Family, Item Five

Annex VI of the European Digital Identity Regulation is a list. Eleven lines, no commentary.

“1. Address; 2. Age; 3. Gender; 4. Civil status; 5. Family composition; 6. Nationality or citizenship; 7. Educational qualifications, titles and licences; 8. Professional qualifications, titles and licences; 9. Powers and mandates to represent natural or legal persons; 10. Public permits and licences; 11. For legal persons, financial and company data.”

Item two is age. That is the attribute the previous piece in this series followed — thirty single-use proofs, a passport rescan every ninety days.

Item five is family composition.

What being on the list means

Article 45e says what the list obliges.

“Member States shall ensure, within 24 months of the date of entry into force of the implementing acts referred to in Articles 5a(23) and 5c(6), that, at least for the attributes listed in Annex VI, wherever those attributes rely on authentic sources within the public sector, measures are taken to allow qualified trust service providers of electronic attestations of attributes to verify those attributes by electronic means at the request of the user.”

Stripped down: make family composition machine-checkable against the register that holds it.

That 24-month clock is not a new one. The regulation contains exactly two within 24 months obligations, and both run from the same trigger.

Article 5a: “each Member State shall provide at least one European Digital Identity Wallet within 24 months of the date of entry into force of the implementing acts referred to in paragraph 23 of this Article and in Article 5c(6).” Article 45e, just quoted: “within 24 months of the date of entry into force of the implementing acts referred to in Articles 5a(23) and 5c(6).”

The same two acts. The duty to ship a wallet and the duty to make family composition retrievable expire on the same day. It is the deadline this series has been counting down since its opening piece.

An authentic source, in the wallet framework’s own definition, is a repository held by a public or private body that is “considered to be a primary source of that information or recognised as authentic in accordance with Union law or national law, including administrative practice.”

Birth registers. Population registers. Civil status registers. The paper things.

The credential

The wallet architecture describes the object that carries this.

A parent acting for a child — booking healthcare, accessing an education platform, filing for a benefit — presents a representation attestation. The framework gives it a dedicated slot: “Representation attestations for a natural person issued to a representative have a distinct attestation type.”

Distinct type matters. It does not blend into an age proof. A verifier can tell what kind of thing it is looking at.

And the architecture says where the relationship data comes from:

“For certain use cases (e.g., parent-child relationships), the Attestation Provider of such attestations will be able to retrieve the relevant information from Authentic Sources at the national level.”

So the loop closes. The regulation puts family composition on the list of things registers must answer for; the architecture builds the credential that asks.

Two reversals

The second piece in this series was about a design that tries to reveal as little as possible. The age proof carries one bit and drops the birthdate. The issuer is told to blur the timestamps so two sites cannot compare notes.

The representation attestation reverses that, twice.

It cannot be hidden. The architecture states that the relying party “is always aware that it is interacting with a legal representative or agent,” guaranteed by the fact that the credential presented has that distinct type. In the discussion draft the wording was blunter: it “SHALL NOT be possible to conceal this information.”

That is not a flaw and this piece will not treat it as one. Concealing that you are acting for someone else is fraud. The requirement is sound. What remains is the plain fact that one wallet is being built to hide age and to expose relationship.

It has to be revocable. The age specification says revocation is not required for age verification, because adding it would raise complexity for issuers and verifiers alike. Reasonable — seventeen does not come back. Representation attestations get the opposite rule: they are “either short-lived or revocable,” and where revocable, the parties entitled under applicable law to request revocation must be able to.

The difference is simple. Age does not run backwards. Relationships do.

They also split. Japan’s family law amendment of May 2024 introduced joint parental authority after divorce, with the new rules expected to take effect in mid-2026. When that lands, the question who represents this child has two answers, and the two can disagree. Japan sits outside the EU framework and cannot be used as evidence about European law — but as an illustration of what a relationship is, it is exact. A relationship is not a state. It is a sequence of events.

What goes in the field

Which attributes a credential carries, in what format, with what validity, and what the holder is authorised to do with it — that is settled by a document called a Rulebook.

For representation attestations, two documents say different things.

