A wallet instance is the actual app installed and running on a user’s device, while a wallet solution is the certified software package that an approved provider makes available for that installation. Think of the wallet solution as the product, and the wallet instance as a single activated copy of that product used by one person.
Under eIDAS 2.0, this distinction carries direct implications for certification, liability, and how organizations manage compliance across potentially millions of users. The sections below unpack each concept and explain why the difference matters in practice.
How do wallet instances and wallet solutions relate to each other?
A wallet solution and a wallet instance exist in a parent-child relationship. The wallet solution is the certified, approved software that a wallet provider develops and maintains. A wallet instance is created every time a user installs and activates that solution on their device. One wallet solution can give rise to millions of wallet instances, each belonging to a different individual user.
The wallet solution sets the rules, security architecture, and certified capabilities. The wallet instance inherits those properties but operates independently on the user’s device. Changes to the wallet solution, such as a security update or a new feature, eventually flow down to all active instances, but each instance also has its own lifecycle, including activation, suspension, and revocation.
This layered structure is what allows the European Digital Identity Wallet to scale across an entire country or the whole EU while still being individually controlled by each citizen. The wallet provider manages the solution centrally; the user manages their own instance.
What exactly is a wallet solution under eIDAS 2.0?
A wallet solution under eIDAS 2.0 is the certified software package, including its backend infrastructure, that a recognized wallet provider offers to users. It is the entity that undergoes conformity assessment and receives official certification before it can be made available to the public. Without a valid certification, no wallet solution can be deployed in the EU.
The wallet solution must meet the requirements set out in the legally binding implementing acts adopted by the European Commission. The Architecture and Reference Framework (ARF) provides the technical elaboration of those requirements, defining standards for how the wallet handles cryptographic keys, how it communicates with relying parties, and how it protects user data.
Wallet solutions can be provided by governments directly or by private companies that have received official recognition from a Member State. Member States are responsible for certifying and notifying wallet solutions within their jurisdiction, and only solutions that have completed this process can be made available to users. This certification is what gives relying parties, such as banks, healthcare providers, and government agencies, the confidence to accept presentations from wallet instances built on that solution.
What exactly is a wallet instance under eIDAS 2.0?
A wallet instance under eIDAS 2.0 is the individual, device-bound installation of a certified wallet solution that belongs to a specific user. It is the operational unit: the app on a person’s smartphone that they use to store credentials, prove their identity, and share verified data with services. Each instance is unique to one person and one device.
When a user activates a wallet instance, several things happen:
- A unique cryptographic key pair is generated and bound to that specific device, held within the Wallet Secure Cryptographic Device that forms part of the wallet unit
- The instance receives a wallet unit attestation (WUA) that confirms it belongs to a valid, certified wallet solution
- The user can then request credentials, such as a digital driving licence or a qualified electronic attestation of attributes (QEAA), to be loaded into their instance
- The instance becomes the user’s personal trust anchor for all subsequent digital interactions
The user is in control of their wallet instance. They decide which credentials to store, what data to share, and with whom. This selective disclosure principle is one of the core privacy protections built into the EUDI Wallet framework. Each time a relying party requests data, the user approves that specific request individually.
Why does the distinction matter for compliance and implementation?
The distinction between wallet solution and wallet instance matters for compliance because certification applies to the solution, while liability and data control apply at the instance level. Organizations that interact with EUDI Wallets, whether as relying parties or credential issuers, need to understand both layers to design compliant processes.
For relying parties such as financial services firms or healthcare providers, accepting a presentation from a wallet instance is only valid if that instance belongs to a certified wallet solution. Verifying a wallet presentation involves three distinct checks: verifying the issuer’s signature against the relevant national trusted list, which is part of the EU List of Trusted Lists (LOTL); checking the revocation status of the credential using the issuer’s status information; and verifying the wallet unit attestation to confirm that the presenting wallet instance runs on a certified wallet solution. Only the first of these checks can be performed fully offline. It is also worth noting that relying party registration is governed by CIR (EU) 2025/848 of 6 May 2025, which requires each relying party to register with the national authority of its Member State of establishment before requesting wallet data. Registration is per intended use, specifying which attributes and attestations will be requested, and the wallet checks requests against that registered scope.
