How does eIDAS 2.0 relate to the EU AI Act on identity verification?

eIDAS 2.0 and the EU AI Act are two separate regulatory frameworks, but they overlap directly when AI is used in identity verification. eIDAS 2.0, established by Regulation (EU) 2024/1183 which amends Regulation (EU) 910/2014, sets the rules for trusted digital identity and electronic signatures across Europe. The EU AI Act regulates how artificial intelligence systems are built and deployed. When an organization uses AI to verify someone’s identity, both frameworks apply at the same time.

This matters especially for organizations in finance, healthcare, government, and other regulated sectors, where identity verification is both a legal requirement and a high-stakes process. The sections below address the most important questions organizations are asking about how these two regulations connect.

Which parts of the EU AI Act apply to identity verification systems?

The EU AI Act classifies AI systems used for biometric identification and categorization of natural persons as high-risk. Identity verification systems that use AI for functions such as facial recognition, document scanning, or liveness detection generally fall within this category and are subject to strict requirements before deployment.

One important distinction applies here: biometric verification that solely confirms a person is who they claim to be, a one-to-one match, is carved out of that high-risk category under the Act. Organizations should assess their specific systems carefully, since the classification depends on what the system actually does, not simply on whether it uses biometrics.

For systems that do fall under the high-risk classification, requirements apply across several areas:

• Risk management: Organizations must identify, analyze, and mitigate risks throughout the system’s lifecycle
• Data governance: Training data must be relevant, representative, and free from significant bias
• Technical documentation: Detailed records of how the system works must be maintained and available for regulators
• Transparency: Users must be informed when they are interacting with an AI system, in line with Article 50 of the AI Act
• Human oversight: Mechanisms must be in place for humans to monitor, intervene, or override the system
• Accuracy and robustness: The system must perform consistently and resist errors or manipulation

The EU AI Act applies to AI systems placed on the EU market or used within the EU, regardless of where the provider is based. So even if a third-party vendor supplies the AI component of an identity verification flow, the organization deploying it carries obligations under the Act.

Organizations should also note that the application dates for the high-risk regime have been affected by the Digital Omnibus on AI. The specific dates applicable to a given system depend on its classification and the relevant transitional provisions, and should be verified against current legislative texts before planning compliance timelines.

How do eIDAS 2.0 trust requirements interact with AI Act risk rules?

eIDAS 2.0 requires that identity verification meets specific assurance levels, particularly when issuing or validating credentials tied to the European Digital Identity (EUDI) Wallet. The legal framework governing the EUDI Wallet is managed by the European Commission, which adopts implementing acts containing the binding requirements. EU Member States are responsible for providing or mandating wallet solutions, certifying and notifying them, and supervising actors within their jurisdiction. The EU AI Act adds a layer of requirements on top of this by demanding that any AI system used in the verification process is safe, transparent, and accountable. The two frameworks are complementary.

Under eIDAS 2.0, identity proofing must meet defined assurance levels: low, substantial, or high, depending on the context. Achieving a high assurance level typically involves biometric checks or document verification. Where those processes involve AI systems that fall under the high-risk classification, AI Act obligations are triggered. In practice, this means that meeting eIDAS 2.0 assurance requirements through certain AI-powered verification methods brings an organization into scope of the AI Act’s high-risk rules.

The requirements are broadly aligned in intent. Both frameworks push organizations toward accuracy, reliability, and user protection. Building a compliant eIDAS 2.0 identity verification process using AI means organizations are already working toward many of the same goals the AI Act demands: robust performance, clear documentation, and respect for user rights.

What compliance obligations overlap between the two frameworks?

Several compliance obligations appear in both eIDAS 2.0 and the EU AI Act, which means organizations can address them together. The most significant overlaps involve data protection, transparency, auditability, and accountability.

Here is where the two frameworks align most directly:

1. Data minimization and privacy: Both frameworks require that only necessary personal data is collected and processed. eIDAS 2.0 builds selective disclosure into the EUDI Wallet design; the AI Act requires that training and operational data is managed responsibly.
2. Logging and audit trails: eIDAS 2.0 requires records of identity transactions for trust and legal validity. The AI Act requires technical documentation and logging of AI system behavior for post-market monitoring.
3. Accuracy requirements: eIDAS 2.0 demands reliable identity assurance; the AI Act mandates that high-risk AI systems meet defined accuracy thresholds and remain robust against errors.
4. User rights and transparency: The EUDI Wallet gives users control over what data they share. The AI Act requires that individuals are informed when AI is being used in decisions that affect them.
5. Conformity assessments: Both frameworks require some form of third-party or self-assessment to demonstrate compliance before deployment.

Organizations that map their obligations across both frameworks early will find meaningful efficiencies. A single compliance effort can satisfy requirements in both directions.

Does using an EUDI Wallet reduce AI Act compliance burden?

Using the EUDI Wallet can reduce the frequency and scope of AI-powered identity checks, which in turn can reduce an organization’s exposure to AI Act obligations. When a user presents verified credentials from their EUDI Wallet, the relying party may not need to run a fresh biometric or document check at all, since the identity has already been verified to a high assurance level by a trusted issuer, such as a Person Identification Data issuer designated by the relevant Member State.

This is one of the most practical benefits of the EUDI Wallet for organizations navigating both regulations. If a bank, healthcare provider, or government service can accept a credential from the wallet, the AI Act’s high-risk requirements may not be triggered for that interaction.

However, this does not eliminate AI Act obligations entirely. Organizations that issue credentials to wallets, or that still use AI for initial onboarding before wallet adoption is widespread, remain in scope. The EUDI Wallet shifts where in the process AI is used, but it does not remove the regulation from the equation altogether.

