The reference standard for the qualified electronic archiving service of the eIDAS V2 Regulation is now known: end of the sterile debate between the NF Z 42 020 Digital Safe and the NF Z 42 013 archiving system?

With this new service, the eIDAS Regulation V2 has imported into French law the previously non-existent legal definition of "electronic archiving" (Art. 3.48 eIDas V2):

“electronic archiving” means a service ensuring the receipt, storage, retrieval and deletion of electronic data and electronic documents in order to ensure their durability and legibility as well as to preserve their integrity, confidentiality and proof of origin throughout the preservation period.

 According to the rule established for all trust services in the eIDAS Regulation, the archiving service has its "qualified" version (Article 45 undecies), which is accompanied by a double presumption:

1. Electronic documents kept in a qualified archiving service “enjoy the presumption of their integrity and of their origin for the duration of the preservation period by the qualified trust service provider”(Art. 45 decies 2). Comparing this provision with Art. 1366 of the French Civil Code, which defines the conditions for the probative value of an electronic document ("An electronic document has the same probative value as a written document on paper, provided that the person from whom it emanates can be duly identified and that it is drawn up and stored in conditions that guarantee its integrity"), it can be inferred that the probative value of an electronic document stored in a qualified electronic archiving service will de facto be presumed.
2. If an archiving service complies with the standards and specifications defined by means of an implementing act, then it is presumed to be qualified. The expected implementing act was published on 16 December 2025 (IMPLEMENTING REGULATION 2025/2532) and it sets as a reference the standard CEN/TS 18170, entitled "Functional requirements for electronic archiving services", accompanied by a number of adaptations (mainly ETSI standards on the cryptographic, security, and interface parts). Thus, only an archiving service that complies with the CEN/TS 18170 standard (plus adaptations) can claim a legal presumption of reliability.

 In France, two types of "competing" services had developed in terms of "archiving with probative value": on the one hand, the "Digital Safe", defined by law (Art. L 103 CPCE) and standardized by AFNOR under the reference NF Z 42-020 (NF 203 certification); on the other hand, the "electronic archiving system", which has no legal definition but has been standardized by AFNOR under the reference NF Z 42-013 (NF 461 certification). 

 Basically, the archiving system and the Digital Safe have the same objectives, namely to store electronic documents in a secure way and maintain their evidentiary value for a certain period of time. The NF Z 42-013 compliant archiving system has more extensive functionalities than the Digital Safe, in particular in terms of document lifecycle management, archiving profile or event logging, but these are not required in all use cases and do not establish any "superiority" of the NF Z 42-013 compliant archiving system over the Digital Safe.

 It is unfortunate that this improbable hierarchy is sometimes debated in dark "expert quarrels", which have no other result than to disrupt a market that does not need it. Let us hope that the arrival of the qualified European archiving service, which will normally push French suppliers to obtain the new certification, will put an end to this.