For organizations issuing credentials into wallets, understanding the instance layer is equally important. A credential is bound to a specific wallet instance. If that instance is revoked or suspended, the credential can no longer be used, even if the underlying wallet solution remains certified. Private keys associated with credentials do not leave the secure device, which means that when a user switches to a new device, credentials must be reissued rather than copied. This has direct consequences for credential lifecycle management.
From a broader implementation perspective, the two-layer model also affects how organizations in financial services and other regulated sectors design their onboarding and verification workflows. Systems need to be built to handle both the solution-level trust anchor and the instance-level binding.
Who is responsible for managing wallet instances versus the wallet solution?
Responsibility is distributed across several parties within the eIDAS 2.0 governance structure. The wallet provider is responsible for the wallet solution: its certification, its security, its updates, and its continued compliance with eIDAS 2.0. The user is responsible for their own wallet instance: activating it, keeping the device secure, and managing which credentials are stored and shared.
This division of responsibility has practical consequences across all parties involved:
- Wallet providers must maintain their certification continuously, push security updates to all active instances, and handle the revocation of wallet units that have been compromised or reported lost.
- Users must protect their device and authenticate themselves to access the wallet. If a device is lost or stolen, the user can request that their instance be suspended or revoked.
- Member States are responsible for providing or mandating wallet solutions, certifying and notifying them, and supervising wallet providers and other actors within their jurisdiction. The European Digital Identity Cooperation Group supports cross-border alignment and cooperation between Member States, while the European Commission manages the overarching legal framework and adopts implementing acts. No single central European authority operationally manages all EUDI Wallets.
- Relying parties must verify wallet unit attestations at the point of interaction, confirming that the instance they are dealing with belongs to a valid, certified solution. A relying party must be able to accept every relevant notified wallet, regardless of which provider issued it. Registration obligations remain tied to the applicable national framework under CIR (EU) 2025/848.
For organizations in government services that are both issuing credentials and accepting them, understanding where their responsibilities begin and end within this structure is essential for sound governance.
How does wallet attestation connect instances to the solution?
Wallet attestation is the cryptographic mechanism that links a wallet instance back to its certified wallet solution. When a wallet instance is activated, the wallet provider issues a wallet unit attestation (WUA), a signed digital statement confirming that this specific instance was created by a valid, certified wallet solution and that it meets the required security standards.
This attestation serves as the trust bridge in every interaction. When a user presents a credential to a relying party, the relying party verifies the wallet unit attestation to confirm that the instance presenting the credential is genuine and has not been tampered with or revoked. This check sits alongside issuer signature verification and revocation status checking as one of three distinct steps in a complete verification flow.
The attestation model also enables selective disclosure to work correctly. Because the instance’s keys are cryptographically tied to its attestation, the user can prove specific attributes without revealing unnecessary personal data, and the relying party can trust that the proof comes from a legitimate, certified environment.
For organizations building systems that accept EUDI Wallet presentations, handling wallet attestations correctly is a core part of the verification chain. Organizations looking at implementation resources will find that attestation handling is consistently highlighted as a critical integration point.
How the ID Connector supports wallet instance and wallet solution handling
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.
In the context of wallet instances and wallet solutions, the ID Connector handles the technical complexity that the two-layer model introduces, including:
- Validating wallet unit attestations at the instance level to confirm the presenting wallet runs on a certified wallet solution
- Verifying issuer signatures against the relevant national trusted lists, which are part of the EU List of Trusted Lists (LOTL)
- Checking credential revocation status using issuer-provided status information
- Enforcing the registered attribute scope so that only the attributes declared in the relying party’s registration under CIR (EU) 2025/848 are requested
- Supporting credential issuance processes that account for instance lifecycle events such as suspension and revocation, including reissuance when a user switches devices
- Integrating EUDI Wallet interactions into onboarding, authentication, and data exchange workflows for financial services, healthcare, pharma, and government
Organizations across regulated sectors that need to accept EUDI Wallet presentations or issue credentials into wallets can use the ID Connector to connect their existing systems to the EUDI Wallet ecosystem without rebuilding their infrastructure from the ground up. Explore TrustTech’s solutions to see how this works in practice, or get in touch to discuss your specific situation.