The EUDI Wallet rollout affects a wide range of sectors across Europe, but some industries face more immediate and far-reaching changes than others. Financial services, healthcare, government, and education are among the sectors most directly impacted, both because of their reliance on identity verification and because eIDAS 2.0 places specific obligations on organizations operating within them. This article walks through the key questions organizations in these sectors are asking right now.
Which industries are required to accept the EUDI Wallet?
Under eIDAS 2.0, which amends Regulation (EU) 910/2014, certain categories of service providers are legally required to accept the European Digital Identity Wallet as a means of identity verification. These obligations apply to regulated private sector organizations where strong authentication or identity verification is required by law or contract. The acceptance obligation for these private sector parties takes effect on 24 December 2027, under Article 5f of the regulation, twelve months after the legal deadline for wallet issuance and public sector acceptance.
The regulation distinguishes between organizations that are obliged to accept the EUDI Wallet and those that may choose to integrate it voluntarily. Obliged relying parties are those operating in regulated sectors where strong user authentication is a legal or contractual requirement, such as financial onboarding under anti-money laundering rules or access to public services under national e-government frameworks. Micro and small enterprises, defined as organizations with fewer than 50 employees and an annual turnover or balance sheet total of no more than 10 million euros, are exempt from the Article 5f acceptance obligation.
Very large online platforms, defined as platforms with more than 45 million users in the EU, fall under a separate provision of Article 5f. For very large online platforms, the obligation applies where the platform requires user authentication, on the voluntary request of the user and for the minimum necessary data. The condition of legally or contractually required strong user authentication does not apply to very large online platforms.
In practice, the sectors most directly affected include:
- Financial services (banks, insurers, payment institutions)
- Healthcare and pharmaceuticals (hospitals, pharmacies, health insurers)
- Government and public services (tax authorities, social security, licensing bodies)
- Telecommunications (SIM registration and contract management)
- Education and professional certification (universities, credential issuers)
- Transportation (airlines, rail operators, driving license authorities)
- Energy (energy suppliers and distributors)
- Very large online platforms (platforms with more than 45 million users in the EU)
Before a relying party can request data from a EUDI Wallet, it must register with the national authority of its Member State of establishment under CIR (EU) 2025/848, adopted on 6 May 2025. Registration specifies, per intended use, which attributes and attestations the relying party is permitted to request. The wallet checks each request against this registered scope. Organizations outside the core sectors listed above may also find integration beneficial, particularly those that currently use third-party identity verification for onboarding or access management.
How does the EUDI Wallet affect the financial services sector?
For financial services, the EUDI Wallet changes how identity verification works at every stage of the customer journey. Banks, payment institutions, and insurers will be able to use wallet-based attestations to verify customer identity during onboarding, satisfy Know Your Customer (KYC) requirements, and support Strong Customer Authentication (SCA) for payments. This reduces friction for customers while meeting regulatory obligations more efficiently.
One of the most significant shifts is in digital onboarding. Today, opening a bank account online often involves uploading documents, taking selfies, and waiting for manual review. With the EUDI Wallet, a customer can share verified identity attributes directly from their wallet in a single interaction, with no need to resubmit documents that have already been verified by a trusted authority such as a Member State issuer of Person Identification Data or a qualified trust service provider.
The wallet also has implications for anti-money laundering compliance. As AML rules tighten across Europe, verified digital attestations from the EUDI Wallet can serve as a reliable source of identity data, reducing the risk of fraud and simplifying audit trails. It is worth noting that whether verified identity data from a EUDI Wallet presentation can be reused for KYC purposes is determined by AML regulation, not by eIDAS 2.0 itself. The new AML framework, including the AMLR which becomes applicable in July 2027, is moving towards identity verification via notified schemes, the EUDI Wallet, and qualified trust services. This is a separate regulatory track from the eIDAS 2.0 acceptance obligation, and organizations in financial services that start preparing their systems now will be better positioned to meet both sets of requirements.
Payment authentication is another key area. The EUDI Wallet was tested in large-scale pilots for payment use cases, including domestic and cross-border transactions, with the aim of enabling wallet-based SCA that is both secure and user-friendly.
What changes does the EUDI Wallet bring to healthcare and pharmaceuticals?
In healthcare and pharmaceuticals, the EUDI Wallet enables secure, privacy-preserving access to medical services and prescription management across borders. Patients will be able to store documents such as the European Health Insurance Card in their wallet, present prescriptions to pharmacies digitally, and access healthcare services in other EU Member States without carrying physical documents. The availability of specific cross-border use cases will depend on national rollout progress and sector-specific implementation in each Member State, and is expected to develop in phases.
For healthcare providers and pharmacies, this means adapting systems to accept wallet-based attestations as a valid form of identification and authorization. A patient presenting a digital prescription through their EUDI Wallet should be able to receive medication at any participating pharmacy, whether in their home country or abroad, provided the relevant relying party has registered under the applicable national framework and the use case is operational in that jurisdiction. E-prescriptions were among the use cases tested in the POTENTIAL large-scale pilot.
The pharmaceutical sector also benefits from improved traceability and reduced prescription fraud. Because wallet attestations are cryptographically signed and issued by trusted authorities, they are tamper-evident and significantly harder to falsify than paper or unverified digital alternatives.
When a relying party in healthcare verifies a wallet presentation, this involves three distinct checks: verification of the issuer’s signature against the relevant national trusted list, which is part of the EU List of Trusted Lists (LOTL); a check of the revocation status using the issuer’s status information; and validation of the wallet unit attestation to confirm that the presenting wallet is running on a certified wallet solution. Only the first of these checks can be performed fully offline.
