Under eIDAS 2.0, stateless persons face a genuine gap in coverage. The regulation amends Regulation (EU) 910/2014 and is built around national identity systems. Stateless individuals, by definition, fall outside those systems. Their access to digital identity tools such as the EUDI Wallet depends heavily on how individual EU Member States choose to handle their situation at a national level, and the regulation itself does not provide a uniform solution.
This article walks through how eIDAS 2.0 defines the problem, what documents stateless persons can use, whether the EUDI Wallet is accessible to them, and what all of this means for organizations that need to verify their identities.
Who counts as a stateless person under EU law?
Under EU law, a stateless person is someone who is not considered a national by any country under the operation of its law. This definition draws on the 1954 UN Convention Relating to the Status of Stateless Persons, which the EU and its Member States broadly recognize. Stateless persons may reside legally within the EU but hold no national citizenship that would give them automatic access to a national eID scheme.
It is important to distinguish between different groups. Refugees, asylum seekers, and stateless persons are legally distinct categories, even though they may overlap in practice. A person can be a recognized refugee while also being stateless. Conversely, someone can hold a travel document issued by a country without being a recognized national of that country.
Within the EU, stateless persons may hold a variety of legal statuses depending on the Member State where they reside. Some have long-term residency permits, others have subsidiary protection status, and some remain in more precarious administrative situations. This diversity makes it difficult to apply a single rule across all cases, and eIDAS 2.0 does not attempt to do so.
What identity documents can stateless persons use under eIDAS 2.0?
Stateless persons can use documents issued to them by their country of residence, such as stateless travel documents, alien passports, or national residence permits, as the basis for identity verification under eIDAS 2.0. The regulation does not restrict identity verification to EU national identity cards or passports. What matters is whether a document can support a verified identity claim at the required assurance level.
The relevant document types that may apply include:
- Convention Travel Documents issued under the 1954 Stateless Persons Convention
- Alien passports or travel documents issued by a Member State to non-nationals residing there
- National residence permits or cards that include biometric data
- Refugee travel documents issued under the 1951 Geneva Convention, where applicable
Whether any of these documents can be used to establish a digital identity at a high assurance level depends on the issuing Member State’s national rules. eIDAS 2.0 sets assurance levels (low, substantial, and high) and defines what evidence is required at each level, but it leaves the specific document acceptance criteria to national implementations. The legally binding requirements are set out in the implementing acts adopted by the European Commission. The Architecture and Reference Framework provides the technical elaboration of those requirements but is not itself legislation. A residence permit with a chip and biometric data may meet the requirements for a high assurance level in one country but not in another.
This is a practical challenge. Organizations that need to verify identities at a high assurance level may find that the documents available to stateless persons do not consistently meet that bar across different Member States.
Can stateless persons access the EUDI Wallet?
Access to the EUDI Wallet for stateless persons is not guaranteed by the regulation itself. eIDAS 2.0, Regulation (EU) 2024/1183, requires Member States to provide a wallet to all citizens, residents, and businesses. The word “residents” is significant, because it opens the door for stateless persons who hold legal residency in a Member State to potentially receive a wallet. However, the regulation does not explicitly define how Member States must handle stateless residents, leaving this to national discretion.
EUDI Wallet governance is a shared responsibility distributed across multiple actors. The European Commission manages the legal framework and adopts implementing acts. Member States are responsible for providing or mandating wallet solutions, certifying and notifying them, and supervising actors within their jurisdiction. The European Digital Identity Cooperation Group supports cooperation and cross-border alignment. National competent authorities, wallet providers, issuers of Person Identification Data and attestations, qualified trust service providers, and relying parties each carry distinct responsibilities within this structure. No single central European authority operationally manages all EUDI Wallets.
The EUDI Wallet is designed to store and present verified identity attributes, credentials, and attestations. For a stateless person to use one, they would first need a verified digital identity anchored to a national scheme. If their country of residence includes them in its national identity system and issues them a wallet, they could, in principle, use it with relying parties in other Member States where the wallet has been certified and notified. If not, they are excluded from the ecosystem entirely, regardless of how long they have lived legally in a Member State.
The four large-scale pilots that ran from April 2023 to 2025 focused primarily on standard citizen and resident use cases. The POTENTIAL consortium, for example, covered government service access, bank account opening, SIM registration, mobile driving licences, remote qualified signing, and e-prescriptions. Edge cases involving stateless persons were not prominently addressed in publicly available pilot findings, which reflects the broader gap in the regulatory framework.
How do Member States differ in handling stateless identity under eIDAS 2.0?
Member States differ significantly in how they treat stateless persons within their national identity systems, and these differences carry over directly into eIDAS 2.0 implementation. Some countries have well-developed frameworks for issuing biometric residence documents to stateless persons that are compatible with digital identity infrastructure. Others have minimal provisions, leaving stateless individuals without a path to digital identity at all.
