Businesses can support customers who do not have a European Digital Identity Wallet by accepting alternative identity verification methods such as national eIDs, bank IDs, and identity documents alongside wallet-based identification. The EUDI Wallet is being rolled out across EU Member States, but adoption will be gradual, and not every customer will have one on day one. The questions below walk through who is unlikely to have a wallet at launch, which alternatives work, what the law requires, and how to build an identity flow that handles both.
Who is unlikely to have an EUDI Wallet at launch?
Several groups of users are unlikely to have a functioning EUDI Wallet in the near term. These include older adults less familiar with smartphone-based services, people without compatible devices, residents of Member States where national wallet rollouts are still in early stages, and customers who simply have not yet chosen to activate one. Wallet use is voluntary under article 5a of the regulation, and no one can be penalised for not having one.
The public sector deadline for wallet issuance and acceptance is 24 December 2026. That means every Member State must have at least one certified wallet available by that date, but it does not mean every citizen will have activated theirs. Implementation progress varies considerably across Europe. Some Member States are already running national wallets in production and marking them as EUDI-conformant. Others have limited beta programmes. A third group has not yet published a rollout plan. Denmark launched AltID in June 2026 alongside MitID. The Netherlands is developing the open-source NL Wallet, building on DigiD and eHerkenning. Austria has ID Austria live. For businesses serving customers across multiple countries, the practical reality is that wallet coverage will be uneven for some time.
Beyond geography, there is also a segment of users who are eligible for a wallet but have not yet gone through the activation process. Businesses should plan for this group as a structural part of their user base, not as a temporary edge case.
What identity verification methods can replace the EUDI Wallet?
National eIDs, bank IDs, and identity documents are the most practical alternatives to the EUDI Wallet for identity verification. These methods are already in widespread use across Europe and can cover the majority of customers who do not yet have a wallet. The right combination depends on the sector, the required assurance level, and the countries your customers come from.
Common alternatives include:
- National eIDs such as DigiD in the Netherlands, ID Austria, or AltID in Denmark, which provide government-issued digital identification
- Bank IDs such as Swedish BankID or Norwegian BankID, which are separate systems operating independently in each country
- Identity documents such as passports or national identity cards, verified through document scanning and NFC chip reading
- Video-based identity verification, where an agent or automated system checks a document and the person presenting it
- Knowledge-based or credential-based login for lower-assurance use cases where full identity verification is not required
One important consideration is assurance level. The EUDI Wallet is issued at the high assurance level. Many existing verification methods do not automatically reach that level. If your regulatory context requires high assurance, such as under strong customer authentication rules in financial services, you need to verify that your alternative methods meet that standard. Accepting a lower-assurance method as a substitute for a high-assurance wallet check is a compliance risk, not just a technical choice.
Are businesses legally required to accept non-wallet identity methods?
There is no general legal obligation under eIDAS 2.0 that forces businesses to accept specific non-wallet identity methods. The regulation focuses on the obligation to accept certified EUDI Wallets, not on mandating a particular set of alternatives. However, sector-specific rules, national law, and anti-money laundering regulations may require businesses to offer identity verification options that work for all customers, including those without a wallet.
The private sector acceptance obligation under article 5f of eIDAS 2.0 applies from 24 December 2027. It covers regulated sectors where strong user authentication is legally or contractually required: banking and financial services, healthcare, telecoms, energy, transport, education, social security, water, postal services, digital infrastructure, and digital services. Very large online platforms designated under the Digital Services Act are also included. 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.
That obligation is about accepting wallets, not about replacing them. But article 5a of the regulation makes clear that wallet use is voluntary and that no one may be disadvantaged for not having one. In practice, this means businesses in regulated sectors need a compliant path for customers who present a wallet and a compliant path for those who do not. The non-wallet path must still meet the assurance and compliance requirements of the applicable sector rules.
For businesses in financial services or healthcare, the AML Regulation applying from July 2027 adds another layer. Whether an institution may rely on identity verification carried out elsewhere is determined by the AMLR and sector-specific rules, not by eIDAS. The wallet provides the mechanism; the legal basis for relying on it sits in AML law.
How can businesses build an identity flow that works with and without the EUDI Wallet?
Businesses can build a wallet-optional identity flow by designing a single onboarding or authentication journey with two parallel tracks: one for customers presenting a certified EUDI Wallet and one for customers using alternative identity methods. The key is to define the required assurance level and compliance outcome first, then map which methods on each track can meet it.
