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[Link to GitHub discussion](https://github.com/eu-digital-identity-wallet/eudi-doc-architecture-and-reference-framework/discussions/557)
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## 1. Introduction
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### 1.1 Discussion Paper topic description
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This document is the Discussion Paper for European Digital Identity Cooperation Group regarding
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Topic O - Catalogues for Attestations
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This document is the Discussion Paper for European Digital Identity Cooperation Group
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on topic **O - Catalogues for Attestations**
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The ARF Development Plan [ARF_DevPlan] describes this Topic as follows:
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Requirements need to be defined to implement the catalogue of Attestation Rulebooks
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> Requirements need to be defined to implement the catalogue of Attestation Rulebooks
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and attributes as outlined in ARF 1.4.1 Annex 2, Topics 25 and 26. Specifically,
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interfaces for registering a Rulebook and for searching and requesting rulebooks and
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attribute definitions should be specified.
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Following the *Commission Implementing Regulation (EU) 2025/1569 of 29 July 2025*
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this document discusses **catalogue of attributes** and
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**catalogue of schemes for the attestation of attributes**.
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## 1.2 Key words
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This document is structured as follows:
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- Chapter 2 presents an overview of catalogues of attributes and catalogues of
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attestation Rulebooks as discussed in the current version of the ARF.
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- Chapter 2 introduces catalogue of attributes and catalogue of schemes for the
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attestation of attributes based on the existing legislation and the ARF.
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- Chapter 3 lists the additions and changes that will be made to the ARF
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as a result of discussing this topic with Member States.
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## 2. Existing requirements related to catalogues for Attestations
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## 2. Existing requirements related to catalogues for Attestations and Definitions.
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Article 45e Article 45e of the [European Digital Identity Regulation] specifies that
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> [...] the Commission shall, taking into account relevant international standards,
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for qualified electronic attestations of attributes for the purposes of paragraph
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1 of this Article.
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Topic 12 of ARF 2.2 outlines the high-level requirements (HLR) for Rulebooks that
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define new types of attestations. Among other aspects, it introduces the concept
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of a catalogue to support the management and discovery of these Rulebooks and attributes.
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In line with the foundations laid out in Topic 12, Topics 25 and 26 further elaborate
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on the purpose and structure of the catalogue of Attestation Rulebooks and the catalogue of attributes.
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It is envisioned that Rulebooks can be registered and made available in a publicly
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accessible catalogue. Particularly, Topic 26 specifies that Schema Providers for
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an Attestation Rulebook that is a QEAA or PuB-EAA
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SHOULD register their Rulebooks in the catalogue of Attestation Rulebooks. The Schema
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Provider for an Attestation Rulebook that is a non-qualified EAA MAY also choose
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to register their Rulebooks in the catalogue of Attestation Rulebooks.
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To enhance discoverability and technical integration, existing HLRs state the the catalogue will be made
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publicly available and machine-readable. It may be hosted in full or partially
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by the Commission and can include an e-discovery mechanism or links to external
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catalogues. The infrastructure supporting the catalogue will be designed for high
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availability and will avoid single points of failure, ensuring resilience and reliability.
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Furthermore, it is required that he registration process will be self-service and open,
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requiring no prior approval from the registry. Similarly, the Commission will also
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publicly communicate the existence and maintenance of the catalogue, along with the
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procedures for proposing a new registration, updating existing records, or removing outdated ones.
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All such changes will be subject to versioning, archiving, and logging, ensuring full traceability
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and accountability throughout the lifecycle of each Rulebook. The specifications and
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formats of these catalogues will be provided by TS11 - Specification of Interfaces
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and Formats for the Catalogue of Attestation Rulebooks and Attributes.
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### 2.1 Existing high-level requirements
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It is clarified that the *scheme for the attestation of attributes* is not the
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same as the *Attestation Rulebook*. Particularly:
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-**Scheme for the attestation of attributes** is a machine-readable attestation definition
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-**Attestation Rulebook** is a human readable specification of the scheme for the attestation of attributes
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The *Commission Implementing Regulation (EU) 2025/1569* additionally defines
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the **catalogue of schemes for the attestation of attributes**. The scope of these two catalogues
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is specified in articles 7 and 8 of the implementing regulation. Particularly, with respect
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to the catalogue of attributes the following are defined:
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**Article 7 paragraph 3**
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> Member States shall request the inclusion of attributes listed in Annex VI to Regulation (EU)
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No 910/2014 to the catalogue of attributes wherever those attributes rely on authentic sources for
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the purpose of the verification by qualified trust service providers.
