The needs and day-to-day life of people and companies in Switzerland are changing. Processes within companies and the public sector are increasingly being digitized. Many everyday errands and services can now be processed online, or, in fact, are now only processed online. A trustworthy electronic ID is the best way to effectively advance digital business processes without media disruptions and to develop online transactions and e-government applications. In light of this, being able to offer unique identification in the digital world with an electronic identity is a key element in ensuring the secure progress of digitization in Switzerland. The new e-ID Act creates the legal basis for a state-issued electronic identity and other electronic documents.

Secure digital systems have long been part of Swiss Post’s day-to-day operations: they create the conditions to enable Swiss Post to implement its core competency – transporting sensitive information in a secure and trustworthy way – in its physical core business as well as in the virtual world. Over recent years, Swiss Post has extended its competencies and resources in IT and encryption technology and now provides digital solutions for public authorities as well as business and private customers. SwissSign – a wholly owned subsidiary of Swiss Post, which means it is entirely in the public sector – provides certified identification and authentication solutions under the SwissID brand. SwissID is not just used by private sector companies, but also by 13 cantons, several municipalities, cities and other public authorities. It already has over 4.3 million users.

1.  Ecosystem development

We welcome the fact that the current draft law, i.e. the anticipated infrastructure, foresees a variety of electronic documents and is thereby moving in the direction of an open ecosystem.

We are calling for a rapid and effective approach to set up this open ecosystem.

2. Level playing field for state e-ID and private identity providers

The e-ID is not a means of authentication for logging in to a digital service; it is a digital proof of identity and a digital equivalent to a passport or identity card. We believe that this distinction has not been made clear enough in the e-ID Act, especially since the Confederation has now developed its own login solution for state applications, the AGOV authentication service.

Through AGOV, the planned state e-ID will also be used as a means of identification for the electronic patient record (EPR). Swiss Post believes the planned regulations on AGOV and the electronic patient record should be revised, especially in view of the fact that, under the provisions of the current EPRA, only electronic means of identification from certified issuers can be used to open and use the EPR. There are currently three private certified identification and authentication solutions: SwissID, TrustID and HIN eID. The new e-ID Act will enable the state e-ID to be used as a means of identification for the EPR via AGOV. However, the Confederation – as the future issuer of e-ID – will not be obliged to obtain certification.

We do not believe it is reasonable for the Confederation to be exempt from the obligation to obtain certification, unlike the currently certified issuers of digital identities. This will result in existing identity providers, who have completed expensive certification procedures for the EPR, being treated unequally and their solutions being forced out of the market.

We are calling for the same requirements for access to the EPR to apply to the Confederation when issuing the state e-ID as those covering the certification procedure for existing private identity providers.

3. Other trust-building measures

To strengthen trust in interactions in the digital world, the bill also requires the Confederation to be able to confirm the identity of verifiers (e.g. companies) based on their entry in the trust register. This also enables private customers to determine whether their business partner is who they claim to be when executing digital transactions.

From Swiss Post’s perspective, this is another key element in promoting trust between the actors in the virtual world.

Swiss Post proposes identification of the verifiers in the trust infrastructure’s register. Contrary to the Federal Council’s proposal, we propose governing the issue at legislative level in order to highlight its importance.

It is anticipated that the State will offer a state-issued electronic wallet that will be able to hold the e-ID and other electronic documents. We consider it positive that users will also be able to use other (private) applications to store and present their electronic documents.

For security reasons, we propose transferring the electronic documents only to wallets issued by recognized trust service providers.

Other measures to strengthen trust and security are possible: the European Union’s legislation goes as far as stipulating that an e-ID will be accepted for the EUID Wallet within the scope of eIDAS 2.0 only with a “high” security level.

A higher security level may help the e-ID to establish itself more quickly.