Your family is item five on Europe's list

Annex VI of the European Digital Identity Regulation is a list of eleven items, with 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 was the subject of the previous piece in this series, which followed it through thirty single-use proofs and a passport rescan every ninety days.

Item five is family composition.

What being on the list means

Article 45e sets out what the list requires.

“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.”

In plain terms: family composition has to be checkable by machine against the register that holds it.

That 24-month deadline is a familiar one. The regulation contains exactly two obligations with the words within 24 months, and both are counted from the same starting point.

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, quoted above: “within 24 months of the date of entry into force of the implementing acts referred to in Articles 5a(23) and 5c(6).”

Both refer to the same two implementing acts. So the duty to provide a wallet and the duty to make family composition retrievable run out on the same day. It is the deadline this series has been counting down to since its opening piece.

The wallet framework defines an authentic source as 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.”

That means birth registers, population registers and civil status registers — the paperwork of everyday life.

The credential

The wallet’s architecture describes the credential that will carry this information.

When a parent acts for a child — booking a medical appointment, logging in to a school platform, applying for a benefit — they present what the framework calls a representation attestation. It gets a category of its own: “Representation attestations for a natural person issued to a representative have a distinct attestation type.”

That matters. A representation attestation cannot be mistaken for an age proof, so whoever checks it knows what kind of document they are looking at.

The architecture also says where the information about the relationship 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 two halves fit together. The regulation puts family composition on the list of things national registers must be able to confirm, and the architecture designs the credential that asks them.

Two reversals

The second piece in this series looked at a design that tries to reveal as little as possible. The age proof carries a single yes-or-no answer and leaves out the date of birth. Issuers are even told to blur timestamps, so that two websites cannot compare what they have seen.

The representation attestation does the opposite, in two ways.

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 does not treat it as one. Hiding the fact that you are acting for someone else is fraud, and the rule against it is sound. But it leaves a plain fact standing: the same wallet is being built to hide a person’s age and to reveal their relationships.

It has to be revocable. The age specification says revocation is not required for age verification, because adding it would make things more complex for issuers and verifiers alike. That makes sense: once you have turned eighteen, you cannot be seventeen again. Representation attestations get the opposite rule. They are “either short-lived or revocable,” and where they can be revoked, the people entitled under the applicable law to ask for revocation must be able to do so.

The reason is simple: age only moves forward, but relationships can end.

They can also split in two. In May 2024 Japan amended its family law to allow joint parental authority after divorce, and the new rules are expected to take effect in mid-2026. Once they do, the question of who represents a child can have two answers, and those answers may not agree. Japan is outside the EU framework and cannot be used as evidence about European law. But as an example of what a relationship is, it fits exactly: a relationship is not a fixed status but a series of events.

What goes in the field

Which details a credential carries, in what format, how long it stays valid and what the holder may do with it are all set out in a document called a rulebook.

On 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 responsibility has moved from the Commission to scheme providers, and “shall” has become “may”.

The documents do not say why, so this piece simply sets the two sentences side by side.

What can be checked is where things stand today. The EUDI attestation rulebooks catalogue currently contains a rulebook for person identification data and a blank template. It has no rulebook for representation.

One point, to head off a misreading: the specifications for verifying attributes do exist. Commission Implementing Regulation (EU) 2025/1569 covers them, and it was amended on 15 July 2026 by (EU) 2026/1735. So the machinery for checking is in place. What is missing is the one document that would say what a representation attestation should contain.

The registers were already there

This design does not create records of who is related to whom. It takes the ones that exist and moves them somewhere new.

Most of the authentic sources the regulation points to are old institutions, and several countries know exactly what such an institution can do.

South Korea rebuilt its own. On 3 February 2005 the Constitutional Court found the provisions underpinning the hoju household-head system incompatible with the Constitution. From 1 January 2008 the household register was replaced by a family relations register built around individuals rather than households.

In China, a person’s hukou is inherited from a parent at birth: it depends on who your parents are, not on where you live. On 22 May 2026 the State Council removed the hukou barrier to joining workplace social insurance, allowing migrant workers to enrol where they work. Policy language reported alongside the decision talks about separating a person from their place of household registration.

Both cases point the same way: towards narrowing what a relationship register decides, or cutting something loose from it.

Two cases do not make a rule, and this piece does not generalise from them. Nor does it suggest that Europe is heading where either country has been. They are here as precedents, for one reason: the regulation names national registers as the source, and some countries already know what those registers can do.

Where the author stands

A disclosure is needed here.

The author of this piece has already published an argument that relationships should be a basic unit of society. It is a personal text from May 2026. Among its suggestions for policymakers is a small pilot of policy built around relationships rather than single households, in which two or more people who register together would receive tax and housing benefits.

So this is not a neutral observation. What Europe is putting together is similar in shape to something the author has called for.

The same text also argues that blood is not what makes a family. Decades of shared meals and shared grief are what make one, it says, and “family” is the name for something built up over time, not for a bloodline.

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

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

This piece does not try to decide which is right. It only points out that what the wallet will query is the second.

Objections

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

“Hiding that you are acting as an agent would be fraud.” Agreed, which is why the requirement is not treated here as a flaw. What this piece points to is the contrast: in the same wallet, age is designed to stay hidden and relationships are designed to be shown.

“The rulebook is on its way.” Probably. But the adopted text says may, not shall. A document that scheme providers may write is pending in a different sense from one the Commission is obliged to produce.

“Household registers in Korea and China have nothing to do with Europe.” This is the strongest objection, and it is answered above: they are precedents only, with no claim that Europe is heading the same way. The regulation names national registers as the source, and those countries know what national registers can do.

“You proposed registering relationships yourself. Why complain now?” Fair question. The answer is that the shape is similar but the safeguards are different. One of 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 rule is that the verifier must be made aware of the representation. The problem is the same, and the answer is the opposite.

The field is still blank

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

The hard part is deciding what the credential says.

Who counts as family? From what date does someone stop counting? If two divorced parents each hold a representation attestation, whose comes first? And what can someone whose relationships are not recorded in any register do with the wallet?

The rulebook is the document that would answer these questions. It has gone from something the Commission must write to something scheme providers may write, and it has not been written.

Item five is on the list, and the field is on the form. What goes in it has not been decided, and the current text does not say whose job it is to decide.

The judgement is left to the reader.