulation (EU) 2023/2854 of the European Parliament and of the Council of 13 December 2023 on harmonised rules on fair access to and use of data and amending Regulation (EU) 2017/2394 and Directive (EU) 2020/1828 (Data Act). [i.3] C(2025)4135 – Standardisation request M/614: "Commission Implementing Decision of 1.7.2025 on a standardisation request to the European standardisation organisations as regards a European Trusted Data Framework in support of Regulation (EU) 2023/2854 of the European Parliament and of the Council". [i.4] ETSI SAREF portal. [i.5] ETSI EN 303 760: "SmartM2M; SAREF Guidelines for IoT Semantic Interoperability; Develop, apply and evolve Smart Applications ontologies". [i.6] ETSI GS CIM 006: "Context Information Management (CIM); NGSI-LD Information Model". [i.7] ETSI GR CIM 048: "Context Information Management (CIM); Handling of data catalogues and data services with NGSI-LD". [i.8] DCAT-AP 3.0.1 profile. [i.9] ETSI TS 104 414: "Data Solutions (DATA); Ontology Web Server - Functional Interfaces and Architectural Specification". [i.10] ETSI TS 104 415: "Data Solutions (DATA); IoT Ontology Web Server - User Interfaces and Use Cases". [i.11] ETSI TR 104 416: "Data Solutions (DATA); IoT Ontology Web Server - Security, Deployment, and Support".
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3 Definition of terms, symbols and abbreviations
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3.1 Terms
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For the purposes of the present document, the following terms apply: ACME CSE: open source CSE Middleware for Education connected product: item that obtains, generates or collects data concerning its use or environment and that is able to communicate product data via an electronic communications service, physical connection or on-device access, and whose primary function is not the storing, processing or transmission of data on behalf of any party other than the user data holder: natural or legal person that has the right or obligation, in accordance with the EU Data Act [i.2], applicable Union law or national legislation adopted in accordance with Union law, to use and make available data, including, where contractually agreed, product data or related service data which it has retrieved or generated during the provision of a related service ETSI ETSI TR 104 410 V1.1.1 (2025-10) 8 data processing service: digital service that is provided to a customer and that enables ubiquitous and on-demand network access to a shared pool of configurable, scalable and elastic computing resources of a centralized, distributed or highly distributed nature that can be rapidly provisioned and released with minimal management effort or service provider interaction data recipient: natural or legal person, acting for purposes which are related to that person's trade, business, craft or profession, other than the user of a connected product or related service, to whom the data holder makes data available, including a third party following a request by the user to the data holder or in accordance with a legal obligation under Union law or national legislation adopted in accordance with Union law EU Data Act: Regulation (EU) 2023/2854 of the European Parliament and of the Council of 13 December 2023 on harmonised rules on fair access to and use of data and amending Regulation (EU) 2017/2394 and Directive (EU) 2020/1828 (Data Act) [i.2] GeoDCAT-AP: extension of DCAT-AP for the representation of geographic metadata public sector body: national, regional or local authorities of the Member States and bodies governed by public law of the Member States, or associations formed by one or more such authorities or one or more such bodies smart contract: computer program used for the automated execution of an agreement or part thereof, using a sequence of electronic data records and ensuring their integrity and the accuracy of their chronological ordering SReq: Standardisation Request to the European Committee for Standardization (CEN), the European Committee for Electrotechnical Standardization (CENELEC) and the European Telecommunications Standards Institute (ETSI) as regards to a European Trusted Data Framework [i.3]
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3.2 Symbols
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Void.