Before eIDAS 2.0, the original eIDAS regulation already exposed this fragmentation. Countries were required to recognize each other’s notified eID schemes, but there was no obligation to create a scheme in the first place, and no requirement to include stateless residents. eIDAS 2.0 tightens many of these gaps for citizens and typical residents, but the situation for stateless persons remains subject to national policy choices.
It is also important to distinguish between different stages of national rollout. The legal deadline for Member States to meet their wallet obligations is 24 December 2026. That deadline is the latest date by which Member States must comply, not a predicted launch date, and it does not guarantee that every national wallet will have reached the same level of maturity by that date, or that every possible cross-border use case will be fully operational throughout Europe from that point. Practical interoperability and national rollout are expected to develop in phases, and organizations should plan accordingly.
The following factors vary from one Member State to another:
- Whether stateless residents are included in the national eID scheme at all
- Which documents are accepted as the basis for identity proofing at each assurance level
- Whether a wallet will be issued to stateless residents alongside citizens
- How identity attributes are linked when a person lacks a national identification number
- What fallback processes exist for digital services when wallet-based verification is not available
Organizations operating across multiple EU countries should not assume that a stateless person who has a verified digital identity in one Member State will automatically be recognized in another. The EUDI Wallet framework is designed so that a certified wallet from one Member State can be used with an appropriate relying party in another Member State, but this does not mean that every use case will immediately be available everywhere, that national registration requirements disappear, or that sector-specific legislation ceases to apply. Cross-border recognition under eIDAS 2.0 applies to notified schemes, and if a stateless person’s identity is only provisionally or partially included in a national scheme, that recognition may not extend across borders.
What does this mean for organizations verifying stateless persons’ identities?
For organizations that regularly verify the identities of stateless persons, eIDAS 2.0 creates both an opportunity and a compliance challenge. The regulation’s emphasis on interoperability and reusable identity could reduce friction for verified stateless individuals over time. The challenge is that the current framework does not guarantee consistent, high-assurance digital identity verification for this group across all Member States.
Organizations in financial services, healthcare, and other regulated sectors are required to verify identity at specific assurance levels under their own regulatory obligations, such as AML, KYC, and healthcare data regulations. When a stateless person cannot access a wallet or lacks a document that meets the required assurance level, organizations need a fallback process that is both compliant and practical.
When verifying identity against a document or a wallet-presented attestation, organizations should be aware that verification involves more than a single check. Confirming the issuer’s signature against the relevant national trusted list, checking revocation status via the issuer’s status information, and validating the wallet unit attestation to confirm that the presenting wallet runs on a certified wallet solution are three distinct steps. National trusted lists are brought together in the EU List of Trusted Lists. Under CIR (EU) 2025/848, adopted on 6 May 2025, relying parties must register with the national authority of their Member State of establishment before requesting wallet data, and must specify per intended use which attributes and attestations they will request.
Key considerations for organizations include:
- Reviewing which documents issued to stateless persons are accepted within your identity verification process and at what assurance level
- Understanding the national rules in each Member State where you operate, since document acceptance and wallet eligibility vary
- Building flexible verification flows that can accommodate both wallet-based and document-based identity proofing
- Ensuring audit trails and compliance documentation are maintained when non-standard documents are used
The regulatory landscape will continue to evolve as Member States finalize their EUDI Wallet implementations, as certification and notification processes progress, and as guidance on edge cases such as stateless identity becomes clearer. Organizations that build adaptable digital identity solutions now will be better positioned to remain compliant as the framework matures across its different rollout phases.
How TrustTech helps with identity verification for stateless persons
Verifying the identity of stateless persons under eIDAS 2.0 is not a problem that resolves itself. The regulatory gaps are real, the national differences are significant, and the compliance stakes are high for organizations in regulated sectors such as financial services, healthcare, and government.
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.
With the ID Connector, your organization can:
- Build verification flows that support both wallet-based identity and document-based identity proofing, so no user group falls through the cracks
- Handle eIDAS 2.0 compliance by design, including support for edge cases such as stateless persons and non-standard identity documents
- Reuse verified identity data across onboarding, KYC, and compliance processes, reducing friction for verified individuals regardless of their document type
- Operate across EU Member States with infrastructure built for cross-border interoperability and regulatory alignment, including verification against national trusted lists and revocation status checks
- Connect every step from first verification to qualified electronic signing via a connected QTSP, with a complete audit trail for compliance purposes
Whether you are in finance, government, healthcare, or another regulated sector, the ID Connector provides the infrastructure to handle digital identity verification securely and at scale, including the most complex cases. Get in touch with TrustTech to discuss how the ID Connector can help your organization prepare for the realities of eIDAS 2.0.