The EUDI Wallet protects your personal data through a combination of selective disclosure, decentralised data storage, and legal safeguards under GDPR and eIDAS 2.0, which amends Regulation (EU) 910/2014. You remain in control of what you share, with whom, and when. This article walks through the key privacy and security mechanisms built into the European Digital Identity Wallet.
What data does the EUDI Wallet actually store?
The EUDI Wallet stores verified identity attributes and official attestations issued by trusted sources, such as governments, healthcare providers, or educational institutions. This can include your name, date of birth, national ID number, driving licence, diplomas, European Health Insurance Card, and other certified credentials. The wallet stores only what you choose to add to it.
Unlike a traditional username-and-password account stored on a company’s server, the data in your EUDI Wallet lives on your own device. This is a fundamental design choice: you are the custodian of your own identity data, not a third-party platform.
The types of credentials the wallet can hold include:
- Government-issued identity documents (national ID, passport data)
- Mobile driving licences
- Educational qualifications and diplomas
- Healthcare credentials such as the European Health Insurance Card
- Professional certifications and organisational roles
- Payment authorisation credentials
These credentials are stored as verifiable attestations, using standardised digital formats such as mdoc and SD-JWT VC, which allow a relying party to check their authenticity without necessarily contacting the original issuer at the moment of verification.
How does selective disclosure protect your privacy?
Selective disclosure means you share only the specific data attributes a service actually needs. Instead of handing over your full identity document, you can present a single verified fact. For example, to prove you are over 18, you can confirm that fact without revealing your exact date of birth or any other personal detail. This can be achieved through attribute-level selective disclosure, for instance by sharing only the attribute “age over 18” from a credential, without requiring zero-knowledge proofs.
This principle is one of the most significant privacy advances the EUDI Wallet brings to everyday digital interactions. Today, many online services ask for far more information than they genuinely need. Selective disclosure changes that dynamic: you decide what gets shared, and the wallet enforces that boundary technically.
The credential formats supported by the Architecture and Reference Framework, mdoc and SD-JWT VC, both support selective disclosure at the attribute level. These mechanisms allow a relying party to confirm that a claim is true without receiving the full underlying document. The result is that the service gets the confirmation it needs, and you retain privacy over everything else.
This approach is directly aligned with the data minimisation principle under GDPR, which requires that only the minimum necessary personal data is processed for any given purpose.
Who can access your data inside the EUDI Wallet?
Only you can initiate the sharing of data from your EUDI Wallet. No third party, whether a government agency, a private company, or the wallet provider, can access your credentials without your explicit, active approval. Every data transaction requires you to approve it in the wallet.
When a service requests data from your wallet, you see exactly what is being asked for before you agree. You can accept, decline, or share only part of what is requested. This is an active, informed action you take each time, not a passive opt-in buried in terms and conditions.
Relying parties, the businesses and public services that request your data, must register with the national authority of their Member State of establishment under CIR (EU) 2025/848 of 6 May 2025 before they can request wallet data. As part of registration, each relying party declares per intended use which attributes and attestations it will request. The wallet checks incoming requests against this registered scope. Relying parties cannot request more data than is necessary for their stated purpose, and they are accountable under GDPR for how they use the data you share.
Wallet providers, whether a government body or a certified private provider, are bound by strict rules under eIDAS 2.0. They are not permitted to access the contents of your wallet or to log which services you interact with. The wallet dashboard is a tool for you as the user, giving you visibility over your own credentials and activity. Governance of the EUDI Wallet is a shared responsibility: the European Commission sets the legal framework and adopts implementing acts, EU Member States provide or mandate wallet solutions and supervise actors within their jurisdiction, and national competent authorities oversee compliance at the national level.
How does the EUDI Wallet limit tracking and profiling?
The EUDI Wallet is specifically designed to limit cross-service tracking and profiling. Each time you share a credential, a unique, unlinkable presentation is generated. This means that two different services cannot compare notes and determine that the same person interacted with both of them, though no system can eliminate all risk of tracking or profiling entirely.
This is a deliberate architectural choice that goes beyond basic privacy compliance. In today’s digital environment, a single login identifier such as an email address or social media account can be used to build a detailed profile of your behaviour across many platforms. The EUDI Wallet is designed to break this pattern.
The anti-tracking protections work through several mechanisms:
- Unlinkable presentations: Each credential presentation generates a unique cryptographic token, so two verifications of the same credential cannot be linked to the same wallet.
- No central transaction log accessible to others: There is no central registry that records when and where you use your wallet. Transactions are not stored in a way that creates a traceable audit trail accessible to third parties.