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3.3 Abbreviations
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For the purposes of the present document, the following abbreviations apply: AI Artificial Intelligence API Application Programming Interface CEN European Committee for Standardization CENELEC European Committee for Electrotechnical Standardization CR Change Request DCAT Data CATalogue vocabulary DCAT-AP Data CATalogue vocabulary Application Profile DSSC Data Spaces Support Centre ETSI European Telecommunications Standards Institute EU European Union GDPR General Data Protection Regulation HTTP HyperText Transfer Protocol IoT Internet of Things JSON JavaScript Object Notation KPI Key Performance Indicator LLM Large Language Model MCP Model Context Protocol MQTT Message Queuing Telemetry Transport NGSI-LD Next Generation Service Interface-Linked Data RDF Resource Description Framework SAREF Smart Applications REFerence ontology SReq Standardisation Request TR Technical Report W3C® World Wide Web Consortium Web World Wide Web ETSI ETSI TR 104 410 V1.1.1 (2025-10) 9
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4 oneM2M
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4.1 Introduction
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The present clause gives a summary of the findings highlighted in ETSI TR 104 409 [i.1] about how oneM2M fulfils the EU Data Act [i.2] with particular reference to Article 33 and the EU Standardisation Request [i.3]. The summary guides the content of the remaining sub-clauses.
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4.2 Use as it is to fulfil the EU Data Act and the SReq
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oneM2M as it is does satisfy a substantial part of the SReq [i.3], especially in the following areas: • General Framework and Architecture: - oneM2M provides a comprehensive interoperability framework designed for seamless communication across various protocols and data models. - It supports a service layer that can be integrated into diverse hardware and software systems (this includes also access to devices, thanks to its legacy from IoT domain). • Terminology, Concepts, and Mechanisms: - oneM2M specifications clearly define: Terminology (e.g. "Application Entity," "Common Services Entity"). Architectural concepts (e.g. hierarchical resource structure). Mechanisms for data sharing, access control, and interoperability. oneM2M supports data sharing by design. API queries are supported, both simple ones and semantic based, also in distributed contexts. oneM2M by design supports distributed architectures. Thanks to its legacy as an IoT Platform, access to devices is native. • Interoperability Requirements: - Data sharing & API access: Fully specifies protocols (HTTP, MQTT, etc.) and RESTful APIs for automatic data transmission. - oneM2M specifies interoperability mechanisms allowing data exchange with other oneM2M instances and non-oneM2M systems while preserving data security and access rights. - It supports API queries, both simple and semantic based, even in distributed contexts. - Distributed architectures: native support for IoT devices and cross-platform data exchange. • Implementation Framework for Semantic Assets: - has good support for semantics, including storage, management, and discovery of ontologies, (e.g. SAREF, and custom ones). - Machine-readable data: Resources are represented in JSON, enabling semantic annotation. - It offers capabilities to discover resources based on semantic descriptions and content. • Trustworthiness Requirements: - oneM2M provides advanced granular access control incorporating roles, tokens, identity verification, time-based restrictions, and location-based conditions. ETSI ETSI TR 104 410 V1.1.1 (2025-10) 10 - It specifies sophisticated access control policies able to handle demanding scenarios. - Consent management support is available, considering GDPR and similar regulations in other parts of the world. - Data integrity: Versioning ("container instances") tracks changes. - License management: Explicitly specified for data sharing. As such, oneM2M can contribute to provide a solid framework for the implementation of "services" in the sense of the DSSC Blueprint, especially in the context of Technical Building Blocks. The Blueprint takes the stance that services can vary widely among Data Spaces, especially since specialized protocols may be in use according to individual vertical application. For that reason, the Blueprint cites examples but does not endorse one specific solution. oneM2M follows a different approach, i.e. that it assumes that most of the use cases can be tackled by using a single framework. Even in the cases where consolidated protocols/data layout are well established for a given vertical industry, a clear path for dealing with that (via the use of Application Entities) is outlined. This way, the effort needed to adapt to a new vertical is reduced to a minimum and clearly confined to easily identified sections of the software implementing the platform. Application Entities exchange data and information with the oneM2M core via messages, following to APIs that are well specified. This approach makes the code implementing the Application Entity to be disjoint from that of the oneM2M core: in this way, existing libraries for the existing/consolidated use cases can be leveraged, and there are no constraints regarding the programming language used. This is by design, with the intention of reusing as much as possible, avoiding reinventing the wheel each time.
