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How does the EUDI Wallet support the eIDAS 2.0 regulation?

European passport and national ID card on marble surface beside a smartphone showing a digital wallet interface, EU blue and gold tones.

The EUDI Wallet is the practical tool through which eIDAS 2.0 delivers on its core promise: a single, secure digital identity that works across all EU Member States. Where eIDAS 2.0 sets the legal and technical framework, the European Digital Identity Wallet is the implementation that puts those rules into action for citizens, residents, and businesses alike. The sections below answer the most common questions organizations have about how the two relate and what they need to do to prepare.

What requirements of eIDAS 2.0 does the EUDI Wallet directly fulfill?

The EUDI Wallet directly fulfills the eIDAS 2.0 requirement that every EU Member State must provide at least one certified digital identity wallet to all citizens, residents, and businesses by 24 December 2026. It also satisfies the regulation’s demands for cross-border recognition, high assurance levels, and support for both public and private sector use cases under a single harmonized framework.

Under the original eIDAS regulation, Regulation (EU) 910/2014, Member States could notify their national eID schemes, but there was no obligation to do so. This created a fragmented landscape where some countries had strong digital identity infrastructure and others had almost none. eIDAS 2.0, Regulation (EU) 2024/1183, amends Regulation (EU) 910/2014 and changes that fundamentally. The regulation mandates that each Member State provide a wallet that meets common technical requirements. The European Commission adopts implementing acts that contain the legally binding technical and security requirements. The Architecture and Reference Framework provides the technical elaboration of those requirements. This ensures that a wallet issued in one country is designed to be recognized and accepted in another, once the relevant certification and notification steps are complete.

The wallet also fulfills the regulation’s requirements around qualified electronic signatures, electronic attestations of attributes, and interoperability with trust services. In practice, this means the EUDI Wallet is a complete trust infrastructure tool that can carry verified credentials, enable legally binding signatures, and support a wide range of digital interactions. Governance is a shared responsibility: the European Commission manages the legal framework and adopts implementing acts, Member States provide or mandate wallet solutions and supervise actors within their jurisdiction, national competent authorities handle certification and notification, wallet providers operate the wallets, and qualified trust service providers, issuers, and relying parties each play defined roles within the framework.

How does the EUDI Wallet store and share identity data?

The EUDI Wallet stores identity data as verifiable digital credentials that are cryptographically secured and tied to the user’s identity. When a user wants to share information, they select exactly which data to disclose, and that data is transmitted directly to the receiving party in a verified and tamper-evident format.

Think of the wallet as a secure digital container. Inside it, users can hold a wide range of documents and credentials: a national identity card, a driving licence, educational qualifications, professional certifications, healthcare data, and more. Each credential is issued by a trusted source, such as a government authority or a recognized institution, and is cryptographically signed to prove its authenticity.

Sharing works through a selective disclosure mechanism. When a user needs to prove their age to access a service, for example, they do not need to share their full identity document. The wallet allows them to confirm only that they are above a certain age, without revealing their date of birth, address, or any other personal detail. This is a significant improvement over physical documents, which always expose more information than is strictly needed.

What is the difference between the EUDI Wallet and existing national eID schemes?

The key difference is scope and obligation. Existing national eID schemes vary widely across Member States and are not always accepted outside their home country. The EUDI Wallet is built on a standardized framework across the EU, legally required to be provided by every Member State, and must be accepted by public sector services throughout the EU from 24 December 2026. For regulated private sector organizations in the sectors covered by Article 5f of the regulation, where strong user authentication is required by law or contract, mandatory acceptance follows on 24 December 2027.

Some countries, such as those in the Nordic and Baltic regions, already have mature national digital identity systems with high adoption rates. However, an existing national eID system is not automatically the same as an EUDI Wallet. A national wallet must be certified and notified under the eIDAS 2.0 framework before it qualifies as an EUDI Wallet. Other countries are still developing their digital identity infrastructure. The current situation means that a business operating across multiple EU countries may need to support several different national eID schemes, each with different technical interfaces and assurance levels.

