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10-07-2024

Comparing the UK's and EU's Digital ID approaches

By Digidentity

As digital identities become vital across industries, both the UK and the EU are developing frameworks to integrate them securely into daily life. While the UK is just starting to lay the groundwork with new legislation, the EU has already established a comprehensive model. Comparing these approaches illustrates where the UK currently stands and what it can learn from the EU's experience.


UK’s Digital Identity Landscape: Progress and Challenges

The upcoming UK Digital Information and Smart Data Bill (DISD Bill) seeks to modernise its digital identity ecosystem. Announced in the King's Speech, the initiative aims to boost economic efficiency by reducing administrative costs, simplifying transactions, and curbing the rise in identity fraud.

A key feature of the DISD Bill is the introduction of ‘trust marks’ for digital identity providers, which serve as government-backed certifications to enhance transparency and trust. However, in comparison with the EU's established EU eIDAS regulation, the UK's Digital Identity and Attributes Trust Framework (DIATF) - which will underpin the DISD Bill - lacks a strong legal foundation. It takes time to establish consistent standards and build public confidence in any digital identity system. The UK must address concerns around data protection and consent management with stronger regulations to keep pace with the EU's more robust approach.

The UK is prioritising the decentralisation of user data to enhance privacy and control, especially in light of rising online fraud, with Ofcom reporting that 46% of UK adults have been personally drawn in by an online scam. To match the EU’s progress and fully capitalise on digital identities, the UK needs a secure, legally supported framework aligned with international standards.


EU’s Digital Identity Leadership: A Proven Model

EU eIDAS sets a high bar with its secure, standardised framework for digital identities across the EU blocs. Unlike the UK's developing system, EU eIDAS already enables secure cross-border transactions and digital interactions, driving economic growth and integration. EU eIDAS offers lessons for the UK, where efforts are still nascent and fragmented by comparison.

A key strength of EU eIDAS is its comprehensive legal framework, which supports cross-border interoperability and trust among businesses and consumers. While the UK's trust marks will provide some degree of transparency, they do not match the standardised, legally binding requirements of EU eIDAS. We are still awaiting legislation that will put the DIATF on a statutory footing.

By adopting principles similar to EU eIDAS, the UK could not only improve its national digital infrastructure but also facilitate smoother international interactions. To do so, it needs to align more closely with the EU's legal and technical standards, ensuring its digital identity ecosystem offers comparable security, interoperability, and public trust. Strengthening these elements would help the UK compete on a global scale and integrate more effectively with the digital economies of its European counterparts.


Conclusion

While the UK is progressing with its digital identity initiatives, it is still lagging behind the EU's eIDAS framework. Amendments to EU eIDAS made in May this year have widened the gap between the EU and UK even further. Implementing secure digital wallets, like those offered by Digidentity, could help address these challenges by providing reliable, government-backed solutions that comply with regulatory standards. Digidentity's digital wallets can enhance data protection, streamline identity verification, and grow public trust—key elements for advancing the UK’s digital identity ecosystem and fostering economic growth.

You can read more about our Digital IDs here.

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