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4.3 Potential improvements
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There are areas where oneM2M allows some room for potential improvements (work may be already being done to address some of said improvements): • Master Catalogue: - oneM2M does not provide a single master catalogue for listing available data. Considering the potential dimensions and the tremendous diversity of services, applications and of the related data sets, oneM2M provides advanced functionality to discover applications and related data, so that data catalogues can be easily built as oneM2M services. - Another work item, recently approved, calls for studying and specifying the interworking between oneM2M and Model Context Protocol (MCP). - This provides an alternative approach, in line with modern developments in LLMs and Agentic AI. There will be challenges as well, most notably about balancing the (typically greedy) access by AI against the granularity of access control allowed by the oneM2M specifications. • Data collection methodology, data quality, and uncertainty: - The oneM2M specifications only guarantee correct handling and transfer of data items between digital entities. - It is implicitly assumed that assessment of data quality is left either to human actors (who can have knowledge of the quality of data and related collection methodology) or to automated tools (that can, e.g. assess quality related information according to given KPIs). - A possible improvement, that can be considered by the oneM2M community, is to define a standardized way to convey information about quality of a given data item to participants of the Data Space. - Similar considerations might apply also to concepts like KPIs or reporting structure for Data Space maturity. ETSI ETSI TR 104 410 V1.1.1 (2025-10) 11 • Auditability of data transactions: - oneM2M provides users with a mechanism for data versioning (so called "content instances" in oneM2M jargon of any resource are kept available and can be accessed by users, subject to access control policies). - A possible improvement to this scheme is to standardize the recording of aspects of the actors that caused such changes to occur. In this way it becomes possible to ensure full accountability of the actors that operate on a given Data Space. Such a feature could be graduated according to the required degree of accountability, from none to who caused data changes up to who just accessed any resource for the most demanding cases.
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4.4 Additional guidelines
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Clauses 6.1.1 and 6.1.2 of ETSI TR 104 409 [i.1] explain that oneM2M is more that the specification of an IoT platform, stating it is well suited to support Data Spaces. These capabilities, however, are not currently advertised on the oneM2M.org website. A possible improvement is to augment the website content to reflect these considerations. oneM2M specifications are technical in nature and describe APIs, mechanisms for managing information, etc. There are guidelines and best practices for implementation and usage of the specifications but, currently, they are oriented towards technical users. To better meet some of the requirements from the SReq [i.3], additional guidelines can be provided, articulated in practical, non-legal language that is accessible to all potential stakeholders. Such additional guidelines should cover not only the way oneM2M compliant frameworks can be implemented/deployed, but also explaining how oneM2M features map to requirements of the SReq [i.3], including coverage of the way to meet domain-specific (non-regulatory) requirements
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5 SAREF
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5.1 Introduction
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ETSI TR 104 409 [i.1] provides an analysis about how the SAREF methodology fulfils the EU Data Act [i.2], with particular reference to the Article 33 and the EU Standardisation Request [i.3]. There have been two main aspects making SAREF well positioned compared to the EU Data Act [i.2]. The first one is that the SAREF methodology is mentioned within the SReq [i.3] as a virtuous example of support to achieve data interoperability. This point paves the way to adopting the SAREF methodology to build data repositories and to making them compliant with the SReq [i.3]. The second one concerns the structure of the SAREF methodology, i.e. a set of Technical Specifications containing the description of each element and examples of concrete specifications. Their quality enables independent developers to develop conformant implementations. As part of the specifications, terminology, concepts and mechanisms used are clearly specified. Clause 5.2 provides a description about the impact of the SAREF methodology, concerning its current level of compliance with the EU Data Act [i.2], if it is used as it is. Instead, clause 5.3 describes a set of action that should be put in place to enhance the compliance level of the SAREF methodology to make it fully compliant with the EU Data Act [i.2] and EU SReq [i.3].