A practical approach follows these steps:
- Define the required assurance level for each use case, based on regulatory requirements and the sensitivity of the service. This determines which methods are acceptable on both tracks.
- Map your current customer base by country and likely wallet availability. This tells you which alternative methods need to be prioritised and for which markets.
- Select alternative methods that meet the assurance level for each market. National eIDs, bank IDs, and document verification are the most common choices.
- Design a unified user journey where the customer chooses their identification method at the start, and the back-end handles the verification logic for each path.
- Register as a relying party under CIR (EU) 2025/848 before requesting wallet data. Registration is required before any wallet interaction and must specify exactly which attributes you will request for each intended use. Requesting more than registered is grounds for revocation.
- Test both tracks before go-live, including edge cases such as customers switching devices or returning with a different wallet instance.
One practical point worth noting: do not link a customer record to a wallet unit identifier. The same person may return with a different wallet unit after changing devices, and attestations are reissued rather than copied. Build your customer dossier around stable identity attributes instead.
What assurance level risks come with non-wallet alternatives?
The main assurance level risk with non-wallet alternatives is that many commonly used methods do not reach the high assurance level that the EUDI Wallet provides by design. If a regulated use case requires high assurance and a business accepts a method that only meets substantial or low assurance, that gap creates a compliance exposure. This is especially relevant in financial services, healthcare, and government services.
Assurance levels under eIDAS are defined as low, substantial, and high. The EUDI Wallet operates at the high level. Many national eIDs and bank IDs operate at substantial assurance. Password-based or knowledge-based methods typically sit at low assurance. The level matters because regulators and auditors will ask whether the method used was appropriate for the transaction or service in question.
There is also a verification quality risk. When a customer presents an EUDI Wallet attestation, verification involves three checks: the issuer’s signature against the national trusted list, the revocation status of the attestation, and the wallet unit attestation confirming the presenting wallet runs on a certified wallet solution. Alternative methods have their own verification chains, but they are not always as structured or as easy to audit. Businesses should document how each alternative method is verified and what assurance level it delivers, so that decision is traceable if questioned later.
A further consideration applies to government services and other contexts where cross-border identity matching is relevant. Alternative methods may not carry the same cross-border recognition as a certified EUDI Wallet, which is designed for interoperability across all Member States.
When should businesses start preparing for wallet-optional identity journeys?
Businesses should start preparing now. The public sector deadline of 24 December 2026 is already the current reference point, and the private sector acceptance obligation under article 5f follows on 24 December 2027. That leaves regulated businesses roughly one year to have compliant identity flows in place, including both wallet acceptance and a working alternative path for customers who do not have one.
The pressure does not come from eIDAS alone. The AML Regulation applies from July 2027, five months before the private sector wallet acceptance deadline. Businesses in financial services and other AML-regulated sectors will need to align their identity verification approach with both frameworks at the same time. Starting that alignment late makes both harder.
Registration as a relying party under CIR (EU) 2025/848 must happen before a business can request wallet data. That registration process takes time and requires a clear picture of which attributes are needed for which use cases. Businesses that have not yet mapped their identity requirements will need to do that work before they can register, which adds to the preparation timeline.
For organisations in education or other sectors where the deadline pressure feels less immediate, the practical argument for early preparation is integration lead time. Building a wallet-optional identity flow into existing systems is not a one-day task, and doing it under deadline pressure increases the risk of gaps in the non-wallet track that affect real customers.
How the ID Connector supports wallet-optional identity journeys
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 businesses building wallet-optional flows, the ID Connector handles the identity layer on both tracks through one connection. Concretely, it covers:
- Acceptance of 27 or more certified European wallets through a single interface, with trust management handled automatically
- Verification of identity attributes that arrive cryptographically signed by the issuing party, so the data is already verified when it reaches your business process
- Support for national eIDs, bank IDs, and identity documents alongside wallet-based identification, so the same integration serves customers with and without a wallet
- Wallet-based login at the highest assurance level, integrated into the login flow you already run
- Qualified signing in one session, once identity is established, with the signature produced via a qualified trust service provider
- Reuse of verified identity data across interactions, so customers do not repeat the same verification step unnecessarily
The ID Connector is used by organisations in financial services, healthcare, pharmaceuticals, and government, where both regulatory compliance and a smooth customer experience are required. Contact TrustTech to discuss how the ID Connector fits your identity flow.