For organizations in healthcare, the key preparation steps involve connecting existing patient identity systems to wallet-compatible infrastructure and ensuring that staff and patient-facing processes can handle wallet-based interactions. Processing health data obtained via a wallet presentation requires a legal basis under Article 9(2) of the GDPR in addition to a general processing ground.
How will government and public services be impacted by the EUDI Wallet?
Government and public services occupy a central role in the EUDI Wallet ecosystem, both as issuers and as consumers of wallet attestations. Under eIDAS 2.0, each Member State is legally required to make at least one certified EUDI Wallet available to all citizens, residents, and businesses by 24 December 2026. Public authorities and public service providers must accept notified wallets as a means of identification from that same date. Governance of the ecosystem 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, while the European Digital Identity Cooperation Group supports cross-border alignment and cooperation. There is no single central European authority that operationally manages all EUDI Wallets.
The 24 December 2026 date is a legal deadline. It does not guarantee that every national wallet will have reached the same level of maturity or that every possible cross-border use case will be fully operational throughout Europe on that date. Practical interoperability and national rollout are expected to develop in phases, and organizations should plan accordingly.
Citizens will be able to use their EUDI Wallet to access a wide range of government services digitally, including:
- Applying for or renewing a passport or driving license
- Filing taxes and accessing tax records
- Claiming social security or disability benefits
- Accessing healthcare entitlements and insurance information
- Proving organizational representation for business registrations
For government organizations, the EUDI Wallet also presents an opportunity to reduce administrative burden. When a citizen’s identity has already been verified and stored in a wallet, government agencies no longer need to reverify the same information repeatedly. This streamlines processes and reduces costs on both sides.
The challenge for public sector organizations lies in integrating legacy systems with new wallet-compatible infrastructure, ensuring accessibility for all citizens, and maintaining trust throughout the transition.
What does the EUDI Wallet mean for education and professional credentials?
The EUDI Wallet creates a standardized way to issue, store, and present educational qualifications and professional credentials across Europe. Students and professionals will be able to carry verified digital diplomas, degrees, and certifications in their wallet and present them to employers, universities, or licensing bodies without needing to request paper copies or go through lengthy verification processes.
This is particularly valuable in a cross-border context. A graduate from one EU country applying for a job or further education in another will be able to share verified attestations directly, removing much of the friction that currently exists around document authentication and translation. Cross-border credential recognition remains subject to national and sector-specific rules. A credential being technically presentable via the EUDI Wallet does not automatically give it the same legal consequence in every Member State, and sector-specific legislation governing professional qualifications continues to apply. Recognition of professional qualifications, for example, is governed by Directive 2005/36/EC, which operates independently of eIDAS 2.0.
For universities and other credential-issuing bodies, the shift involves adopting standards for issuing credentials as verifiable attestations that are compatible with the EUDI Wallet ecosystem. The DC4EU large-scale pilot, which ran from April 2023 to 2025, tested how education and social security credentials work in practice across multiple Member States.
Professional licensing bodies, such as those governing medical practitioners, lawyers, or engineers, will also need to consider how their attestations fit into the wallet framework, particularly where cross-border recognition of qualifications is already a regulatory requirement. Registration as a relying party under CIR (EU) 2025/848 is required before a licensing body can request wallet data, and licensing bodies should engage with their relevant national competent authorities as part of their preparation. Organizations in the science and education sector can use this transition as an opportunity to modernize their credential infrastructure entirely.
When do organizations need to be EUDI Wallet-ready?
The key regulatory dates differ depending on whether an organization is in the public or private sector. Member States must make at least one certified EUDI Wallet available to all citizens, residents, and businesses by 24 December 2026, and public authorities must accept notified wallets from that date. For regulated private sector organizations, such as banks, healthcare providers, telecom operators, and other sectors where strong authentication is legally or contractually required, the acceptance obligation takes effect on 24 December 2027, under Article 5f of the regulation.
These are legal deadlines. National wallet availability, certification and notification, operational interoperability, and acceptance by relying parties are distinct steps, and their timing will vary across Member States. Wallet infrastructure, trust frameworks, and interoperability standards are being finalized now, and organizations that engage early will have more time to test, iterate, and train their teams before compliance becomes mandatory. For private sector relying parties, the period following the 24 December 2026 deadline is also a practical window: once certified wallets become available to citizens in their Member State, organizations can begin real-world testing of wallet-based interactions ahead of their own compliance date in 2027.
The practical readiness timeline looks roughly like this: organizations should currently be assessing which of their processes involve identity verification, mapping those processes against EUDI Wallet use cases, and beginning conversations with technology partners about integration options. By the time the relevant deadline applies to their sector, the expectation is that core systems are wallet-compatible and staff are equipped to support wallet-based interactions with customers or citizens.
How TrustTech helps organizations prepare for the EUDI Wallet rollout
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 organizations in financial services, healthcare, pharma, and government, the ID Connector handles the technical complexity of wallet acceptance directly. This includes:
- Accepting wallet presentations and validating issuer signatures against national trusted lists, which are part of the EU List of Trusted Lists (LOTL)
- Checking revocation status using issuer-provided status information
- Validating wallet unit attestations to confirm the presenting wallet runs on a certified wallet solution
- Enforcing the registered attribute scope so that only the data specified in the relying party’s registration under CIR (EU) 2025/848 is requested
- Supporting qualified signing via a connected qualified trust service provider
- Carrying other identity means, such as national eIDs and bank IDs, through the same interface
A vendor processing wallet data on behalf of a client organization does not itself become the relying party. The registration obligation under CIR (EU) 2025/848 rests with the organization delivering the service to the end user. The ID Connector is designed to support that registered relying party in meeting its technical obligations.
Get in touch with our team to discuss your organization’s situation and find out how the ID Connector fits into your EUDI Wallet readiness.