The EU Digital Identity Wallet is not mandatory for citizens. Under eIDAS 2.0, every EU member state is required to offer the wallet to its citizens, but using it remains entirely voluntary. Citizens can choose whether or not to adopt it, and no one can be forced to use the EUDI Wallet as a condition for accessing services or employment. The sections below explain who is obligated to do what, which sectors must accept the wallet, and when it will be available across Europe.
Who is actually required to provide the EU Digital Identity Wallet?
Under eIDAS 2.0, EU member states are the parties required to act. Every country in the European Union is obligated to provide at least one EUDI Wallet solution to its citizens by the legal deadline set out in the regulation. The obligation falls on governments, not on individuals. Citizens are the intended beneficiaries, not the parties carrying a legal duty.
This distinction matters. The regulation creates a supply-side obligation: member states must ensure that wallet solutions are certified, notified, and made available in a way that meets the legally binding requirements set out in the implementing acts adopted under eIDAS 2.0. The Architecture and Reference Framework (ARF) provides the technical elaboration of those requirements. Citizens then have the option to request and use a wallet if they choose to.
Governance under eIDAS 2.0 is a shared responsibility across multiple actors. 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. The European Digital Identity Cooperation Group supports cooperation and cross-border alignment between member states. National competent authorities, wallet providers, issuers of Person Identification Data and attestations, qualified trust service providers, and relying parties each carry distinct roles within this structure. No single central European authority operationally manages all EUDI Wallets.
Private sector parties and public authorities in certain sectors also carry obligations, but these relate to accepting the wallet rather than issuing it.
Can citizens be forced to use the EUDI Wallet by employers or services?
No. eIDAS 2.0 explicitly prohibits making the use of the European Digital Identity Wallet a mandatory condition for accessing services. Employers cannot require employees to use it, and service providers cannot refuse access to users who choose not to. The principle of voluntary use is built into the regulation to protect individual autonomy.
This protection applies in both the public and private sectors. A bank cannot tell a customer that the EUDI Wallet is the only accepted form of identification. A government portal cannot block access for citizens who prefer alternative identity verification methods. The wallet is designed to be an additional option, not a replacement that eliminates other routes.
The reasoning behind this is straightforward. Digital inclusion is a core concern for European policymakers. Not every citizen has equal access to smartphones or digital literacy, so forcing wallet adoption would risk excluding vulnerable groups. The regulation therefore ensures that wherever the wallet is accepted, equivalent non-digital alternatives must remain available.
What happens if a citizen chooses not to use the EUDI Wallet?
If a citizen decides not to use the EUDI Wallet, nothing changes about their ability to access services. They can continue using existing identity documents, national eID systems, and other accepted verification methods. The wallet adds a new option without removing existing ones.
In practice, this means citizens who opt out will not lose access to banking, healthcare, government services, or any other regulated sector. Service providers that are required to accept the EUDI Wallet must still support alternative identification methods for users who do not have or want a wallet.
Over time, wallet adoption may become the more convenient route for many interactions, particularly for cross-border services where fragmented national systems currently create friction. Convenience is not the same as compulsion. Citizens retain the right to manage their identity in the way that suits them best, and the regulation is designed to make the wallet attractive rather than unavoidable.
Which sectors are required to accept the EU Digital Identity Wallet?
eIDAS 2.0 identifies a set of relying parties that are required to accept the EUDI Wallet for identity verification and attribute sharing. The acceptance obligation applies in two phases, with different deadlines for public and private sector organisations.
From 24 December 2026, public authorities must accept notified EUDI Wallets for online services that require electronic identification. From 24 December 2027, the mandatory acceptance obligation under Article 5f of eIDAS 2.0 applies to relying parties in regulated private sectors where strong user authentication is required by law or contract. The sectors covered by that private sector obligation include:
- Financial services: Banks and financial institutions subject to strong customer authentication and KYC requirements must accept the wallet for customer identification and onboarding.
- Healthcare: Public healthcare providers and systems handling patient identity and health data are included in the scope of mandatory acceptance.
- Telecommunications: Providers offering mobile and internet services fall within the scope of mandatory relying parties.
- Energy: Energy sector operators within the regulated scope are included.
- Transport: Major transport operators and platforms are required to accept wallet-based identity credentials.
- Education: Institutions issuing or verifying educational credentials and qualifications are included.
- Social security, drinking water, postal services, digital infrastructure, and digital services are also listed within the scope of the private sector obligation.
