report

My identity belongs to me: self-sovereign identity in a changing regulatory landscape

Published in Privacy by

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In today’s digital society, identity is more than a credential: it is the key that unlocks access to services, rights, and opportunities. This simple truth raises a profound question – who truly controls our identity? The TRUSTED project is built on a clear response: my identity belongs to me. This principle is at the heart of Self-Sovereign Identity (SSI), a model that places individuals – not institutions, platforms, or data infrastructures – at the center of digital identity management.

SSI is not merely a technical architecture. It represents a fundamental shift in how identity is understood, governed and used. Grounded in values such as dignity, autonomy, privacy, and data protection, SSI echoes long-standing European commitments to fundamental rights. It asserts that identity emerges from the person, and that control over personal data is not something granted by systems – it is a natural right.

Yet the infrastructures that mediate identity—digital wallets, authentication frameworks, AI systems, data spaces, and consent mechanisms—play a powerful role in either reinforcing or undermining these rights. This is why TRUSTED approaches SSI as an ethics-driven framework, not just a technological component. Technology is never neutral: it embeds assumptions about power, agency, and accountability. TRUSTED therefore designs identity mechanisms that strengthen, rather than weaken, individuals’ ability to act autonomously and protect their digital footprint.

Putting SSI values into practice

The TRUSTED approach combines SSI with a suite of privacy-preserving technologies to ensure that empowerment is both conceptual and operational. A secure, portable digital identity wallet allows individuals to authenticate, present attributes, and interact with organizations across sectors – health, mobility, volunteering, finance – while maintaining full control over the data they reveal.

Central to this is TRUSTED’s dynamic consent and permissions management system, which allows users to define precisely:

which attributes they share,
for what purpose,
under which conditions,
and for how long.
Consent is not a one-time agreement; it becomes a continuously manageable expression of user agency. Behind the scenes, the system uses robust cryptographic tools, verifiable credentials, and immutable logging to ensure that the expression of consent is technically enforced. Individuals can see, audit, and adjust how their identity is being used, reinforcing both trust and transparency.

This architecture reflects a clear conviction: identity should never be flattened into a set of static fields managed by others; rather, it must remain a dynamic extension of the person, shaped and governed by the individual.

A shifting regulatory landscape

While TRUSTED advances this rights-centred vision, the broader regulatory environment is also evolving. In 2025, the European Commission launched the Digital Omnibus, a set of proposals intended to simplify the GDPR and the AI Act. The objective is to reduce administrative burdens and encourage AI innovation, particularly for small and mid-size enterprises.

However, these reforms introduce nuanced and potentially far-reaching changes. A more flexible interpretation of “personal data,” broader permissions to process sensitive data for AI development, and delayed enforcement of certain high-risk AI obligations are all part of the proposals. These shifts, though presented as technical fine-tuning, have implications for how identity, consent, and data protection are operationalized within the European digital ecosystem.

For example, redefining personal data around what a specific controller can identify may result in inconsistent protections across shared environments, such as data spaces. A dataset treated as non-personal by one participant may still be identifiable by another. Similarly, broader use of legitimate interest for AI training could reduce the reliance on explicit user consent – risking decreased visibility into how individuals’ data is transformed into model contributions, even in distributed or federated settings.

These changes do not necessarily undermine Europe’s commitment to data protection, but they do highlight a tension: as regulatory frameworks adapt to support innovation, the responsibility for protecting individuals may shift increasingly toward system designers and operators.

This is where TRUSTED’s contribution becomes particularly significant.

Staying true to SSI principles in a time of change

In a landscape where digital rules are being recalibrated, TRUSTED demonstrates that it is possible to uphold strong, rights-based standards irrespective of regulatory softening. The project’s design philosophy ensures that technical safeguards remain aligned with the highest thresholds of privacy and data protection, even if legal requirements become more flexible.

Rather than relying solely on formal legal definitions of personal data, TRUSTED anchors its identity framework in architectural principles: minimization, purpose limitation, selective disclosure, and cryptographic enforcement. This means that even if certain processing activities could legally bypass consent under a new legitimate-interest basis, TRUSTED chooses to treat consent as essential, not optional.

Similarly, while AI Act obligations may be delayed or reduced, TRUSTED integrates privacy-preserving federated learning and strict governance from the outset. These ensure that raw data never needs to be centralized and that model updates are processed with safeguards that limit leakage and inference risks. TRUSTED does not depend on regulatory requirements to enforce fairness, transparency, or accountability – it builds them into the infrastructure.

Most importantly, by grounding access to data and learning tasks in verifiable digital identity mechanisms, TRUSTED ensures that identity remains the gatekeeper, not an afterthought. People decide what attributes they present, when, and under which constraints. Organizations receive only what is strictly necessary, and every access is auditable, attributable, and accountable.

This approach ensures that the core SSI principle – my identity belongs to me – survives and remains meaningful, even in an evolving legal framework where the boundaries of personal data or consent might shift.