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**Article 7 paragraph 3**
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> In addition, Member States may request the inclusion of attributes not listed in Annex VI to
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the catalogue of attributes wherever those attributes rely on authentic sources within the public sector.
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Private entities that are considered to be a primary source of information or recognised as authentic
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in accordance with Union or national law, including administrative practice, may request the inclusion
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of attributes not listed in Annex VI to the catalogue of attributes wherever the requesting entity is
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responsible for those attributes.
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Similarly, with respect to the catalogue of schemes for the attestation of attributes
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the following are defined:
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**Article 8 paragraph 3**
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> Owners of a scheme for the attestation of attributes may request adding schemes to the catalogue of schemes [...]
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Therefore, the two catalogues are distinct and serve different purposes. The catalogue
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of attributes is limited to attributes that rely on authentic sources within the public
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sector, with its primary objective being the discovery of verification points. Only specific
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type of entities shall be allowed to add or modify an entry in this catalogue. In contrast,
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the catalogue of schemes for the attestation of attributes has a broader scope, as it
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allows any scheme owner to register their attestation scheme.
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The ARF includes high-level requirements (HLR) for these catalogues, which however
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are considered outdated and will be updated. For more details see Section 3 of this
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document
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### 2.1 Catalogues' contents
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Articles 7 and 8 of the *Commission Implementing Regulation (EU) 2025/1569*
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define the minimum parameters that a request to include or modify an entry
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in the catalogues shall contain. Specifically, a request to include or to modify
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an attribute in the catalogue of attributes shall contain at least:
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* identification of the entity making the request
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* where applicable, a reference to Union or national law or administrative practice
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under which the entity making the request is considered to be a primary source of
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information or recognised authentic source.
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* if the request refers to an attribute already existing in the catalogue or is a new attribute
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* a namespace for the identifier of the attributes, the value of which is unique within the catalogue of attributes
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* an identifier of the attribute, unique within the namespace, and the version of the attribute
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* semantic description of the attribute
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* the data type of the attribute
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* the verification point for the attribute at national level or a link to a description
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on how to initiate the verification requests.
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Similarly, a request to include or to modify a scheme in the catalogue of
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schemes for the attestation of attributes shall contain at least:
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* the name of the scheme [...]
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* the name and contact information of the scheme for the attestation of attributes owner
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* the status and version of the scheme
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* a reference to specific laws, standards or guidelines, where the issuance,
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validation, or use of an electronic attestation of attributes within the scope of the scheme is subject to them
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* the format or formats of electronic attestation of attributes within the scope of the scheme;
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* one or more namespaces, attribute identifiers, semantic descriptions and data types of each attribute
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that is part of an electronic attestation of attributes within the scope of the scheme, either by
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reference to an attribute in the catalogue of attributes in Article 7, or an attribute defined
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in an analogue way within the scope of the scheme
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* a description of the trust model and the governance mechanisms applied under the scheme, including the revocation mechanisms;
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* any requirements concerning the providers [...] or the sources of information on which those providers rely
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when issuing electronic attestations of attributes [...]
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* a statement whether electronic attestations of attributes within the scope of the
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scheme are to be issued as qualified electronic attestations of attributes, as
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electronic attestations of attributes issued by or on behalf of a public sector body
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responsible for an authentic source, or as both.
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The contents of both catalogues SHALL be available in both human and machine readable formats.
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**Topic 25**
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## 3 Additions and changes to the ARF
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### 3.1 High-Level Requirements to be added to Annex 2
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The following High-Level Requirement is proposed to be added under Topic 12:
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**ARB_30**
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A Schema Provider for an Attestation Rulebook MAY generate a machine-readable version
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of the attestation schema and register it in the catalogue of schemes for the attestation of attributes.
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The registration SHALL include a reference to the corresponding Attestation Rulebook.
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### 3.2 High-Level Requirements to be changed
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The requirements specified in Topics 25 and 26 shall be removed, as they are considered outdated.
