Attestation Rulebook for attestations of type Company Information

Category: non-qualified EAA

• Author(s):
  • [Ana Delmas, DFO]
  • [Florin Coptil, Robert Bosch GmbH]
• Previous Authors *
• Reviewer(s):
  • [Dominic Hurni, SBB]
  • [Ricky Lamberty, Robert Bosch GmbH]
• Contact:
  • Florin Coptil*
• Feedback:

Written against: ARF version 3.0.0, WE BUILD template version 1.0 (generic)

Feedback: GitHub issues

Table of contents

• 1 Introduction
  • 1.1 Document scope and purpose
  • 1.2 Document structure
  • 1.3 Key words
  • 1.4 Terminology
• 2 Compliance
  • 2.1 Compliance statement
  • 2.2 Regulatory basis
  • 2.3 Traceability
• 3 Attestation attributes
  • 3.1 Introduction
  • 3.2 Mandatory attributes
  • 3.3 Optional attributes
  • 3.4 Conditional attributes
• 4 Metadata
  • 4.1 Mandatory metadata
  • 4.2 Optional metadata
  • 4.3 Conditional metadata
  • 4.4 Code lists
  • 4.5 Integrity rules
• 5 Formats
  • 5.1 SD-JWT VC-based encoding
  • 5.2 ISO/IEC 18013-5-compliant encoding
  • 5.3 W3C Verifiable Credentials Data Model-based encoding
• 6 Protocols
  • 6.1 Issuance
  • 6.2 Presentation
• 7 Issuance
  • 7.1 Binding
  • 7.2 Issuance Policy
  • 7.3 Lifecycle management
  • 7.4 Embedded disclosure policy
• 8 Revocation
• 9 Presentation
  • 9.1 Presentation Policy
  • 9.2 Presentation modes
  • 9.3 Transactional data
• 10 Trust Framework
• 11 References

1 Introduction

This attestation addresses the following question:

What additional company information is available that is not publicly accessible can be atteested by the company or by a QTSP provider?

The Company Information (CompanyInfo) Attestation describes additional company-level information which is not part of the EUCC core identity dataset. The attestation enables structured exchange of business profile attributes for use in KYS (Know Your Supplier), KYC (Know Your Customer), supplier onboarding, and risk assessment processes.

1.1 Document scope and purpose

The Company Information (CompanyInfo) Attestation describes additional company-level information which is not part of the EUCC core identity dataset. The attestation enables structured exchange of business profile attributes for use in KYS (Know Your Supplier), KYC (Know Your Customer), supplier onboarding, and risk assessment processes.

This attestation complements the EU Company Certificate (EUCC) by providing additional non-core identity attributes, in particular company size indicators and financial scale. It is intended for use by legal entities operating within the EU single market and by relying parties performing business due diligence.

Design Decisions

This CompanyInfo Attestation Rulebook is based on:

• EU Company Certificate (EUCC) framework as the foundational legal identity layer
• Standard financial reporting taxonomies (IFRS, GAAP) for structured financial data exchange
• XBRL-inspired fact-based financial reporting structure
• ISO 4217 for currency codes
• ISO 8601 for date formatting
• Submission Regulation – Commission on Implementing Regulation (EU) [number] on the formats for submitting beneficial ownership information.

1.2 Document structure

This Rulebook follows the generic WE BUILD attestation rulebook template. Chapter 2 states how it complies with the ARF and the applicable Regulations. Chapters 3 and 4 define the attributes and metadata in an encoding-independent manner. Chapter 5 states the formats in which this attestation is issued. Chapters 6 to 9 cover protocols, issuance, revocation and presentation. Chapter 10 sets out the trust framework, and chapter 11 lists references.

1.3 Key words

This document uses the capitalised key words 'SHALL', 'SHOULD' and 'MAY' as specified in [RFC 2119], to indicate requirements, recommendations and options.

In addition, 'must' (non-capitalised) indicates an external constraint, a requirement not mandated by this document but by an external document. The word 'can' indicates a capability. Other words such as 'will', 'is' and 'are' are statements of fact.

1.4 Terminology

Additional terminology specific to this attestation:

2 Compliance

2.1 Compliance statement

This Rulebook complies with the applicable requirements of Topic 12, Attestation Rulebooks, in Annex 2 of the Architecture and Reference Framework, version 3.0.0. It uses the terminology of Annex 1 of the ARF.