It is also important to recognize that EUDI Wallet availability and maturity will vary across Member States. 24 December 2026 is the legal deadline by which Member States must make notified wallet solutions available and ensure that public-sector online services requiring electronic identification accept them. Practical interoperability and national rollout are expected to develop in phases. The level of maturity of individual national wallets, the progress of certification and notification, and the readiness of relying-party acceptance will differ across countries. Organizations should plan for a phased transition. As wallet adoption grows, organizations may find their reliance on in-house AI verification decreasing, which is a meaningful compliance benefit over time.

For organizations exploring digital identity solutions that are wallet-ready from the start, this is an important design consideration.

Who is responsible for compliance when AI is used in identity verification?

Under the EU AI Act, responsibility falls on both the provider (the company that develops or places the AI system on the market) and the deployer, referred to in the Act as the user responsible for deployment (the organization that uses it in its own products or services). When an organization uses a third-party AI identity verification tool, it is typically acting as a deployer and carries specific obligations of its own, separate from those of the vendor.

As a deployer of a high-risk AI system, an organization must:

• Use the system only for its intended purpose as described by the provider
• Ensure human oversight is in place and that staff are trained to use the system appropriately
• Monitor the system’s performance in its specific context and report serious incidents
• Conduct a fundamental rights impact assessment where required
• Keep records of its use of the system

Under eIDAS 2.0, responsibility is similarly distributed across multiple actors. Qualified trust service providers carry formal obligations, wallet providers are responsible for the integrity and security of their solutions, and issuers of Person Identification Data and attestations must meet the requirements set out in the implementing acts. National competent authorities and registrars supervise these actors within their jurisdictions. Organizations that rely on identity verification as part of their onboarding or authentication flows also bear responsibility for the assurance levels they accept and the processes they put in place. Relying parties, in particular, must ensure that their acceptance of wallet credentials aligns with the applicable national registration framework under CIR (EU) 2025/848 of 6 May 2025, and with any sector-specific requirements that apply to them. Under that implementing act, a relying party must register with the national authority of its Member State of establishment before requesting wallet data, and must register per intended use which attributes and attestations it will request. The wallet checks requests against this registered scope.

This distributed accountability model means organizations cannot simply outsource compliance to a vendor. Procurement decisions must include a careful review of how responsibility is shared, and contracts should clearly define which party is responsible for which obligations.

What should organizations do now to align with both regulations?

Organizations should start by mapping where AI is currently used in their identity verification processes and assessing whether those systems meet the EU AI Act’s high-risk classification. From there, they can build a compliance roadmap that addresses both the AI Act and eIDAS 2.0 together.

Practical steps to take now include:

1. Audit your identity verification stack: Identify every point where AI is used, who supplies it, and what data flows through it.
2. Classify your AI systems: Determine whether your systems fall into the high-risk category under the AI Act and what specific obligations apply, taking into account the updated application dates under the Digital Omnibus on AI.
3. Review vendor contracts: Clarify which obligations sit with your provider and which sit with your organization as deployer.
4. Align with eIDAS 2.0 assurance levels: Ensure your verification processes can meet the assurance levels required for your use cases, including wallet-based interactions.
5. Prepare for EUDI Wallet integration: Organizations in financial services and government services should plan for accepting wallet credentials as a primary verification method, which reduces AI risk exposure. Public-sector bodies face a deadline of 24 December 2026. Private relying parties in regulated sectors, including banking, healthcare, telecoms, energy, transport, and others listed under Article 5f of eIDAS 2.0, face a deadline of 24 December 2027. Micro and small enterprises with fewer than 50 employees and an annual turnover or balance sheet total not exceeding 10 million euros are exempt. Because national wallet rollouts will progress at different speeds, preparation should account for a phased adoption path.
6. Document everything: Both frameworks require clear records of how systems work, how decisions are made, and how risks are managed.

Organizations in healthcare, pharmaceuticals, and other regulated sectors should also consider sector-specific guidance, as additional rules may apply on top of the two frameworks. For those working in healthcare identity verification, the intersection of data sensitivity, Article 9 GDPR obligations for biometric data, and AI risk is particularly important to address proactively.

How TrustTech helps organizations navigate eIDAS 2.0 and the EU AI Act

Aligning with both eIDAS 2.0 and the EU AI Act requires the right infrastructure and clear processes. TrustTech’s ID Connector is an integration that lets relying parties accept every certified European wallet, whatever Member State issued it, for identification, login and qualified signing. EUDI Wallet acceptance comes first; the same interface also carries other IDs, such as national eIDs, bank IDs and identity documents, inside and outside the EU.

For organizations working through the intersection of eIDAS 2.0 and the EU AI Act, the ID Connector addresses several of the practical compliance challenges directly:

• EUDI Wallet acceptance: The ID Connector enables organizations to accept verified credentials from notified wallets, reducing the need for AI-powered identity checks and the associated high-risk AI Act obligations
• Trust management and verification: The ID Connector handles verification against national trusted lists, revocation status checks, and validation of wallet unit attestations, so organizations can confirm that a presenting wallet runs on a certified wallet solution
• Registered attribute scope: The ID Connector supports the relying-party registration model under CIR (EU) 2025/848, ensuring that only the attributes registered for a given intended use are requested from the wallet
• Reusable identity data: Organizations can verify identity once and reuse trusted identity data across the full process, reducing repeated AI-based checks
• Qualified signing: Every signature and consent action is identity-linked and audit-ready, satisfying both eIDAS 2.0 requirements and the AI Act’s documentation obligations, through connection to a qualified trust service provider
• Sector coverage: The ID Connector is relevant for organizations in financial services, government, healthcare, and pharmaceuticals, where both eIDAS 2.0 and the AI Act apply with particular force

Get in touch with TrustTech to discuss what EUDI Wallet acceptance and reduced AI verification exposure looks like for your organization.