Businesses that qualify as relying parties under eIDAS 2.0 must register with a national authority in their member state of establishment before they can request data from a European Digital Identity Wallet. This registration requirement is set out in CIR (EU) 2025/848 of 6 May 2025 and applies to any organisation that wants to receive identity attributes or attestations from an EUDI Wallet. The sections below cover who is affected, how procedures vary across the EU, and what practical steps organisations should take before the deadlines arrive.
What are the national registration procedures for the EUDI Wallet?
Under CIR (EU) 2025/848, every relying party must register with a designated national authority in the member state where it is established before it can request wallet data. Registration is not a one-time formality: once approved, the relying party receives access certificates that wallets check at every data request. Without a valid certificate, the wallet will not release any attributes.
The registration process requires a relying party to declare, per intended use, exactly which attributes and attestations it will request. This scope declaration is binding. The wallet checks every incoming request against the registered scope and stops the presentation if the request exceeds what was declared. Requesting more attributes than registered is an explicit ground for revocation of the registration, making the scope declaration the most consequential practical step in the entire process.
Each member state designates its own registrar for this function. The registrar may sit within an existing supervisory body or be a separately designated authority. Some member states may also issue registration certificates alongside access certificates, allowing wallets to verify the permitted scope automatically.
Which types of businesses are affected by EUDI Wallet registration requirements?
The registration requirement applies to any organisation that acts as a relying party: a party that requests identity data from a wallet to deliver a service to a user. The private sector obligation under Article 5f of eIDAS 2.0 takes effect on 24 December 2027 and covers regulated sectors where strong user authentication is legally or contractually required.
The regulation names the following sectors explicitly:
- Banking and financial services
- Healthcare
- Telecommunications
- Energy
- Transport
- Education
- Social security
- Drinking water
- Postal services
- Digital infrastructure and digital services
Very large online platforms (VLOPs) designated under the Digital Services Act, those with more than 45 million EU users, are also included. For VLOPs, the obligation applies where the platform requires user authentication, on a voluntary basis and limited to the minimum necessary data.
One important carve-out: micro and small enterprises with fewer than 50 employees and an annual turnover or balance sheet total of no more than 10 million euros are exempt from the private acceptance obligation.
It is also worth clarifying who is not a relying party. A supplier that processes wallet data on behalf of a client is acting as a data processor under Article 28 GDPR, not as a relying party. The registration obligation stays with the organisation that delivers the service to the user. Platform providers, cloud suppliers, and system integrators should be clear about this distinction when structuring their contracts and compliance responsibilities.
How do national registration procedures differ across EU member states?
The legal framework for registration is set at EU level through CIR (EU) 2025/848, but the practical implementation varies by member state. Each country designates its own registrar, sets its own application process, and determines how access certificates are issued and renewed. The result is that the steps a business takes in one country may differ from those required in another.
Member states are also at different stages of wallet readiness. Denmark’s AltID has been live since June 2026, running alongside MitID and starting with age and identity verification. Austria’s ID Austria is operational. The Netherlands is developing the open-source NL Wallet, building on DigiD and eHerkenning as its foundation. Other member states have limited beta programmes, and some have not yet published a rollout plan. This uneven landscape means that registration procedures in some countries are well-defined, while in others the national authority and its processes are still being established.
For organisations operating across multiple member states, this creates a practical challenge: registration must be completed in each member state of establishment where the service is delivered. There is no single EU-wide registration that covers all jurisdictions. Businesses with cross-border operations should map their establishment footprint early and track the registration timelines in each relevant country separately.
What steps should businesses take to prepare for registration changes?
Preparation for EUDI Wallet registration comes down to four concrete actions that organisations can start on now, well ahead of the 24 December 2027 deadline for the private sector.
- Determine whether you are a relying party. Identify which of your services will request wallet data and confirm that your organisation, not a supplier or processor, is the party delivering those services to users. If you use a third-party platform or integration layer, clarify in writing who holds the registration obligation.