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5.2 Use of SAREF to fulfil the EU Data Act and the SReq
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The content of the present clause refers to the version of SAREF published at the date in which the present document is written. Any subsequent updates of SAREF may affect the validity of the content provided below. ETSI ETSI TR 104 410 V1.1.1 (2025-10) 12 The SAREF methodology is described in ETSI EN 303 760 [i.5] where there are provided the good practices about how the SAREF methodology can be used to grant semantic interoperability for IoT smart applications in a set of high-level outcome-focused provisions. Through the methodology described within ETSI EN 303 760 [i.5], it is possible to support all parties involved in the development and manufacturing of IoT smart applications and products with guidance on making them interoperable in compliance to the SAREF framework. The provisions give organizations and companies the flexibility to innovate and implement SAREF-compliant semantic interoperability solutions appropriate for their products and applications. Indeed, through the adoption of the described methodology, the datasets produced meets completely the following aspects of the SReq [i.3]: • Paragraph 1 (c) of the EU Data Act [i.2], Article 33; • Harmonised standards on Trusted Data Transactions - Part 1: Terminology, concepts and mechanisms; • Harmonised standards on Trusted Data Transactions - Part 2: Trustworthiness requirements; • Technical specification(s) on an implementation framework for semantic assets; • European standard on a quality framework for internal data governance; and partially: • Paragraph 1 (a) of the EU Data Act [i.2], Article 33; • Harmonised standards on Trusted Data Transactions - Part 3: Interoperability requirements. In particular, the SAREF methodology is fully compliant with the accessibility requirement. This enables the creation of datasets that, in turn, will be all compliant with the SReq [i.3]. Indeed, by adopting the SAREF methodology, datasets can be published by using the RDF Turtle language, a machine-readable format recommended by the W3C®. This way, it is possible to understand the structure of the datasets built by using the SAREF methodology in a clear manner. The usage of the SAREF methodology in its current version leaves open some gaps before fulfilling completing the SReq [i.3]. Clause 5.3 provides a list of possible actions to improve the SAREF methodology.
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5.3 Potential improvements
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The present clause provides a set of actions that should be considered to improve the SAREF methodology, and a mention to possible assets that would make the SAREF ecosystem fully compliant with the EU Data Act [i.2] and the SReq [i.3]. Particularly, three feasible actions can be implemented to enhance the fulfilment of SReq [i.3]. The SReq [i.3] explicitly requires reliance on existing communities and well-established specifications, in particular DCAT-AP and some extensions. Therefore, DCAT-AP is intended to serve as the baseline methodology for dataset and catalogue metadata, while SAREF can provide domain-specific semantics enriching DCAT-AP descriptions. First, the SAREF methodology ensures the management of metadata catalogues describing the resource. The vocabulary recommended by the EU SReq is DCAT-AP [i.8] and some existing extensions. Through DCAT-AP, it is possible to generate a DCAT-AP extension or mapping for each dataset built by using the SAREF methodology. This new application profile allows to provide metadata describing such datasets to make them compliant with the SReq [i.3]. Indeed, currently, datasets built by using the SAREF methodology are, on the one hand, equipped with some descriptors coming from the RDF language. But, on the other hand, each dataset is not associated with a datasheet providing all the necessary information required by the SReq [i.3] (e.g. data quality descriptors). To satisfy this requirement, it is necessary to integrate the management of DCAT-AP extensions into the SAREF methodology. This way, the data structures, data formats, vocabularies, classification schemes, taxonomies and code lists, will be described in a publicly available and consistent manner with other Data Spaces to allowing the publication of SAREF-based datasets within the Common European Data Spaces catalogue and ensuring cross-domain interoperability. Second, to provide a SAREF-based query endpoint. The ontologies instantiating the SAREF methodology are available for download through the dedicated portal. However, it is still missing an endpoint to query datasets built by using the SAREF methodology (i.e. instantiating the SAREF ontologies) with the aim of extracting knowledge about their structures and contents. ETSI ETSI TR 104 410 V1.1.1 (2025-10) 13 Third, to implement and deploy a SAREF-compliant web server. The SAREF ecosystem comes with a collection of synthetic examples showing how the ontologies instantiating the SAREF methodology can be used. However, the type of scenarios specified in the SReq [i.3] is not addressed since, currently, the SAREF methodology does not include an accompanying web server enabling the mentioned type of access. Currently, even SAREF is available for download through its website, it is not equipped with a facility allowing the access to the structured data produced by using SAREF. This issue is going to be addressed through the adoption of the ETSI IoT Ontology Web Server [i.9], [i.10], [i.11].
