EUAlternatives
    Regulation

    The EU Digital Identity Wallet: What It Is, and Why It Matters for Your Product

    EU Alternatives Team4 April 202612 min read

    On 20 May 2024, EU Regulation 2024/1183 entered into force. Often referred to as "eIDAS 2.0", this regulation amends the original 2014 eIDAS framework and introduces a new requirement: every EU member state must provide at least one European Digital Identity Wallet (EUDI Wallet) to its citizens and residents by 31 December 2026.

    This is not a proposal or a consultation. The regulation is adopted, published in the Official Journal, and the implementation deadlines are running.

    This article covers what the regulation requires, what the wallet does, who needs to accept it, and what product teams should be aware of.

    What the Regulation Requires

    The legislative process for eIDAS 2.0 began in June 2021 when the European Commission tabled its proposal. After trilogue negotiations, the European Parliament approved the text in March 2024, and the Council of the EU formally adopted it in April 2024. The regulation entered into force on 20 May 2024.

    The key deadlines established by the regulation and its implementing acts are:

    • 20 May 2024: Regulation entered into force
    • November 2024: Initial implementing acts due from member states
    • May 2025: Updated implementing acts due
    • 31 December 2026: Every member state must offer at least one EUDI Wallet. All public and semi-public organisations (government agencies, municipalities, public hospitals, public education institutions) must accept the wallet
    • 31 December 2027: All relying parties, including private-sector organisations that require identity verification, must accept the wallet

    The Commission has already adopted over 20 implementing regulations covering protocols and interfaces (CIR 2024/2982), wallet certification (CIR 2024/2981), person identification data and electronic attestations of attributes (CIR 2024/2977), security breach handling (CIR 2025/847), relying party registration (CIR 2025/848), and cross-border identity matching (CIR 2025/846), among others.

    What the EUDI Wallet Is

    The EUDI Wallet is a mobile application, provided or approved by a member state government, that allows citizens to:

    1. Store verified identity data (known as Person Identification Data, or PID), issued by the member state
    2. Store electronic attestations of attributes (EAAs), such as a driving licence, a university diploma, a professional qualification, or proof of address
    3. Present this data selectively to relying parties, both online and in-person, with the user's explicit consent

    The wallet is designed around user control. The user decides what to share, with whom, and when. The technical architecture supports selective disclosure, meaning a user can prove they are over 18 without revealing their date of birth, or confirm a professional qualification without sharing their home address.

    Use of the wallet is voluntary for citizens. No one is required to have one. But member states are required to make one available, and regulated entities are required to accept it.

    The Architecture

    The European Commission has published a detailed Architecture and Reference Framework (ARF), now at version 2.6, which defines the technical structure of the wallet ecosystem. The key roles are:

    • Users: Citizens or residents who hold and use the wallet
    • PID Providers: Member state authorities that issue person identification data
    • Attestation Providers: Entities that issue qualified or non-qualified electronic attestations of attributes (for example, a university issuing a diploma attestation)
    • Relying Parties: Organisations that verify and consume attestations presented by users
    • Wallet Providers: Entities that develop and maintain the wallet application, operating under member state oversight

    The ARF defines the data models, attestation formats, presentation protocols (both remote and proximity-based), trust mechanisms, and certification requirements. All wallet solutions must be certified according to the scheme defined in CIR 2024/2981 before they can be offered to citizens.

    What Has Been Tested

    Six Large-Scale Pilot (LSP) projects have been testing the EUDI Wallet in real-world scenarios. Four have concluded their work, and two new pilots (APTITUDE and WE BUILD Consortium) began in 2025. Together, these pilots involve approximately 550 private companies and public authorities from 26 member states, plus Norway, Iceland, and Ukraine.

    The use cases tested include:

    • Banking and payments: Strong customer authentication, KYC processes, and B2B/B2G transactions
    • Digital travel credentials: Digital versions of passports and travel documents
    • Mobile vehicle registration certificates: Storing and presenting vehicle documentation
    • Tickets and check-in: Public transport, hotel check-in, and event access
    • Business processes: Streamlining B2B interactions with verified company credentials

    The POTENTIAL pilot, which concluded in September 2025, confirmed that cross-border wallet interoperability is technically feasible, but stressed the need for consistent application of common standards across member states.

    Who Must Accept the Wallet

    The regulation distinguishes between two phases of mandatory acceptance:

    By 31 December 2026

    All public and semi-public organisations must accept the EUDI Wallet. This includes government agencies, municipalities, public hospitals, and public education institutions. If your product serves public-sector clients in the EU, this deadline is directly relevant.

    By 31 December 2027

    All relying parties must accept the wallet. This broadly covers any organisation that requires personal information from users for identity verification purposes. Industries explicitly mentioned in the regulation and implementing acts include:

    • Banking and financial services
    • Telecommunications
    • Healthcare
    • Transport

    If your product involves user registration, age verification, identity checks, or KYC processes, and you operate in the EU, you will likely need to accept the EUDI Wallet.

    What This Means for Product Teams

    If you are a relying party

    You will need to register as a relying party under the framework defined in CIR 2025/848. This involves:

    1. Registering with the appropriate national authority
    2. Implementing the protocols and interfaces defined in CIR 2024/2982 to accept wallet presentations
    3. Specifying exactly which attestations and attributes you need (the regulation requires you to request only data that is necessary for the specific service)
    4. Supporting both remote and proximity-based presentation flows, depending on your use case

    If you issue credentials or attestations

    If your product or organisation issues documents that users might want to store in their wallet (diplomas, licences, certifications, membership cards), you may want to become an Attestation Provider. This means issuing qualified or non-qualified electronic attestations of attributes in the formats defined by the ARF.

    If you build identity or authentication services

    The EUDI Wallet introduces a standardised, government-backed identity layer across all 27 member states. This affects existing identity verification services, single sign-on providers, and authentication platforms. The wallet supports a level of assurance that is tied to government-issued PID, which may complement or compete with existing identity solutions.

    What This Does Not Cover

    This article is based on the adopted regulation (EU 2024/1183), the published implementing regulations, and the Architecture and Reference Framework (ARF v2.6). Some aspects are still being finalised:

    • National implementation details vary by member state, and not all have published their transposition plans
    • The full certification process for wallet solutions is defined but operational experience is limited
    • Pricing and fee structures for attestation issuance and verification are not standardised at the EU level
    • The exact scope of "relying party" obligations for smaller businesses is still being clarified through national transposition

    Key Resources

    For product teams that need to go deeper, the primary sources are:

    • The regulation itself: EU Regulation 2024/1183, published in the Official Journal
    • Architecture and Reference Framework: Available at eudi.dev, maintained by the European Commission
    • Implementing regulations: Published in the Official Journal, covering protocols (CIR 2024/2982), certification (CIR 2024/2981), PID and EAA specifications (CIR 2024/2977), and relying party registration (CIR 2025/848)
    • Large-Scale Pilot results: Published by the individual consortia, including POTENTIAL, NOBID, DC4EU, EWC, and the newer APTITUDE and WE BUILD pilots

    The Bottom Line

    The EUDI Wallet is not a concept or a pilot. It is backed by adopted EU law with binding deadlines. By the end of 2026, every member state must offer a wallet. By the end of 2027, regulated private-sector organisations must accept it.

    For European product teams, the practical question is not whether this will happen, but whether your product is ready for it. The regulation, the implementing acts, and the technical specifications are all published and available. The time to start reading them is now.