Most of these make sense and are definitely blockers for this ever releasing but -
Remove the concept of the Pseudonym Provider and ensure pseudonyms are generated and stored locally without the possibility of linking back to real identities.
Correct me if I'm wrong but this data all has to be signed somewhere right? Like the eID contains cryptographically signed assertions about the user in some standard (JWT?) format.
What use is signing the assertions locally? There would be no way to tell if the citizen actually had any valid id at all. A pseudonym provider is the privacy layer that allows for signing of new tokens after ensuring the validity of the old.
How could you sign an anonymous token using a valid one without it being linked back to the valid one? It seems like impossible constraints.
Am I totally off base here?