The EUDI Wallet framework changes this by introducing a common standard. Once wallets are certified, notified, and relying parties have completed the applicable national registration steps, organizations can connect to a single framework instead of managing multiple integrations. The wallet also extends functionality beyond traditional eID schemes by supporting electronic attestations of attributes, meaning it can carry far more than just a basic identity credential. It can hold professional qualifications, health data, and other verified information that national eID schemes typically do not support. Cross-border interoperability is designed into the framework, but not every use case will be immediately available in every Member State from day one, and sector-specific legislation in each country continues to apply.

Which sectors are required to accept the EUDI Wallet?

Under eIDAS 2.0, certain categories of services are legally required to accept the EUDI Wallet. Public sector digital services must accept the wallet from 24 December 2026. For regulated private sector organizations, the mandatory acceptance obligation takes effect on 24 December 2027, where strong user authentication is required by law or contract under Article 5f of the regulation. The sectors subject to this private-sector obligation include banks and financial institutions, healthcare providers, telecommunications operators, energy companies, transport services, educational institutions, social security bodies, drinking water providers, postal services, digital infrastructure providers, and digital service providers. Very large online platforms with more than 45 million users in the EU are also covered by Article 5f, under a separate provision: for those platforms, the obligation applies where the platform requires user authentication, on a voluntary request from the user and for the minimum necessary data.

Micro and small enterprises, defined as organizations with fewer than 50 employees and an annual turnover or balance sheet total not exceeding 10 million euros, are exempt from the mandatory acceptance obligation.

The sectors where acceptance is mandated reflect the areas where secure digital identity has the most immediate impact. For financial services, the wallet supports identity verification for account opening and strong customer authentication. For healthcare, it enables secure access to patient records and cross-border health services. For government services, it simplifies access to public administration across all Member States.

The large-scale pilot programs tested these use cases across the following areas:

  1. Government services: Applying for official documents, filing taxes, and accessing social security information
  2. Banking: Verifying identity when opening an account online, removing the need to repeatedly submit personal documents
  3. Telecommunications: Proving identity for SIM card registration, reducing fraud for mobile operators
  4. Healthcare: Accessing medical records and health services across borders
  5. Education: Sharing academic credentials and qualifications in a verified digital format
  6. Travel: Testing digital travel credentials for cross-border movement
  7. Payments: Authorizing transactions using wallet-based identity and authentication

Organizations in financial services and healthcare in particular should treat wallet acceptance as a regulatory requirement they need to plan for now.

How does the EUDI Wallet protect user privacy under eIDAS 2.0?

The EUDI Wallet protects user privacy through a combination of selective disclosure, user approval, and a design principle that prevents unnecessary data sharing. Under eIDAS 2.0, the wallet is specifically required to ensure that users remain in control of what they share, with whom, and for how long. No data is shared without explicit user action.

Several privacy-by-design principles are built into the wallet architecture:

  • Selective disclosure: Users share only the specific attributes needed for a transaction, not their full identity document
  • No central tracking: The wallet architecture is designed to prevent any single party, including the wallet provider, from tracking all of a user’s interactions
  • User approval: Every data sharing event requires active confirmation from the user
  • Minimal data exposure: Services can only request the data they are entitled to receive, not everything available in the wallet
  • Pseudonymous identifiers: In some use cases, the wallet can present a pseudonymous identifier rather than a full identity, reducing the risk of profiling

It is worth noting that the wallet dashboard is a tool for the user to review their own interactions. It is not a logging facility operated by the wallet provider.

This approach addresses a real limitation of physical identity documents. When you hand over a passport or ID card, you expose your full name, date of birth, address, and other details, even if the service only needed to confirm your nationality. The EUDI Wallet makes it technically and legally possible to prove what needs to be proven without revealing anything more.

