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 unpack exactly 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 issue at least one EUDI Wallet solution to its citizens by the deadlines 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 build, certify, and make available a wallet that meets the technical and security requirements set out in the Architecture and Reference Framework (ARF). Citizens then have the option to request and use that wallet if they choose to.

Private sector parties and public authorities in certain sectors also carry obligations, but these relate to accepting the wallet rather than issuing it. The European Commission, together with the European Digital Identity Cooperation Group, oversees the development of common standards and technical specifications to ensure that wallets issued by different member states are interoperable across borders.

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. But 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. These are primarily large public and private sector organisations operating in regulated domains. The sectors covered by mandatory acceptance obligations 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.
• Government and public administration: Public authorities offering digital public services are required to accept the wallet for citizen identification.
• Telecommunications: Providers offering mobile and internet services fall within the scope of mandatory relying parties.
• Transport: Major transport operators and platforms are expected to accept wallet-based identity credentials.
• Education: Institutions issuing or verifying educational credentials and qualifications are included.

For organisations in these sectors, preparing for wallet acceptance is not optional. They need to integrate with the wallet ecosystem, update their identity verification flows, and ensure their systems can process verifiable credentials. Financial services organisations in particular face intersecting obligations, since wallet acceptance aligns with existing AML, KYC, and strong customer authentication requirements under PSD2 and upcoming AMLR frameworks. Similarly, healthcare providers will need to align wallet integration with their existing patient identity and data governance processes.

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 organically 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 the eIDAS 2.0 regulation, which entered into force in May 2024. Member states have a 24-month implementation window to issue at least one certified wallet solution to their citizens, meaning the first national wallets are expected to be available by mid-2026. In 2026, several member states are already in advanced stages of piloting and preparing for launch.

The rollout is happening in phases:

1. Large-scale pilots (2023 to 2025): The European Commission funded four large-scale pilot consortia to test the wallet in real-world scenarios across sectors including finance, healthcare, travel, and education. These pilots informed the technical specifications and identified implementation challenges.
2. National wallet launches (2025 to 2026): Member states are issuing or certifying their national wallet implementations. Some countries, such as Denmark with its AltID initiative, are already signalling their approach and providing early signals for how national wallets will be positioned.
3. Mandatory acceptance by relying parties (2027 and beyond): Once national wallets are available, relying parties in the sectors listed above have a further period to integrate and begin accepting wallet-based credentials. Full compliance obligations for the private sector are expected to phase in over 2027 and 2028.

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. For organisations that need to accept the wallet, now is the right time to assess readiness and begin integration planning rather than waiting for formal deadlines to arrive.

How TrustTech helps organisations prepare for the EUDI Wallet

Understanding the rules around the European Digital Identity Wallet is one thing. Translating them into working systems and compliant processes is another. TrustTech supports organisations across regulated sectors in doing exactly that, whether they are preparing to accept wallet credentials, integrate verifiable credentials into onboarding flows, or align their existing identity infrastructure with eIDAS 2.0 requirements.

Working with TrustTech, organisations can expect:

• A clear assessment of where your current identity and compliance infrastructure stands relative to EUDI Wallet requirements
• Technical integration support for accepting wallet-based credentials within your existing systems
• Guidance on reusable identity flows that reduce friction for users while meeting regulatory obligations
• Expertise across finance, healthcare, government, and other regulated sectors where wallet acceptance will be mandatory
• An eIDAS 2.0-ready platform built to connect identity verification, qualification checks, and digital signatures in a single trusted flow

If your organisation is working through what the EUDI Wallet means in practice, get in touch with TrustTech to discuss your situation and explore how we can help you get ready.