Identity Assurance In The Uk: Technical Implementation And Legal Implications Under The Eidas Regulation

The UK Government has been designing a new Electronic Identity Management (eIDM) system that, once rolled out, will take over how citizens authenticate against online public services. This system, Gov.UK Verify, has been promoted as a state-of-the-art privacy-preserving system, tailored to meet the requirements of UK citizens and is the first eIDM interoperability in which the government does not act as an identity provider itself, delegating the provision of identity to competing third parties. According to the recently enacted EU eIDAS Regulation, member states can allow their citizens to transact with foreign services by notifying their national eID scheme. Once a scheme is notified, all other member states are obligated to incorporate it into their electronic identification procedures. The UK Government is contemplating at the moment whether it would be beneficial to notify. This article examines Gov.UK Verify's compliance with the requirements set forth by the Regulation and the impact on privacy and data protection. It then explores potential interoperability issues with other national eID schemes, using the German nPA, an eIDM based on national identity cards, as a reference point. The article highlights areas of attention, should the UK decide to notify Gov. UK Verify. It also contributes to relevant literature of privacy-preserving eID management by offering policy and technical recommendations for compliance with the new Regulation and an evaluation of interoperability under eIDAS between systems of different architecture.