- Issuer involvement at verification: When you present a credential, verifying the issuer’s signature can be done against the relevant national trusted list without contacting the issuer directly. However, checking revocation status requires access to the issuer’s status information, and validating the wallet unit attestation requires confirming that the presenting wallet runs on a certified wallet solution. Full offline verification without any network access applies only to the signature check.
- User-controlled pseudonyms: The wallet generates a different pseudonym per relying party and stores it locally. This prevents any single identifier from becoming a universal tracking key across services.
What happens to your data if you lose your device?
If you lose your device, your personal data remains protected because the EUDI Wallet is secured by strong authentication, typically a PIN, biometric lock, or both. Without these credentials, no one can open the wallet or access the data stored inside it.
Your credentials are cryptographically tied to your wallet unit, specifically to the Wallet Secure Cryptographic Device in which the private keys are held. Private keys for your PID and attestations do not leave that secure element. This means that even if someone gains physical access to your phone, they cannot copy your credentials to another device and use them as you. The binding between the credential and your specific wallet unit is enforced at the cryptographic level.
If your device is lost or stolen, you can take the following steps:
- Report the loss to your wallet provider to have your wallet unit suspended or revoked
- Re-obtain your credentials from the original issuers onto a new device, as attestations must be reissued rather than simply transferred
- Use remote device management tools if your device supports them to wipe the wallet remotely
Because the data is stored on your device, there is no single server that a hacker could breach to steal millions of people’s identity data at once. This decentralised model significantly reduces the systemic risk of large-scale data breaches.
How does the EUDI Wallet comply with GDPR?
The EUDI Wallet is built to comply with GDPR by design. The regulation’s core principles, including data minimisation, purpose limitation, storage limitation, and user rights, are embedded directly into the wallet’s technical and legal architecture under eIDAS 2.0. The implementing acts adopted by the European Commission contain the legally binding requirements, while the Architecture and Reference Framework provides the technical elaboration of those requirements.
Several GDPR requirements are addressed directly through how the wallet works:
- Data minimisation: Selective disclosure ensures only necessary data is shared
- Purpose limitation: Relying parties can only request data for their declared, registered purpose
- Approval in the wallet: Every data sharing action requires your active approval; this is separate from the legal basis a relying party must hold under GDPR for its own processing
- Right of access: You can see all credentials stored in your wallet at any time
- Right to erasure: You can delete credentials from your wallet; credential revocation is handled through the issuer’s revocation mechanism
- Accountability: Wallet providers and relying parties must meet defined legal obligations and are subject to oversight by national competent authorities
The eIDAS 2.0 regulation and GDPR work together. Where eIDAS 2.0 sets the technical standards and trust framework, GDPR provides the legal basis for how personal data must be handled. Together, they create a layered protection framework that applies across all EU Member States. Sector-specific legislation, for example in financial services or healthcare, does not disappear within this framework. Relying parties in those sectors remain subject to their own regulatory obligations alongside eIDAS 2.0 and GDPR. For health data, a relying party also requires a lawful basis under Article 9(2) GDPR in addition to a general processing ground.
It is also worth noting that approving a data request in the wallet is not the same as giving consent as a GDPR legal basis. A relying party must identify its own appropriate legal basis for processing the data you share. In many regulated contexts, such as identity verification for financial services, that basis will be a legal obligation rather than consent.
For organisations in sectors such as financial services or healthcare, where data protection obligations are particularly stringent, this alignment between eIDAS 2.0 and GDPR is especially relevant. Integrating the EUDI Wallet into your services can support your existing compliance posture.
How the ID Connector supports EUDI Wallet data protection in practice
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.
For organisations preparing to accept the EUDI Wallet, the ID Connector from TrustTech handles several of the technical verification steps that data protection depends on. It verifies issuer signatures against the relevant national trusted lists, which are brought together in the EU List of Trusted Lists. It checks revocation status through the issuer’s status information. It validates wallet unit attestations to confirm that the presenting wallet runs on a certified wallet solution. It also checks that incoming data requests stay within the attribute scope that the relying party registered under CIR (EU) 2025/848.
The legal deadline for Member States to issue wallets and for public-sector bodies to accept them is 24 December 2026. For relevant regulated private-sector organisations, the acceptance obligation under Article 5f applies from 24 December 2027. Organisations in financial services, healthcare, telecom, energy, transport, and other regulated sectors that begin technical preparation now will be better placed as national rollout develops in phases.
The ID Connector also supports qualified signing via a connected qualified trust service provider, and handles the reuse of verified identity data where a relying party’s registered scope and legal basis permit it. Explore TrustTech’s digital identity solutions or contact our team to discuss how the ID Connector fits your organisation’s EUDI Wallet integration.