Hi George, There should be no reason that it can't be used that way. We chatted about this a bit in person but the current delegate SD-JWT language follows the same as the SD-JWT RFC. I don't think there is any technical constraint beyond the Holder / Delegate Holder being some entity with a key.
I'd prefer to keep the issuer/holder/verifier names, to make the draft more readable for audiences familiar with SD-JWT, but I'll take a pass to make sure it's clear it can be used beyond the wallet model (as that is the intent), and that none of the requirements prevent that. It'd also probably be good to add an implementation considerations section providing a non-wallet example. Cheers Gareth
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