2.2 Regulatory basis

This attestation is not a qualified electronic attestation of attributes. The data described in Annex V points b, c and e of Regulation (EU) 2024/1183 is addressed as required by EW-DM-12-018 and as recommended by EW-DM-12-020 and EW-DM-12-022. Where a recommendation is not followed, the reason is stated below.

Where the attestation is issued as a qualified electronic attestation of attributes, the trust model of chapter 10 applies in its qualified form and the legal category recorded in section 4.1 changes accordingly.

2.3 Traceability

Every applicable requirement mapped to the section that satisfies it. Requirements marked not applicable carry a stated reason.

3 Attestation attributes

The CompanyInfo Attestation is designed to provide a standardized, verifiable representation of a legal entity's business profile attributes, including workforce size and structured financial reporting data. This attestation complements the EUCC by providing additional non-core identity attributes required for KYS, KYC, supplier onboarding, and risk assessment processes.

Attributes are defined here in an encoding-independent manner (EW-DM-12-007). The encoding of each attribute is given in chapter 5.

3.1 Introduction

Data Model:

The attestation structure is defined as a structured object with a nested array of financial facts:

CompanyInfo
├─ legal_entity (M)
│   ├─ legal_person  (M)
│   │   ├─ legal_person_name (tstr) (M)
│   │   ├─ legal_form_type (tstr) (M)
│   ├─ identifier  (M)                          // At least one identifier required
│   │   ├─ euid (str) (O)                       // European Unique Identifier
│   │   ├─ lei (str) (O)                        // Legal Entity Identifier per ISO 17442
│   │   ├─ tax (str) (O)                        // National tax or registration number    
│   │   ├─ gln (str) (O)                        // Global Location Number for legal entities, GS1 identifier
│   │   ├─ duns (str) (O)                       // Data Universal Numbering System, Dun & Bradstreet identifier
│   │   ├─ eori (str) (O)                       // Economic Operators Registration and Identification number, EU customs identifier
│   │   ├─ bpnl (str) (O)                       // Business Partner Number Legal entity, Catena-X identifier per ICD 0243
│   │   ├─ siren (str) (O)                      // Système d'Identification du Répertoire des ENtreprises, French company identifier
├─ number_of_employees  (String) (M)            // ex. less than 5, 52, 100 -> string   
├─ trade_alias [tstr] (O)                       // optional attributes 
├─ previous_legal_name [tstr] (O)     
└─ financial_statements (O)                     //optional 
    ├─ taxonomy (tstr) (M)
    └─ facts [1..n]
        ├─ id (tstr) (M)
        ├─ concept(tstr) (M) 
        ├─ value (number) (M)
        ├─ unit (tstr) (M)
        ├─ period_start (date) (M)
        └─ period_end((date) (M)

Note: M - mandatory / O - optional.

Explanation: The Legal_Entity object SHALL appear exactly once and contains:

• Legal_Person, the official legal name and legal form of the entity issuing the attestation.
• Identifier, the EUID (mandatory) and optionally LEI and/or tax registration number.
• number_of_employees is mandatory top-level attributes.
• trade_alias and previous_legal_name are optional and may contain zero or more text values.
• financial_statements is a optional nested object containing the reporting taxonomy and at least one financial fact.
• Each Fact in the facts array is a self-contained reported financial data point with its own concept, value, unit, and reporting period.

Attestation Classification:

This attestation type MAY be classified as:

• "EAA" self-issued by the legal entity as part of its disclosures.
• "QEAA" issued by a Qualified Trust Service Provider (QTSP) or authorized competent body that can independently attest the company information (e.g., based on official company register data or audited financial statements).

3.2 Mandatory attributes

3.2.1 CompanyInfo Top-Level Attributes

3.3 Optional attributes

LegalPersonIdentifier Optional Attributes

Main Object

financial_statements Optional Attributes

3.4 Conditional attributes

No conditional attributes are defined for this attestation type. All attributes are either mandatory or optional as specified above.

4 Metadata

Metadata describes the attestation rather than its subject.