- Define your attribute scope per intended use. For each service, list exactly which attributes and attestations you need. This scope will be declared at registration and is binding. Requesting anything beyond it is grounds for revocation, so the scope must reflect genuine operational need, not a precautionary maximum.
- Identify the national authority in your member state of establishment. Find out which body is designated as registrar in each country where you are established and monitor its published guidance. Registration procedures, timelines, and technical requirements will be published at national level.
- Prepare your technical integration for wallet acceptance. Receiving wallet data requires handling access certificates, verifying wallet unit attestations, and checking revocation status. These are not trivial additions to an existing identity flow. Building or procuring the technical capability to accept certified wallets from all 27 member states takes time, and testing should begin before the deadline, not after.
One deadline worth keeping in mind alongside 24 December 2027 is July 2027, when the new Anti-Money Laundering Regulation (AMLR) becomes applicable. For organisations in financial services, the AMLR may shape how wallet-based identity verification fits into KYC processes, and those two regulatory tracks are worth aligning early.
What are the risks of not registering or preparing too late?
Organisations that fail to register before requesting wallet data will not receive access certificates, and wallets will refuse their data requests. This is not a soft compliance gap: the technical enforcement is built into the wallet itself. An unregistered relying party simply cannot access wallet attributes, regardless of what other identity verification methods it uses.
Beyond the technical block, late preparation carries several compounding risks. Scope declarations require internal alignment between legal, compliance, and product teams. Getting that alignment wrong and declaring a scope that is too broad create grounds for revocation after registration. Revocation means losing access certificates and being unable to request wallet data until the issue is resolved with the national authority.
For organisations in healthcare and government, where identity verification is embedded in regulated processes, a gap in wallet acceptance capability could interrupt service delivery. The public sector deadline is earlier: 24 December 2026, when public service providers must accept notified wallets for online services requiring electronic identification.
There is also a competitive dimension. Organisations that complete registration and build wallet acceptance early will be able to serve users who present EUDI Wallets from day one. Those that delay will face a period where they cannot accept a growing share of user identities, particularly as wallet adoption increases across the EU.
Where can businesses find official guidance on EUDI Wallet registration?
The primary legal reference for registration is CIR (EU) 2025/848 of 6 May 2025, which sets out the registration obligations for wallet relying parties. This implementing regulation is published in the Official Journal of the European Union and is the authoritative source for the rules that apply across all member states.
For technical specifications, the Architecture and Reference Framework (ARF), currently at version 3.0.0, provides the common technical baseline for wallet interoperability, including the requirements for access certificates and attribute scope verification. The ARF is maintained by the European Commission and updated regularly, so organisations should check the current version at each stage of their implementation planning.
National guidance comes from the designated registrar in each member state. As member states publish their registration procedures, these will typically be available through national digital identity or supervisory authority websites. The European Commission’s EUDI Wallet pages also aggregate updates across member states and link to the large-scale pilot outcomes, which offer practical insight into how wallet acceptance works in practice.
For organisations that want to track the broader regulatory picture, the EU List of Trusted Lists (LOTL) and national trusted lists (ETSI TS 119 612) are the reference points for verifying which wallet solutions are certified and which trust service providers are qualified. These are separate from the relying party registration registers and serve a different function in the trust chain.
How the ID Connector helps with EUDI Wallet registration and acceptance
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 working through the registration process and building their technical acceptance capability, the ID Connector handles the parts that sit between registration and live wallet interactions:
- Verification of wallet unit attestations, confirming that the presenting wallet runs on a certified wallet solution
- Revocation status checks, so that revoked attestations are not accepted
- Signature verification against the national trusted lists of the issuing member state
- Monitoring of the registered attribute scope per interaction, so that requests stay within what was declared at registration
- Reuse of verified identity data across identification, login, and qualified signing within the same session
Organisations in financial services, healthcare, pharmaceuticals, and government use the ID Connector to bring wallet acceptance into existing systems through one integration, without rebuilding identity flows from scratch. Contact TrustTech to discuss how the ID Connector fits your registration timeline and technical setup.