How does eIDAS 2.0 address interoperability between member states?

eIDAS 2.0, Regulation (EU) 2024/1183, amends Regulation (EU) 910/2014 and addresses interoperability between member states by introducing a unified framework built around the European Digital Identity (EUDI) Wallet, mandatory cross-border recognition, and standardised technical specifications that all member states must follow. Unlike the original regulation, which allowed significant variation between national systems, eIDAS 2.0 creates binding obligations that close the gaps in cross-border digital identity exchange. The sections below explore exactly how this works in practice and what it means for your organisation.

What mechanisms does eIDAS 2.0 introduce to enable cross-border identity recognition?

eIDAS 2.0 introduces mandatory mutual recognition of national electronic identity schemes across all EU member states, combined with a common technical framework that standardises how identity data is structured, exchanged, and verified. Every member state is now required to offer citizens, residents, and businesses a EUDI Wallet, creating a shared infrastructure for cross-border recognition that the original regulation never achieved.

The original eIDAS regulation from 2014 was a step in the right direction, but it had a fundamental limitation: member states were not required to create interoperable systems, only to recognise notified schemes from other countries. This led to a patchwork of national solutions with very different levels of maturity and coverage.

eIDAS 2.0 changes this by making the EUDI Wallet a legal obligation for all member states. The regulation also introduces a set of implementing acts, which contain the legally binding requirements, covering everything from identity proofing and attribute formats to protocols, interfaces, and certification requirements. The Architecture and Reference Framework (ARF) provides the technical elaboration of those requirements. Together, these instruments ensure that a wallet issued in one country can be read, validated, and trusted in another, without the need for bilateral agreements or custom integrations. Governance under eIDAS 2.0 is a shared responsibility: the European Commission manages the legal framework and adopts implementing acts; member states provide or mandate wallet solutions, certify and notify them, and supervise actors within their jurisdiction; the European Digital Identity Cooperation Group supports cross-border alignment; and national competent authorities, wallet providers, issuers of Person Identification Data and attestations, qualified trust service providers, and relying parties each carry distinct roles within the ecosystem.

In addition, eIDAS 2.0 opens the framework to the private sector. Qualified and non-qualified electronic attestations of attributes can now be issued by accredited private providers, alongside governments. This significantly expands the range of identity data that can flow across borders in a standardised, trusted way.

How does the EUDI Wallet ensure interoperability across different countries?

The EUDI Wallet supports interoperability through a shared Architecture and Reference Framework (ARF) that provides the technical elaboration of the requirements set out in the implementing acts. All wallet solutions must comply with those requirements. Because every member state must build or certify its wallet solution against the same specification, wallets from different countries can communicate and exchange verified identity data without custom integration work. No single central European authority operationally manages all EUDI Wallets; responsibility is distributed across member states, national competent authorities, and the other actors described above.

The ARF covers a wide range of technical requirements, including how identity data is structured, how wallets authenticate users, how credentials are presented to relying parties, and how privacy is protected through selective disclosure. Selective disclosure is particularly important for cross-border use: it allows a user to share only the specific attributes a service needs, such as age or nationality, without revealing their full identity profile.

To validate that wallet solutions actually meet these requirements, the regulation introduces a certification scheme. Member states are responsible for certifying and notifying their wallet solutions. A wallet solution that has been certified and notified by one member state is recognised as compliant across the EU. This removes the need for each country to independently verify another country’s implementation.

The four large-scale pilot projects that ran from April 2023 to 2025 played a key role in testing this interoperability in practice. With over 350 participating entities from 26 member states, Norway, Iceland, and Ukraine, the pilots tested real-world scenarios across a range of use cases. POTENTIAL covered government services, opening a bank account, SIM registration, mobile driving licences, remote qualified signing, and e-prescriptions. EWC focused on digital travel credentials, payments, and organisational digital identity. NOBID concentrated on payments. DC4EU addressed education and social security. The insights from these pilots directly informed the technical specifications that are now being implemented across the EU. A second wave of pilots started in 2025, with WE BUILD focusing on business wallets and payments, and APTITUDE covering travel, ticketing, vehicle registration, and payments.