4.1 Mandatory metadata

Legal category. This Rulebook retains the attestation_legal_category attribute. Section 4.1 of the generic template replaces it with the category attribute of [ETSI TS 119 472-1], whose value for this category is eaa:eu:non-qualified. EW-DM-12-029, legacy ARB_25, of ARF version 3.0.0 is a SHALL that still requires attestation_legal_category, so the template and the ARF disagree. The attribute is left as written and the deviation is recorded for the rulebook quality assurance group.

4.2 Optional metadata

4.3 Conditional metadata

No conditional metadata elements are defined for this attestation type.

4.4 Code lists

4.4.1 Currency Codes

The unit attribute within each Fact object, when representing a monetary value, SHALL follow ISO 4217 currency codes.

No standardized EU value lists apply to employee_number or trade_alias.

4.4.2 Financial Taxonomy Codes

The taxonomy attribute SHOULD use one of the following standardized values:

4.4.3 Concept Codes

The concept attribute SHOULD use one of the following standardized values:

4.4.4 Financial Fact Concept Codes

The concept attribute within each Fact object SHALL use one of the following standardized values:

a. Income Statement (P&L)

b. Balance Sheet

c. Cash Flow Statement

d. Financial Ratios / KPIs

4.4.5 Fiscal Year Format

Fiscal year, as referenced in the period_start and period_end attributes, SHALL follow the Gregorian calendar year format (YYYY) for year identification, with full ISO 8601 date representation (YYYY-MM-DD) for period boundaries.

4.5 Integrity rules

The following integrity rules SHALL be enforced:

• Legal_Entity SHALL appear exactly once and SHALL contain legal_person_name, legal_form_type, and at least one identifiers.
• employee_number SHALL be a non-negative integer.
• financial_statements SHALL contain at least one Fact in the facts array.
• Each Fact SHALL have a value that is a non-negative numeric value where applicable (e.g., revenue, total assets).
• If a monetary value is reported, the corresponding unit SHALL be a valid ISO 4217 currency code.
• period_start SHALL be a valid ISO 8601 date (YYYY-MM-DD).
• period_end SHALL be a valid ISO 8601 date (YYYY-MM-DD).
• period_end SHALL be equal to or later than period_start.
• trade_alias MAY contain zero or more text values.
• previous_legal_name MAY contain zero or more text values.
• previous_legal_name SHALL NOT contain the current legal name of the entity.
• Each attribute SHALL appear at most once in the attestation.
• The id field within each Fact SHALL be unique within the facts array of a single attestation.
• taxonomy SHALL be a non-empty string identifying the applicable financial reporting standard.

5 Formats

5.1 SD-JWT VC-based encoding

The CompanyInfo attestation uses the SD-JWT VC format to allow for selective disclosure of company attributes.

Selective Disclosure: Top-level claims (employee_number, trade_alias, previous_legal_name, financial_statements) SHALL be individually selectively disclosable, enabling a legal entity to disclose only the attributes requested by a Relying Party.

The . notation is used to indicate the nesting of attributes.

Verifiable Credential Type (vct): vct: eu.we-build:companyinfo:1

5.1.1 Attribute Encoding Table

Notes:

• MUST: The claim SHALL be selectively disclosable, the holder MAY choose to disclose or withhold this claim when presenting the credential to a Relying Party.
• MUST NOT: The claim SHALL NOT be selectively disclosable, it is always present in plain text in the JWT header/payload and cannot be withheld by the holder, as it is required for credential verification and trust establishment.
• financial_statements facts are marked as MUST disclosable as a unit, individual facts within the array are not independently selectively disclosable in this version.
• iat, exp, and iss follow RFC 7519 standard JWT claim naming conventions.

5.1.2 Status Claim

For SD-JWT VC-compliant Attestations, the attestation MUST include a status claim if the technical validity period is greater than 24 hours. This claim enables Relying Parties to determine if a credential has been revoked via a status list mechanism, as specified in SD-JWT VC.

The status claim SHALL be a JSON object with the following members:

Example:

{
  "status": {
    "type": "status-list",
    "status_list_credential": "https://issuer.example.com/status/companyinfo/2025",
    "status_list_index": 123,
    "status_purpose": "revocation"
  }
}

5.1.3 Example Payload

The following example shows the payload of the attestation in SD-JWT VC format before the encoding into the SD-JWT format.