Relying parties have their own obligation under the GDPR to establish a lawful basis for processing the data they receive. For identity verification in regulated contexts such as KYC, that basis is typically a legal obligation. For health data, an additional condition under Article 9(2) GDPR is required. Approving a data request in the wallet is a separate act from providing consent as a GDPR legal basis.

When do organizations need to be ready for the EUDI Wallet?

Member States are legally required to make the EUDI Wallet available to citizens and businesses by 24 December 2026. Public sector organizations must be ready to accept the wallet by that same date. Regulated private sector organizations in the sectors covered by Article 5f of the regulation must meet the mandatory acceptance obligation by 24 December 2027. These are legal deadlines, the latest permissible dates, not predictions of when every national wallet will have reached the same level of maturity or when every cross-border use case will be fully operational throughout Europe. Practical interoperability and national rollout are likely to develop in phases, and organizations should not wait for a single European go-live moment before starting their preparation.

The timeline is tighter than many organizations realize. Four large-scale pilot programs ran from April 2023 to 2025, covering government services, banking, telecommunications, mobile driving licences, qualified remote signing, e-prescriptions, digital travel credentials, payments, education, and social security across 26 Member States, Norway, Iceland, and Ukraine. A second wave of pilots started in 2025, with WE BUILD focusing on business wallets and payments, and APTITUDE covering travel, ticketing, vehicle registration, and payments. The revised eIDAS regulation entered into force on 20 May 2024. The first implementing acts, covering technical specifications, security standards, and interoperability rules for the EUDI Wallet, were adopted by the end of 2024. A second wave of technical implementing acts, covering areas such as qualified electronic archiving, validation, certificates, and qualified trust service providers, was published in 2025. On 6 May 2025, the Commission adopted CIR (EU) 2025/848, which sets out the registration requirements for relying parties. The technical groundwork is largely set, though certification and notification of individual national wallets will follow their own national timelines.

For organizations, the practical implication is that wallet readiness is a current compliance and technology challenge. Organizations that wait for full national rollout before starting their integration work risk falling behind quickly. The earlier an organization understands the technical requirements and maps them to its existing systems, the smoother the transition will be. Under CIR (EU) 2025/848, relying parties must register with the national competent authority of their Member State of establishment before they can request wallet data. Registration covers each intended use and specifies which attributes and attestations will be requested. Engaging with the relevant national authority early is therefore an important step.

Government agencies and public sector bodies in particular face early obligations, as government services are among the first categories required to accept the wallet from 24 December 2026. Regulated private sector organizations, especially those in the sectors covered by the mandatory acceptance obligation under Article 5f, should use this period to audit their identity verification processes, assess their current infrastructure, and identify where wallet integration will be needed ahead of the 24 December 2027 deadline.

How TrustTech helps organizations prepare for the EUDI Wallet

Navigating the technical and regulatory complexity of eIDAS 2.0 and the EUDI Wallet is not straightforward, especially for organizations that are still running identity processes built for a different era. TrustTech’s 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.

TrustTech’s platform and solutions are designed around the eIDAS 2.0 framework and support organizations with:

  • Wallet acceptance across every certified European wallet solution, regardless of the issuing Member State
  • Verification against national trusted lists, brought together in the EU List of Trusted Lists, and revocation status checks
  • Validation of wallet unit attestations to confirm that a presenting wallet runs on a certified wallet solution
  • Monitoring of registered attribute scope so that only data covered by the relying party’s registered intended use is requested
  • Reuse of verified identity data across interactions, reducing repeated verification for users and organizations
  • Qualified electronic signatures via a connected qualified trust service provider, with a complete audit trail

Organizations in financial services, healthcare, and government can connect their existing identity verification processes to the ID Connector and meet their wallet acceptance obligations without rebuilding their infrastructure from the ground up. Get in touch with TrustTech to discuss what EUDI Wallet readiness looks like for your organization.