In the course of the planned amendment of the Identity Card Act (Personalausweisgesetz) by the German Federal Government, the Conference of the Independent Data Protection Authorities of the Bund and the Länder (the Conference) has called for reform to take better account of civil and data protection rights. One of the Conference’s main criticisms related to the current plan for the obligatory activation of the online function of electronic identity cards. Such a solution could only be considered lawful if citizens have the right to decide whether electronic identification can be used. The Conference also criticised the allocation of authorisation certificates to service suppliers and the almost unconditional right (to be introduced from 2021) of the police and secret services to access ID photographs through an automated process.