{
  "vct": "eu.we-build:companyinfo:1",
  "iss": "https://issuer.example.com",
  "iat": "2025-01-15T10:00:00Z",
  "exp": "2026-01-15T10:00:00Z",
  "issuing_entity": "did:example:legal-entity-123",
  "schema_version": "1.0",
 
  "legal_entity": {
    "legal_person": {
      "legal_person_name": "Example GmbH",
      "legal_form_type": "GmbH"
    },
    "identifier": {
      "euid": "DE1212.HRB123456",
      "tax": "DE123456789"
    }
  },
  "number_of_employees": "1250",
  
  "trade_alias": ["BuildCo", "WeBuild Solutions"],
  "previous_legal_name": ["Former Company Name GmbH"],
  
  "financial_statements": {
    "taxonomy": "IFRS",
    "facts": [
      {
        "id": "fact-001",
        "concept": "Revenue",
        "value": 45000000.00,
        "unit": "EUR",
        "period_start": "2024-01-01",
        "period_end": "2024-12-31"
      },
      {
        "id": "fact-002",
        "concept": "NetIncome",
        "value": 3200000.00,
        "unit": "EUR",
        "period_start": "2024-01-01",
        "period_end": "2024-12-31"
      }
    ]
  },
  
  "status": {
    "type": "status-list",
    "status_list_credential": "https://issuer.example.com/status/companyinfo/2025",
    "status_list_index": 123,
    "status_purpose": "revocation"
  }
  "cnf": {
   "jwk": {
     "kty": "EC",
     "crv": "P-256",
     "x": "TCAER19Zvu3OHF4j4W4vfSVoHIP1ILilDls7vCeGemc",
     "y": "ZxjiWWbZMQGHVWKVQ4hbSIirsVfuecCE6t4jT9F2HZQ"
   }
  }
}

Sample payloads are provided under ../data-schemas/sd-jwt/sample-data/company-info-sd-jwt-sample.json

5.2 ISO/IEC 18013-5-compliant encoding

ISO/IEC 18013-5 (also called mdoc) is out of scope for this Rulebook, as offline proximity presentation is not a current requirement for the CompanyInfo attestation.

5.3 W3C Verifiable Credentials Data Model-based encoding

This Rulebook does not define a W3C Verifiable Credentials Data Model encoding for this attestation type.

6 Protocols

6.1 Issuance

This attestation is issued using OpenID for Verifiable Credential Issuance [OpenID4VCI], as profiled by [HAIP].

6.2 Presentation

This attestation is presented using OpenID for Verifiable Presentations [OpenID4VP]. Only remote presentation is in scope, consistent with chapter 5, which records the mdoc encoding as out of scope.

7 Issuance

7.1 Binding

7.2 Issuance Policy

For EAA (Self-Issued / Standard Issuance):

• The issuer (i.e., the legal entity itself) issues the attestation based on the information and supporting documentation available at the time of issuance.
• The issuer is responsible for ensuring that the attested information remains accurate and must immediately revoke the attestation if any change occurs that affects the validity or accuracy of the underlying data.

For QEAA (Qualified Issuance):

• The issuer-either a Qualified Trust Service Provider (QTSP) or another authorized competent body-must issue and verify the attestation exclusively on the basis of authoritative sources, such as official company register data or audited financial statements.
• The issuer is also responsible for maintaining a high level of assurance throughout the attestation's validity period by continuously monitoring the underlying information. If any change affecting the accuracy or validity of the attested data is detected, the issuer must promptly revoke the attestation.

The Issuer SHALL implement the base issuer obligation as defined in the Issuer Obligation specification: https://github.com/webuild-consortium/webuild-attestation-rulebooks-catalog/blob/main/rulebooks/rb-base/verifier-base-verification.md#41-issuer-obligations

7.3 Lifecycle management

The issuer sets the validity period of the attestation and reissues it when the underlying facts change, revoking the superseded attestation as described in chapter 8.

7.4 Embedded disclosure policy

This attestation defines no embedded disclosure policy.

8 Revocation

An attestation SHALL remain valid only while its underlying information is accurate, complete, and legally effective.

Revocation Mechanism

• Token Status List: The issuer must maintain an active IETF Token Status List (aligned with the Attestation Status List mechanism specified by the EU Commission).
• Credential Metadata: The metadata status_list must be populated in every issued CompanyInfo attestation, referencing the status list URI and the credential's specific index.