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6 NGSI-LD
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6.1 Introduction
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ETSI TR 104 409 [i.1] provides an analysis about which components of NGSI-LD fulfils the EU Data Act [i.2], with particular reference to the Article 33 and the EU Standardisation Request [i.3]. NGSI-LD [i.6] is information model and API for publishing, querying and subscribing to context information. It enables structured information sharing across multiple domains like smart cities, smart industries, and digital twins. The NGSI-LD information model represents Context Information as entities that have properties and relationships to other entities. It is derived from property graphs, with semantics formally defined on the basis of RDF and the semantic web framework. There have been two main aspects making NGSI-LD aligned to the EU Data Act [i.2]. The first one is that with NGSI-LD it is possible to describes both data points and datasets with a set of metadata making this information accessible. The possibility of describing datasets put NGSI-LD at the same semantic level of DCAT by making NGSI-LD compliant with the SReq [i.3]. The second one is how the accessibility requirement is satisfied by the NGSI-LD standard. The specifications provide a complete documentation concerning the accessing mechanisms to all the data stored by using such a standard. NGSI-LD comes also with a set of open-source implementations of web service that can be used to access data collections stored by using the NGSI-LD format. Clause 6.2 provides a description about the impact of NGSI-LD, concerning its current level of compliance with the EU Data Act [i.2], if it is used as it is. Instead, clause 6.3 describes a set of action that should be put in place to enhance the compliance level of NGSI-LD to make it fully compliant with the EU Data Act [i.2] and EU SReq [i.3].
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6.2 Use of NGSI-LD to fulfil the EU Data Act and the SReq
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The content of this clause refers to the version of NGSI-LD published at the date in which the present document is written. Any subsequent updates of NGSI-LD may affect the validity of the content provided below. The NGSI-LD specifications are described in [i.6] where there are provided the good practices about how NGSI-LD can be used to grant semantic interoperability for IoT smart applications in a set of high-level outcome-focused provisions. Through the specifications described in [i.6], it is possible to support all parties involved in the development and manufacturing of IoT smart applications and products with guidance on making them. The provisions give organizations and companies the flexibility to innovate and implement NGSI-LD compliant semantic interoperability solutions appropriate for their products and applications. Indeed, through the adoption of the described methodology, the datasets produced meets completely the following aspects of the SReq [i.3]: • Paragraph 1 (c) of the EU Data Act [i.2], Article 33; • Paragraph 3 and Paragraph 8 of the EU Data Act [i.2], Article 33; • Harmonised standards on Trusted Data Transactions - Part 2: Trustworthiness requirements; • Technical specification(s) on a data catalogue implementation framework; and partially: • Paragraph 1 (a) of the EU Data Act [i.2], Article 33; • Harmonised standards on Trusted Data Transactions - Part 1: Terminology, concepts and mechanisms; • Harmonised standards on Trusted Data Transactions - Part 3: Interoperability requirements; ETSI ETSI TR 104 410 V1.1.1 (2025-10) 14 • Technical specification(s) on an implementation framework for semantic assets; • European standard on a quality framework for internal data governance. The usage of NGSI-LD in its current version leaves open same gaps before fulfilling completing the SReq [i.3]. Clause 6.3 provides a list of possible actions to improve NGSI-LD. A key development in this area is ETSI GR CIM 048 [i.7], which provides a detailed mapping between NGSI-LD and DCAT-AP. This mapping demonstrates how NGSI-LD annotations at the entity level can be systematically expressed in DCAT-AP compliant metadata records, thereby bridging dataset semantics with the catalogue-level requirements mandated by the SReq [i.3] ensuring discoverability.