What role do trust frameworks and trust lists play in eIDAS 2.0 interoperability?

Trust frameworks and national trusted lists are central to eIDAS 2.0 interoperability. They create a shared, publicly accessible record of which identity providers, wallet solutions, and trust service providers have been officially recognised and certified. Without this shared infrastructure, a relying party in Germany would have no reliable way to verify whether a credential presented by a user from Portugal actually comes from a trusted source.

Under eIDAS 2.0, each member state maintains a national trusted list that includes certified wallet solutions, qualified trust service providers, and recognised electronic identity schemes. These lists are standardised in format and publicly accessible, meaning any organisation across the EU can check whether a given provider or credential meets the required level of assurance. The national trusted lists are brought together in the EU List of Trusted Lists (LOTL). Where relevant, Lists of Trusted Entities (LoTE) may also apply within the ecosystem.

The regulation also introduces new trust list entries specifically for wallet ecosystems, including certified wallet relying parties and approved attribute providers. This extends the trust chain beyond just identity providers to cover the full range of entities involved in a digital identity transaction.

For organisations operating in regulated sectors such as financial services or healthcare, trusted lists provide a practical compliance tool. Rather than conducting their own due diligence on every identity provider they interact with, organisations can rely on the relevant national trusted list as a verified source of truth, reducing both risk and operational overhead.

What are the main interoperability challenges organisations still face under eIDAS 2.0?

Despite the progress eIDAS 2.0 represents, organisations still face real interoperability challenges. The regulation sets the framework, but implementation timelines, technical readiness, and legacy system constraints vary considerably across member states and industries. Organisations cannot assume that cross-border digital identity exchange will work seamlessly from day one, and practical interoperability is likely to develop in phases as national rollouts mature.

Some of the most common challenges include:

• Uneven implementation timelines: While member states are legally required to meet their wallet obligations by 24 December 2026, the pace of deployment differs. The legal deadline does not guarantee that every national wallet solution will have the same level of maturity or that every possible cross-border use case will be fully operational throughout Europe on that date. Some countries are further ahead than others, and practical interoperability will develop in phases.
• Legacy system integration: Many organisations have existing identity and onboarding systems that were not designed with wallet-based credentials in mind. Connecting these systems to the new wallet ecosystem requires technical investment and architectural changes.
• Attribute schema inconsistencies: Even within a shared framework, differences in how attributes are defined and populated at the national level can create friction when credentials are used cross-border.
• Relying party registration and compliance: Organisations that want to accept EUDI Wallet credentials must register as relying parties under CIR (EU) 2025/848, adopted on 6 May 2025, with the national authority of the member state where they are established, before they can request wallet data. Registration is per intended use: relying parties declare which attributes and attestations they will request, and the wallet validates requests against that registered scope. National registration requirements apply alongside eIDAS 2.0, and sector-specific legislation continues to apply in parallel. Understanding and completing this process takes time.
• User adoption and trust: Technical interoperability alone does not guarantee that users will adopt the wallet or that organisations will accept it. Building user confidence in cross-border digital identity takes time and clear communication.

Organisations in government and other regulated sectors face an additional layer of complexity, as they must align their identity processes with both eIDAS 2.0 requirements and sector-specific regulations such as AML, KYC, and GDPR simultaneously. Cross-border use does not remove the need to consider applicable national or sector-specific rules, and the legal consequences of a credential may vary between member states depending on national law.

How should organisations prepare their systems for eIDAS 2.0 interoperability?

Organisations should prepare for eIDAS 2.0 interoperability by starting with a clear assessment of their current identity infrastructure, identifying the gaps between their existing systems and the requirements of the EUDI Wallet ecosystem, and then building a phased roadmap toward compliance and integration. Waiting before acting is a risky strategy: the regulatory obligations are already in effect, the ecosystem is moving fast, and national rollouts will develop at different speeds.