Authorized Authority: Only the authorized issuer (the QTSP/competent body for QEAA, or the self-issuing legal entity for EAA) may modify the status list entry.

Revocation Triggers & Business Rules

• QEAA Trigger (Automatic): The QTSP/competent body must actively monitor official company register data and audited financial statements. Any detected discrepancy or change in the company registry must automatically trigger revocation of the QEAA.
• EAA Trigger (Manual Obligation): The self-issuing legal entity is under strict obligation to immediately update or revoke its EAA if its available documents, financial thresholds, or ownership structures change.

Relying Party Action: A revoked or suspended attestation must be treated as invalid for credential-validity purposes by all RPs. The business interpretation is determined by the Relying Party's internal compliance policies.

9 Presentation

Base Verification Process

The Relying Party SHALL perform the base attestation verification process as defined in the Base Verification specification: https://github.com/webuild-consortium/webuild-attestation-rulebooks-catalog/blob/main/rulebooks/rb-base/verifier-base-verification.md#42-relying-party-obligations

9.1 Presentation Policy

To verify and validate a received presentation of an attestation of this type, the following steps SHALL be performed:

1. verify the signature over the attestation using a trust anchor obtained as described in chapter 10;
2. verify that the attestation is within its validity period;
3. check revocation status as described in chapter 8, unless the attestation is short-lived, or its remaining lifetime is below the revocation time threshold;
4. verify device binding where section 7.1 records the attestation as device-bound;
5. request only those attributes that are necessary for the stated purpose of the transaction, and, where the trust model for this attestation requires Relying Party registration, only those attributes it is registered and authorised to request.

Obligations specific to this attestation type, carried over from the Relying Party obligations of the previous version of this Rulebook:

When receiving and processing an attestation, the Relying Party SHALL perform the following verification obligations.

9.2 Presentation modes

Remote presentation is in scope. Proximity presentation is not in scope, consistent with chapter 5, which records the mdoc encoding as out of scope.

9.3 Transactional data

This Rulebook defines no transactional data.

10 Trust Framework

The trust anchor is obtained as described in the branch below that corresponds to the legal category under which the attestation was issued.

This chapter specifies the trust anchor mechanisms used by Relying Parties to establish trust in the issuer of an Electronic Attestation of Attributes (EAA) or a Qualified Electronic Attestation of Attributes (QEAA). The corresponding verification procedures are defined in Sections 4.2.2–4.2.4.

Qualified Electronic Attestations of Attributes (QEAAs)

For QEAAs, trust is established through the X.509 Public Key Infrastructure (PKI) and the applicable Trust List of Licensees (TLOL). The issuer's certificate chain, including the intermediate certificate contained in the QEAA header, SHALL be validated up to a trusted root certificate. This validation SHALL be performed using the applicable TLOL, taking into account the trust list state applicable at the time of issuance.

Successful certificate chain validation establishes that:

• the issuer's certificate was recognized within the applicable trust framework;
• the issuer's identity has been validated by the supervisory authority during inclusion in the TLOL; and
• the issuer satisfies the trust requirements applicable to QEAAs.

In addition, the Relying Party MAY apply further authorization checks based on its internal policies, such as maintaining a whitelist of accepted QEAA providers.

Electronic Attestations of Attributes (EAAs)

For EAAs, trust is established through a cryptographic chain anchored in the Electronic Business Wallet Owner Identity Document (EBWOID). The EBWOID SHALL be included in the header of every EAA. During EBWOID issuance, the EBWOID provider verifies that the public key contained in the EBWOID is owned by the Electronic Business Wallet (EBW) owner.

The Relying Party SHALL verify the EBWOID in accordance with the verification procedure defined in this Rulebook. Upon successful verification, the Relying Party obtains:

• assurance that the EBWOID was issued by an authorized provider and is not self-issued;
• the verified identity of the issuer, including its name and EUID (or another globally unique EBW owner identifier); and
• the public key authorized to verify the EAA signature.

Authorization of the issuer is subsequently determined in accordance with the Relying Party's internal policies. Such authorization MAY be based on locally maintained wallet configuration or on trusted jurisdiction- or domain-specific trust list services that identify issuers authorized for a particular type of EAA

Trust anchor location

The attribute or metadata carrying the trust anchor location contains at least the URL at which a machine-readable version can be found or looked up.

11 References