Very large online platforms (VLOPs) fall under a separate provision of Article 5f. For VLOPs, the obligation applies where the platform requires user authentication, on the voluntary request of the user and for the minimum necessary data. The condition relating to legally or contractually required strong authentication does not apply to VLOPs.
Micro and small enterprises are exempt from the private sector acceptance obligation. The exemption covers organisations with fewer than 50 employees and an annual turnover or balance sheet total not exceeding 10 million euros.
Before a relying party can request wallet data, it must register with the national authority of its member state of establishment under CIR (EU) 2025/848, adopted on 6 May 2025. Registration is per intended use: the relying party specifies which attributes and attestations it will request, and the wallet checks each presentation request against that registered scope. A relying party does not choose a wallet provider. It must be able to accept every relevant notified wallet, regardless of which provider issued it.
It is also worth noting that a relying party does not automatically need a qualified trust service provider (QTSP) simply to accept the wallet. A QTSP becomes relevant in specific contexts, such as qualified electronic signing or the issuance of qualified electronic attestations of attributes (QEAAs).
Smaller businesses and organisations outside the listed sectors are not currently required to accept the wallet, though they may choose to do so voluntarily. The expectation is that wallet adoption will expand as more citizens use it and as the ecosystem matures.
When will the EU Digital Identity Wallet be available across Europe?
The timeline for the EUDI Wallet rollout is tied to eIDAS 2.0, which amends Regulation (EU) 910/2014 and entered into force on 20 May 2024. The legal deadline for member states to make at least one certified wallet solution available to their citizens is 24 December 2026. That deadline establishes a legal obligation. It is not a guarantee that every national wallet will reach the same level of maturity on that date, or that every possible cross-border use case will be fully operational throughout Europe from that moment. Practical interoperability and national rollout are expected to develop in phases, reflecting differences in existing digital identity infrastructure across member states.
The rollout is happening in distinct stages:
- Large-scale pilots (2023 to 2025): The European Commission funded four large-scale pilot consortia to test the wallet in real-world scenarios. The EWC consortium piloted Digital Travel Credentials, payments, and organisational digital identity. POTENTIAL covered government services, bank account opening, SIM registration, mobile driving licences, remote qualified signing, and e-prescriptions. NOBID focused on payments. DC4EU addressed education and social security. These pilots ran from April 2023 to 2025 and have concluded. A second wave of pilots started in 2025: WE BUILD focuses on business wallets and payments, and APTITUDE covers travel, ticketing, vehicle registration, and payments.
- National wallet certification and launch (2025 to 2026): Member states are working toward certifying and notifying their national wallet implementations ahead of the 24 December 2026 deadline. The status of individual national wallets varies by country and changes as development progresses. Organisations should consult current authoritative national sources. Where a country already operates a national digital identity system, that system is not automatically equivalent to a certified EUDI Wallet and the two should be distinguished.
- Mandatory acceptance by private relying parties (from 24 December 2027): Once national wallets are available and notified, relying parties in the regulated private sectors listed above must integrate and begin accepting wallet-based credentials by 24 December 2027. The first five core implementing acts were adopted at the end of 2024, starting the relevant 24-month period that leads to this deadline.
The pace of rollout will vary between member states depending on existing national digital identity infrastructure. Countries with mature eID systems are likely to move faster, while others may need more time to build the underlying technical and governance frameworks. There will not be a single European go-live moment at which everything becomes available simultaneously. For organisations that need to accept the wallet, assessing readiness and beginning integration planning now is more effective than waiting for formal deadlines to arrive.
How TrustTech helps organisations prepare for the EUDI Wallet
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 in financial services, healthcare, government, and other regulated sectors preparing for the acceptance obligations described above, the ID Connector handles the technical layer that makes wallet acceptance work in practice:
- Accepting wallet-based credentials and verifying issuer signatures against the relevant national trusted lists, which are brought together in the EU List of Trusted Lists (LOTL)
- Checking revocation status against issuer-provided status information
- Validating wallet unit attestations to confirm that the presenting wallet runs on a certified wallet solution
- Monitoring the registered attribute scope so that each presentation request stays within what the relying party has registered under CIR (EU) 2025/848
- Supporting reuse of verified identity data across onboarding and authentication flows
- Connecting to a qualified trust service provider for qualified signing where that is required
If your organisation is working through what the EUDI Wallet means in practice, get in touch with TrustTech to discuss your situation.