Key milestones to keep in mind: by 24 December 2026, every EU member state must have at least one certified EUDI Wallet solution operational, and public sector bodies must accept notified wallets as a means of identification for online services requiring electronic identification. This is the legal deadline for member states’ wallet obligations; it is not a prediction that every national wallet solution will be fully mature or that every cross-border use case will be operational everywhere on that date. For private sector organisations, 24 December 2026 is the point at which wallet solutions become available and acceptance ahead of the mandatory deadline can be tested in practice. Regulated private sector organisations, including those in banking and financial services, healthcare, telecoms, energy, transport, education, social security, drinking water, postal services, and digital infrastructure, face a mandatory acceptance obligation from 24 December 2027 under Article 5f of the regulation, where strong user authentication is legally or contractually required. Very large online platforms (VLOPs) with more than 45 million users in the EU fall under a separate provision of Article 5f: the obligation applies where the platform requires user authentication, on the voluntary request of the user and for the minimum necessary data. These are legal deadlines, not predictions of when every organisation or member state will have fully deployed the wallet in practice. Micro and small enterprises, defined as organisations with fewer than 50 employees and an annual turnover or balance sheet total not exceeding 10 million euros, are exempt from the Article 5f obligation.

A practical preparation approach follows these steps:

1. Map your current identity processes: Understand how you currently verify, onboard, and authenticate users or counterparties. Identify where cross-border identity is already relevant and where it will become relevant under eIDAS 2.0.
2. Assess your technical architecture: Evaluate whether your existing systems can support wallet-based credential presentation, selective disclosure, and the protocols required by the ARF. Identify integration points that need updating.
3. Understand your relying party obligations: If you plan to accept EUDI Wallet credentials, you will need to register as a relying party under CIR (EU) 2025/848 with the national authority of the member state where you are established, and declare the attributes and attestations you intend to request, before you can request wallet data. Start this process early.
4. Align with trust list requirements: Ensure that any identity providers or trust services you use are listed on the relevant national trusted lists, which are brought together in the EU List of Trusted Lists (LOTL). Build processes for monitoring changes to these lists over time.
5. Pilot with real use cases: Identify one or two concrete cross-border identity scenarios relevant to your business and test your readiness against those specific cases.
6. Engage with the ecosystem: Stay connected with developments in your sector, including the outcomes of the large-scale pilot projects and any sector-specific guidance from regulators.

Organisations that treat eIDAS 2.0 interoperability as a compliance checkbox will miss the broader opportunity. Cross-border digital identity, when implemented well, reduces onboarding friction, lowers the cost of compliance, and enables faster, more trusted digital interactions across the EU. The organisations that invest in getting this right now will be better positioned to serve customers and partners across borders as the ecosystem matures. For more guidance on building a practical roadmap, explore the resources available from TrustTech.

How TrustTech helps with eIDAS 2.0 interoperability

Connecting to the EUDI Wallet ecosystem involves more than reading the regulation. Organisations need to register as relying parties, declare their attribute scope, validate credentials against national trusted lists, handle revocation checks, and verify wallet unit attestations, all while keeping pace with implementing acts and ARF updates. The 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.

Concretely, the ID Connector handles:

• Wallet acceptance across member states, so your systems can receive and process credentials from any notified EUDI Wallet solution without building separate integrations per country
• Validation against national trusted lists and the EU List of Trusted Lists (LOTL), so issuer signatures can be checked against the correct authoritative source
• Revocation status checks, using the status information provided by the issuer of each attestation
• Wallet unit attestation validation, confirming that the presenting wallet instance runs on a certified wallet solution
• Attribute scope enforcement, ensuring that credential requests stay within the scope declared during relying party registration under CIR (EU) 2025/848
• Qualified signing via a connected QTSP, for use cases where a qualified electronic signature is required

TrustTech works with organisations in financial services, healthcare, pharma, and government. Ready to take the next step? Get in touch with TrustTech and find out how the ID Connector can connect your organisation to the EUDI Wallet ecosystem.