Missing attributes in the EUCC

[flo0x]

The following three points are missing from the EUCC attestation:

1. Registered Address – The address should be provided as separate attributes (e.g., street, postal code, city, country) rather than as a single field.
2. Contact Address – This attribute is currently missing.
3. Natural Person Role – For natural persons, the role is missing (e.g., "J" in Finland or "CEO" in Germany).

[flo0x]

@Jonas-To @Nieuwlaar We reviewed the EUCC and we couldn't find those 3 blocks ..
In the EWC Version were there ? are that not planned to be supported any more?

[Jonas-To]

Hi @flo0x,

1. registered address in the EUCC is given as an object, with multiple sub-claims in the object for the specific attributes (e.g. street, postal code ect). see section 2.5 in the eucc rulebook, and can also be found with the . notation in the SD-JWT mapping section 3.2.
   Why are you requesting a flat structure in the case of address instead of an object? I could see its use in a selective disclosure case, however, the rulebook takes a stance against using selective disclosure in with the EUCC.

2. We could change digital_contact_point to contact_point and add a visitor address to as an optional attribute? I am uncertain if the authentic sources have a visitor address on file for companies. @astridverhallen @Nieuwlaar Could you check if such an attribute has been requested by a usecase ? The formulation of 2025/25 opens for it with the correspondence address of the company, such as its electronic mail or postal address;
   I think when I wrote the webuild draft, I made an assumption of the registered address also being the postal address, which might be right from a registry perspective, but might not reflect reality.

3. For the information about natural persons, we are limited by the company law definition what we are allowed to disclose:

Article 16b) 
(j)  the first names, surnames and date of birth, or equivalent information when that date is not recorded in the national register, of any persons who either as a body or as members of any such body are authorised by the company to represent it in dealings with third parties and in legal proceedings, and whether those persons may do so alone or are required to act jointly;
(k) where the persons referred to in point (j) are legal persons, the name, the legal form, the EUID or, where the EUID is not applicable, the registration number;

The interpretations I have received on these paragraphs is that this can not be the basis for disclosing role information, as that is a higher granularity.

[flo0x]

@Jonas-To
1 .Understood. So the full_address is a concatenation of the individual address components (street, designator, postal code, etc.).
2. The digital contact points represent the electronic contact details. What we are still missing is a postal/contact address, which may differ from the registered address. It would be very helpful if this could be included as an additional attribute.
3. According to the EU Company Certificate (EUCC) specification, the register "shall ensure that companies disclose at least the following documents and particulars in the register." This defines the minimum mandatory set of attributes.

For our use case, however, we also require the role of the natural person (e.g., CEO, Managing Director, etc).
We definitely need this attribute !!!

Should I setup a call to clarify it `?

[flo0x]

@Jonas-To Attached the decision after the meeting
1.The eucc will be extended with an tow optional objects ( postal_address) and (visitor_address).
2. The role available today (stored in the national register) for the natural persons will be checked by Jonas .
The value will be exactly the one stored in the national register (no mapping or translation)
As input this is required for record purpose according to the Art. 63(4) AMLR.