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Contextualising Organisational Digital Identity

DATUM

August 20, 2026

KATEGORIEN

Guest Contribution: Why Organisational Digital Identities Matter More Than Ever
Daniel Säuberli and Vasily Suvorov, Accelerate

Assessing Organisational Digital Identity in the Context of Switzerland’s Trust Infrastructure

With Postulate 25.4717, “Electronic Identities for Organisations …”, the National Council instructed the Federal Council during the 2025 winter session to examine and report on whether, and in what form, an organisational digital identity could be developed as a complement to Switzerland’s existing public trust infrastructure.

The mandate was explicitly analytical in nature. It does not require the introduction of a new identity system, nor the creation of additional platforms or identification numbers. At its core is the question of whether existing legal and technical foundations can be used to make organisation-related attributes digitally verifiable.

This would address a functional gap in digital legal and business transactions. While natural persons will in future have a standardised means of digital identification through the state-issued E-ID, organisations currently lack a structured and cryptographically verifiable way to bring their legal existence, roles and powers of representation into digital processes without media discontinuities. Today, such checks are still largely document-based, tied to registers or confined to individual portals. As digitalisation progresses, this creates friction, media breaks and uncertainty.

The Postulate therefore does not call for a new system. Rather, it asks whether existing register-based facts can be digitally derived in a form that is machine-readable and verifiable. The central question is whether an organisation’s capacity to act can be represented in digital processes in a legally reliable manner without changing the underlying substantive law.

The assessment does not alter the existing allocation of responsibilities. Authority over registers remains with the competent bodies, and the federal division of responsibilities between the Confederation and the cantons remains unchanged. No new legal institutions are created. The sole purpose of the assessment is to determine whether digital proofs of existing facts can be structured in a functionally appropriate way.

With the E-ID Act and the associated SWIYU trust infrastructure, Switzerland already has a state-backed foundation for digital credentials. The architecture has deliberately been designed as an open framework and allows for electronic credentials beyond the E-ID itself.

An organisational identity fits naturally within this framework, particularly because organisational KYC processes are already required for the design of the trust register and its associated governance. The focus is not on the identity of natural persons, but on the digital representation of organisations within the trust network.

The Postulate therefore calls for an assessment of how this function could be developed further at both national and international level, enabling organisations to act in the digital space as independent legal entities in their own right. It should also examine how their governing bodies, functions, controlled machines and delegated roles can be represented in a machine-readable, cryptographically secured and seamless manner.

The assessment can therefore build on existing infrastructure while being complemented by international concepts, digital public goods and innovation driven by the open market.

Figure: Positioning from the Roundtable presentation in relation to the prevailing approach centred on service platforms, portals and “access management”.

The question is not whether a new system should be created, but whether existing register information can be made usable in a standardised, structured and verifiable form. The cantonal commercial register is the primary legal source for the existence of legal entities, their governing bodies and their authorised signatory arrangements. For digital interactions, a machine-readable derivation of these facts would be appropriate. The underlying legal facts would remain in the register. The digital representation would not replace the register, nor would it create a parallel structure.

International reference models for register-based digital credentials could serve as an extension. Their use would neither create new obligations nor predetermine a specific solution. Switzerland would retain full authority over its registers as well as its legal autonomy.

The purpose of the assessment mandated by the Postulate is therefore not to prescribe a specific solution, but to clarify the structural options for addressing repeatedly expressed requirements concerning the digital management and presentation of organisational facts.

From a legal perspective, the issue is not the creation of new legal frameworks, but the recognition of digital credentials as an admissible form of existing evidence. Particularly relevant are the Swiss Code of Obligations, the Swiss Civil Code, commercial register law, ZertES, the E-ID Act, administrative procedural law and anti-money laundering legislation. A substantive legal framework already exists in all of these areas. The question to be examined is whether digital credentials can complement these frameworks efficiently.

Of particular importance is the representation of roles and powers of representation. In digital business processes, identifying an organisation alone is not sufficient. What matters is linking a specific action to an authorised role within that organisation. This attribution must be traceable, verifiable and, where necessary, revocable.

[Illustration of the organisational and role delegation chain, positioned here following the section on the representation of roles and powers of representation (GLEIF).]

For several years, international reference frameworks have been emerging that make register-based credentials for legal entities interoperably referenceable. These approaches are designed as digital public goods and aim to make national registers discoverable and verifiable within a globally compatible framework. They do not replace national registers, but complement them with a technical reference layer. The potential use of such standards would neither require international treaties nor imply any transfer of sovereign competencies.

GRID representation of the integration of national registers into international reference layers
Positioned here following the section on international interoperability.

As digitalisation progresses, business and administrative processes are undergoing significant transformation. Transactions are becoming increasingly automated, verification processes are shifting upstream, and compliance requirements are being embedded directly into digital workflows. In this context, the unambiguous attribution of an organisation’s authority to act becomes increasingly important. An organisational digital identity could help enable risk-based identification while making verification and compliance processes more efficient.

Figure: Example of a digital business process spanning multiple actors across the private sector and public administration.

In such a model, the state would not act as the operator of commercial processes. Its role would be limited to providing digital public infrastructure, clear recognition criteria and verifiable trust anchors. The development of applications, wallets and additional services could remain market-driven.

Figure: Illustration from the Org e-ID Roundtable, positioned here following the section on digital business processes and international interoperability.

The eCH White Paper on OrgID and digital powers of attorney, coordinated by the Federal Chancellery, addresses a public-administration-oriented use case within existing portals. It provides important insights into the clear separation between legally relevant organisational representation and technical access and authorisation management. The scope of the Postulate goes further by considering cross-organisational digital credentials that can be used independently of a specific context. The two perspectives are therefore complementary.

The assessment should in particular clarify governance questions, potential adaptation requirements for register components, recognition criteria and the appropriate supervisory framework. Compared with comprehensive platform projects, the required infrastructure should be structurally more limited, as neither centralised mass data storage nor new government-operated user interfaces would be required. Nevertheless, the legal and organisational implications need to be assessed carefully.

In summary, the Postulate calls for an objective assessment of whether an organisational digital identity could provide proportionate added value as a complement to Switzerland’s existing trust infrastructure. It creates an opportunity to examine the digital representation of organisational authority to act in a structured manner and to assess its potential on the basis of evidence.

The relevance of organisational digital identity continues to increase as business and administrative processes become increasingly automated. As not only individuals, but also organisations, delegated roles, machines and AI agents begin to act digitally, the reliable and machine-readable verification of identity, authority to represent and mandate becomes a fundamental prerequisite for trusted digital transactions. At the same time, Switzerland is already actively involved in international structures for organisational identification: it holds two seats in the Regulatory Oversight Committee (ROC) of the global LEI system, represented by the Federal Department of Finance (FDF) and the Swiss National Bank (SNB). This provides a strong basis for aligning national developments at an early stage with international standards and interoperability requirements.