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In addition, the content of these topics shall be updated to reflect the conclusions of
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this discussion paper. Topic 25 shall also clarify that the scope of the catalogue of attributes is
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limited. Consequently, any references to Topic 25 that describe this catalogue as a general-purpose
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catalogue should be revised accordingly.
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A list of the requirements that shall be removed follows:
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**Topic 25**
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|**Index**|**Requirement specification**|
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| CAT_09 | The Commission SHALL make publicly available the existence and maintenance of the Attestation Rulebooks catalogue mentioned in CAT_01, including processes to propose the registration to public and private parties, allowing to register an Attestation Rulebook, and conditions for updating and/or removing Attestation Rulebooks. These processes SHALL include archiving and logging changes of the history of the Attestation Rulebooks catalogue in an appropriate way, including versioning. |
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| CAT_10 | The body registering an Attestation Rulebook SHALL include a unique reference to this body and the way to contact it, or how to find information for doing so. *Notes: - Topic 12 describes an option for Member State-specific (i.e., domestic) Rulebooks, extending a EU-wide Rulebook. - Rulebooks may also be shared between interested parties in an out-of-band manner.*|
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### 2.3 Discussion
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**Question 1**
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What is the relationship between the two catalogues (catalogue of attributes and catalogue of attestations)? Should they exist independently,
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or can they be combined? A note in [CAT_01] states:
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*"[...] The catalogue of attributes does not need to be a separate catalogue, but
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could be combined with the Attestation Rulebooks."*
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Is this note still valid?
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---
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**Question 2**
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What is the relationship between the catalogue of attributes and other registries?
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For example, [ARB_06b] requires that:
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*“For [SD-JWT VC]-compliant attestations, the Schema Provider for the Attestation
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Rulebook SHALL ensure that each claim name is either included in the IANA registry
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for JWT claims, or is a Public Name as defined in [RFC 7519].”*
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Possible interpretations of the role of the catalogue of attributes include:
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* It will serve as an **alternative registry** (e.g., instead of registering with IANA).
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* It will be a **complementary registry** (e.g., registration with both IANA and the catalogue of attributes is required).
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* It will be the **only mandatory registry** (e.g., registration with IANA is optional).
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---
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**Question 3**
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How should attributes with the same semantics and identifier but from different
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namespaces be handled?
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For example, `first_name` may exist in `eu.europa.ec.eudi.pid.1`, `org.iso.18013.5.1.
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mDL`, etc.
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* There should be a separate entry for each identifier–namespace pair, and reuse
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across namespaces should be encouraged.
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---
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**Question 4**
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Do we need machine-readable catalogues?
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Some existing requirements highlight the need for “high availability and avoiding a
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single point of failure.” But in what way could a catalogue be considered a single
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point of failure? Will it be used during issuance or the presentation process?
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* Probably not. The catalogue should serve as an **informational resource**, and
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Wallet Units should **not be required** to interact with it at runtime.
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* A machine-readable catalogue could be very useful for both the Provider and the
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RP, e.g., a very generic Provider can be envisioned where the attestation to be
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issued is configured based on the machine-readable catalogue. Similarly, a very generic
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Wallet could leverage the use of machine-readable catalogue
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---
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**Question 5**
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Is CAT_07 valid as written? Is fully self-service registration without approval a
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desirable feature? What does “self-registration” truly mean in this context? Should
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the process be automated?
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* It is likely that **some manual review and approval** will be necessary.
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---
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**Question 6**
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Is there a need for registry structures, such as hierarchy or grouping? For example,
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IANA supports “groups of registries” and “subregistries.”
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* This might be beneficial—for instance, in cases where **country-specific
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extensions** to a Rulebook are defined. However, it may also introduce **unnecessary
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complexity**.
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***Grouping attestations** could improve usability (similar to IANA), but this
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raises questions: **Who will manage the groups?**
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## 3 Additions and changes to the ARF
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### 3.1 High-Level Requirements to be added to Annex 2
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### 3.2 High-Level Requirements to be changed
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### 3.3 Descriptions to be added to the ARF main document
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The ARF includes in various locations the term `catalogue of published Attestation Rulebooks`
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(e.g., section 3.15). This should be rephrased to `catalogue of schemes for the attestation of attributes`.
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Similarly, Section 5.5 of the ARF has to be re-written and adapted to the definitions set
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