May 2025, discussion paper, Requirement 1

“The Commission SHALL create a Rulebook for attestations issued to a natural person representing another natural person.”

23 July 2026, ARF Annex 2, requirement RP_01

“Attestation Scheme Providers MAY create one or multiple Attestation Rulebooks for representation attestations issued to a natural person representing another natural person.”

The duty moved from the Commission to scheme providers, and shall became may.

Why is not something these documents disclose, so the two sentences are placed side by side and left there.

The present state is checkable. The EUDI attestation rulebooks catalogue currently holds a person-identification-data rulebook and a blank template. There is no representation rulebook in it.

One clarification, to prevent a wrong reading. The specifications for verifying attributes do exist. Commission Implementing Regulation (EU) 2025/1569 covers that ground, amended on 15 July 2026 by (EU) 2026/1735. What is missing is not the verification machinery. It is the single document that would say what goes inside a representation attestation.

The registers were already there

This design does not create relationship records. It moves them.

The authentic sources the regulation points at are mostly old institutions, and several countries know exactly what such an institution can do.

South Korea rebuilt one. On 3 February 2005 the Constitutional Court found the provisions underpinning the hoju household-head system unconstitutional; from 1 January 2008 the household register was replaced by a family relation register organised around individuals rather than households.

China’s hukou is inherited from a parent at birth — determined by relationship, not by where someone lives. On 22 May 2026 the State Council removed the hukou barrier to enrolling in workplace social insurance, letting migrant workers enrol where they work. The policy language reported around it describes separating a person from their place of household registration.

Two cases, pointing the same way: reducing what relationship registration decides, or detaching something from it.

Two cases are not a world, and this piece will not generalise from them. Nor will it suggest Europe is heading where either of them has been. They are here as precedent, for one reason: the regulation named national registers as the source, and some countries already know what those registers are capable of.

Where the author stands

A disclosure belongs here.

The person writing this has already published an argument that relationship should be a basic unit of society. It is a personal text from May 2026, and among its suggestions to policymakers is this: a small pilot of relationship-unit policy rather than single-household policy, in which two or more people registering together receive tax and housing benefits.

So this is not a neutral observation. What Europe is assembling overlaps in shape with something the author asked for.

The same text also argues that a family is not a family because of blood — that decades of shared meals and shared grief are what make one, and that family is the name of an accumulation rather than the name of a bloodline.

Item five treats it as a value to be looked up.

The same word, defined in two directions. In one, family is made by time. In the other, family composition is made by registration.

This piece will not settle which is right. It notes only that the thing the wallet queries is the second one.

Objections

“A parent booking a child’s appointment — where is the problem?” No problem was claimed. It is a needed function, done on paper today. The question is where that relationship comes from and what gets written down.

“Hiding that you are an agent would be fraud.” Yes. That is why the requirement is not treated here as a defect. What remains is the direction: in one wallet, age is engineered to hide and relationship is engineered to show.

“The rulebook is coming.” Probably. But the adopted text says may, not shall. A document scheme providers may write is a different kind of pending than one the Commission owes.

“Household registers in Korea and China have nothing to do with Europe.” The strongest objection, and answered above: precedent only, no claim that Europe is heading there. The regulation named national registers; those countries know what national registers can do.

“You proposed relationship registration. Why the complaint?” Fair. The answer is that the shape is similar and the safeguards differ. Among the safeguards in that earlier text was a rule against public shaming, written specifically so that a person’s family and children would not suffer by association. The architecture’s requirement is that the verifier be made aware of the representation. Same problem, opposite answer.

The field is blank

Parents act for children every day. Turning that into a credential is not the hard part.

The hard part is what the credential says.

Who counts as family. From what date someone stops counting. Which of two divorced parents takes precedence when both hold a representation attestation. What a person whose relationships are absent from every register can do inside that wallet.

The document that answers those questions is the rulebook. It moved from something the Commission must write to something scheme providers may write, and it has not been written.

Item five is on the list. The field is on the form. What goes in it has not been decided, and the current text leaves that decision unassigned.

The judgement is left to the reader.