TRUSTED’s role in the future of digital identity

As European institutions debate the balance between simplification and protection, TRUSTED offers a concrete demonstration of how innovation and rights can reinforce one another. Data spaces and AI ecosystems can thrive without diluting user autonomy; federated learning can expand knowledge without sacrificing confidentiality; and digital identity can enhance access without eroding dignity or sovereignty.

TRUSTED’s message is clear: the future of digital identity must be built around the individual – not around systems, organisations, or regulatory loopholes.

By combining the philosophical clarity of Self-Sovereign Identity with robust technical safeguards, TRUSTED shows that it is possible to navigate regulatory change while maintaining an unwavering commitment to privacy, transparency, and empowerment.

The original version of this article was published on the TrustED project website at this link.

Service involved

Assessment of technology impact on privacy
We help our clients and partners to achieve their business goals while addressing ethics, privacy and cybersecurity concerns in a manner that prevents conflicts, sanctions and loss of money derived by the lack of ethical and legal compliance to national and European applicable regulations. All information technologies must respect human fundamental rights and ensure the rights of people in relation to the protection of their private life, personal data and freedom. The new EU General Data Protection Regulation (GDPR) that replaced the Data Protection Directive in all EU member states on May 2018 introduces many new obligations for companies and a comprehensive set of rights for data subjects, including the right to an effective judicial remedy against a controller or a processor and the right to compensation. Therefore, in addition to being at the receiving end of an enforcement action, data controllers and processors may be subject to court proceedings and have to pay compensation to data subjects for their infringements of the GDPR. Our approach to help our clients to avoid this kind of issues consists of a holistic service composed by the following main components: providing a Data Protection Officer to drive the organization’s legal compliance action; mapping the data processed by the organisation to measure its impact on the ethical principles and legal framework; assessing the cybersecurity mechanisms used by the organisation technologies; conducting an impact assessment for all data processing mechanisms identifying ethical, legal and security risks; making recommendations for the implementation of the organisational and technical means to be compliant with the legal framework while ensuring data confidentiality (preserving authorized restrictions on information access and disclosure, including personal privacy and proprietary information protection), integrity (assurance that data is not modified or deleted in an unauthorized and undetected manner), availability (ensuring there’s timely and reliable access to and use of information) and accountability (supporting non‐repudiation, deterrence, fault isolation, intrusion detection and prevention, and after‐action recovery and legal action).
Ethics assessment of technology
We help our clients and partners in the process of critical analysis to examine the effects that the introduction and use of a technology may have on human rights, society, and the environment. This is a complex process that requires a systematic view and consideration of how technology might affect people and society at large in the short and long term. The ethical impact of technology is therefore crucial when developing and deploying new technologies, in order to mitigate the negative effects and maximise the benefits, and to enable developers, organisations and policy makers to make informed decisions. In this assessment, we assist our clients and partners to consider all relevant factors; there are several methodologies and approaches used to assess the ethical impact of technologies, including:
  • Privacy impact analysis: this type of analysis assesses the effects of technology on the privacy of individuals and their personal information. It considers the risks of monitoring and tracking, the consequences of possible data breaches and the security measures needed to protect users' privacy.
  • Social impact assessment: this type of analysis evaluates the effects of technology on society and the economy in general, considering impacts on unemployment, social equality, access to education and health, quality of life and environmental sustainability.
  • Ethical impact assessment: This type of analysis assesses the effects of technology on society's morals and values, considering impacts on social justice, accountability, transparency, human dignity and individual freedom.
  • Life cycle analysis: This type of analysis assesses the environmental impacts of technology throughout its life cycle, from production to use and end of life.
Ethical impact assessment of technologies therefore requires a multidisciplinary evaluation involving technology experts, ethics experts, legal experts, environmental experts and other stakeholders.
Social acceptance of technologies assessment
Connected, disruptive technologies permeate all aspects of our daily lives and pose challenges to the real foundation of human rights, such as the right to privacy or the freedom of speech. One could say that human values such as trust, accountability, and dignity are mutually influenced by the social acceptance of technologies. We support our clients to conceive a novel way of aligning the thus-far divergent concepts of sustainability, ethics impact, and technological innovation. By combining these three concepts, we respond to the need of a socially responsible innovation ecosystem by developing a tailored methodology for assessing users’/citizens’ social acceptance of technologies, a fundamental driver for technology market adoption. Our social acceptance framework includes six fundamental dimensions over which social acceptability (i.e. perception, motivation, trust, awareness, capacity enabling, and accountability) is measured and assessed through a two-step approach based on an online Sentiment Analysis (SA) – to create structured and actionable knowledge from the web – and the engagement of our client’s stakeholders (e.g. relevant target groups, associations of citizens, domain operators, decision makers, etc.) for the technology co-creation and communication regarding its social acceptance.