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6.3 Potential improvements
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This Clause provides a set of actions that should be considered to improve NGSI-LD, and a mention to possible assets that would make NGSI-LD fully compliant with the EU Data Act [i.2] and the SReq [i.3]. In the previous clause, it has been mentioned that NGSI-LD satisfies the accessibility requirement by including information about its content, use restrictions, and licences in a machine-readable format, to allow the recipient to find, access and use the data. Concerning the aspects related to information about the data collection methodology, data quality and uncertainty, they are not applicable in the case of NGSI-LD since it is defined as a vocabulary to annotate data that have been previously collected. Hence, such a verification is demanded to the creator of the dataset annotated with the NGSI-LD vocabulary. The NGSI-LD information model consists of a specification. Their quality enables independent developers to develop conformant implementations. As part of the specifications, terminology, concepts and mechanisms used are clearly specified. These can be contributed to define the subset of the SReq [i.3] that can be covered by NGSI-LD. Concerning the specific requirement of terminology specification, the NGSI-LD specifications play the role of drivers to build assets being compliant with the SReq [i.3]. Hence, the appropriate adoption of NGSI-LD specifications would allow the fulfilment of all aspects mentioned by this requirement when constructing new data resources. Finally, also the requirement concerning the evaluation of the maturity and the interoperability of the NGSI-LD specifications cannot be fulfilled by NGSI-LD since the evaluation procedure within the Common European Data Space is still under development. 7 oneM2M, SAREF and NGSI-LD cooperation to fulfil EU Data Act and SReq Previous clauses describe how each single asset fulfil the SReq [i.3]. The present clause provides insights and recommendations about how the interplay between them may mitigate current gaps. First, the interplay between oneM2M and SAREF can satisfy the requests regarding various aspects of semantics that come from the SReq [i.3]. In particular, the aspect of managing data tagging since SAREF provides the methodology to describe the semantic meaning of data, while oneM2M provides the actual data. This is slightly different than just stating that oneM2M allows (multiple) ontologies to be loaded and to perform tagging and queries. Indeed, in the case of such an interplay, this aspect becomes more concrete. Second, the interplay of oneM2M and NGSI-LD could equip oneM2M datasets with a light-semantic index facilitating the discoverability of data managed by oneM2M. ETSI ETSI TR 104 410 V1.1.1 (2025-10) 15
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8 Conclusions
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The present document provides a set of guidelines that may drive future activities on oneM2M, SAREF and NGSI-LD in the context of their usage concerning the implementation of data spaces that intend to be compliant with the EU Data Act [i.2]. For each asset, there are reported which points of the SReq [i.3] are already fulfilled and which actions can be put in place to fill the current gaps. Of course, by considering the nature of each asset and their purpose, not all aspects of the SReq [i.3] can be achieved (e.g. to exploit the outcomes of the ongoing work of CEN/CENELEC on dataset quality aspects, to equip the SAREF methodology with such capability). Finally, the present document provides an analysis of how the interplay between oneM2M, SAREF and NGSI-LD can increase the fulfilment of SReq [i.3]. ETSI ETSI TR 104 410 V1.1.1 (2025-10) 16 Annex A: Change history Date Version Information about changes 23.04.25 V0.0.1 Initial structure of Early Draft including all headlines and a description for each about the intended content of the clause 24.04.25 V0.1.0 Early Draft provided to TC DATA for acceptance as basis for further drafting 29.08.25 V0.2.0 Final Draft V0.2.0 provided for approval 15.09.25 V0.2.1 Incorporation of comments received during the Remote Consensus Phase of V0.2.0 06.10.25 V0.2.2 Incorporation of further comments received ETSI ETSI TR 104 410 V1.1.1 (2025-10) 17 History Document history V1.1.1 October 2025 Publication
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