The eIDAS 2.0 pilot architecture is a structured technical and governance framework used to test the European Digital Identity Wallet (EUDI Wallet) at scale before its official rollout. It combines a reference implementation, a shared Architecture and Reference Framework (ARF), and four large-scale pilot consortia that involved over 350 organisations across 26 EU Member States plus Norway, Iceland, and Ukraine. This article explains what was tested, how the architecture works, and what the findings mean for organisations preparing for production deployment.
What did the Large Scale Pilots test in eIDAS 2.0?
The Large Scale Pilots tested whether the EUDI Wallet works reliably in real-world scenarios before it becomes mandatory across the EU. Launched in April 2023 and running through 2025, the pilots examined the wallet’s security, interoperability, and usability across everyday situations that European citizens and businesses encounter. They also collected structured feedback on the wallet’s reference implementation to inform the final production design.
The pilots covered 11 concrete use cases, including:
- Accessing government services such as applying for a passport, filing taxes, or retrieving social security information
- Opening a bank account online without repeated identity submissions
- SIM card registration to reduce fraud for mobile network operators
- Cross-border payments using wallet-based authorisation
- Sharing educational credentials and employment qualifications across borders
- Digital travel credentials for EU-wide mobility
Four distinct pilot consortia ran these tests. The POTENTIAL Consortium piloted government services, opening a bank account, SIM registration, mobile driving licences, remote qualified signatures, and electronic prescriptions. The EU Digital Identity Wallet Consortium (EWC) focused on digital travel credentials, payments, and organisational digital identity. The NOBID Consortium, a group of Nordic and Baltic countries joined by Italy and Germany, piloted wallet-based payment authorisation. The DC4EU Consortium covered educational credentials and social security. Each consortium blended public and private sector expertise and was co-funded by the European Commission through grants under the DIGITAL Europe Programme.
A second wave of pilots started in 2025. The WE BUILD pilot focuses on business wallets and payments. The APTITUDE pilot covers travel, ticketing, vehicle registration, and payments.
What components make up the eIDAS 2.0 pilot architecture?
The eIDAS 2.0 pilot architecture is built around three core components: the Architecture and Reference Framework (ARF), the EUDI Wallet prototype, and the Common Toolbox. Together, these form the technical backbone that all pilot consortia worked from, ensuring that different implementations remain interoperable and compliant with the regulation.
The Architecture and Reference Framework (ARF)
The ARF was developed following a European Commission Recommendation issued on 3 June 2021, which called on Member States to collaborate on a shared technical foundation. The European Digital Identity Cooperation Group (EDICG), formerly known as the eIDAS Expert Group, supports cooperation and cross-border alignment among Member States and maintains the ARF. The ARF’s role is to provide the technical elaboration of the requirements set out in the legally binding implementing acts adopted by the Commission. The ARF defines the protocols, interfaces, data formats, and certification requirements that all wallet solutions must conform to. The current version of the ARF reflects the adopted Commission Implementing Regulations, which cover everything from personal identification data (PID) and electronic attestations of attributes to qualified electronic signatures, trust service notifications, and cross-border identity matching.
The ARF specifies the use of mdoc and SD-JWT VC as credential formats. For proximity presentation, it references ISO/IEC 18013-5, and for online presentation ISO/IEC TS 18013-7. Credential issuance uses OID4VCI and presentation uses OID4VP. The High Assurance Interoperability Profile (HAIP) sets out the interoperability baseline that certified wallet solutions must meet.
Governance of the EUDI Wallet is a shared responsibility. 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 the actors within their jurisdiction, including wallet providers, issuers of Person Identification Data and attestations, qualified trust service providers, and relying parties. National competent authorities carry out certification and notification at the national level. No single central European authority operationally manages all EUDI Wallets.
The EUDI Wallet prototype
The European Commission procured a reference wallet prototype that serves as a working test environment. It includes code libraries and a sample application that pilot participants used to validate the ARF specifications in practice. The prototype is open source, meaning Member States and other interested parties can build their own wallet solutions on top of it. This open approach ensures that the technical standards are publicly verifiable and that implementation resources are accessible to the broader ecosystem.
How does the EUDI Wallet exchange data in the pilot setup?
In the pilot architecture, the EUDI Wallet exchanges data through cryptographically secured, user-controlled flows between three parties: the wallet holder (the citizen or business), the issuer of credentials (such as a government authority or bank), and the relying party (the organisation requesting the data). The wallet stores verified digital documents and attributes, and the holder decides which data to share and with whom.
The wallet enables selective disclosure. A user can share only their age or nationality without revealing their full name or address. This approach is central to the regulation’s data minimisation principle and gives users genuine control over their personal information. A user approves each individual presentation request in the wallet. This approval is separate from any consent that a relying party may need as a legal basis under the GDPR for its own processing of that data.
From a technical standpoint, the data exchange relies on standardised protocols and interfaces defined in the ARF, ensuring that a certified wallet issued in one Member State can be used with an appropriate relying party in another. Cross-border interoperability operates at the level of the framework: not every use case will immediately be available in every Member State, and sector-specific legislation and national registration requirements continue to apply alongside the wallet framework.
When a relying party receives a presentation, verification involves three distinct checks: first, verifying the issuer’s signature against the relevant national trusted list, which is part of the EU List of Trusted Lists (LOTL); second, checking the revocation status of the attestation using the issuer’s status information; and third, checking the wallet unit attestation to confirm that the presenting wallet runs on a certified wallet solution. Only the first of these checks can be performed fully offline.
Before a relying party can request wallet data at all, it must register with the national authority of its Member State of establishment under CIR (EU) 2025/848, adopted on 6 May 2025. The relying party registers per intended use, specifying which attributes and attestations it will request. The wallet checks incoming requests against this registered scope.
For organisations in financial services, this matters directly. The pilot use case for opening a bank account demonstrated how a customer can present their verified identity from the wallet and reuse that verified identity across multiple services, reducing friction for both the user and the institution.
What interoperability challenges did the pilots uncover?
The Large Scale Pilots revealed that achieving genuine cross-border interoperability is the most complex challenge in the eIDAS 2.0 architecture. While the ARF provides a shared technical baseline, translating that baseline into consistent implementations across 26 Member States with different legal systems, existing identity infrastructure, and technical maturity levels proved demanding in practice.
Several specific challenges emerged during testing:
- Identity matching across borders: Matching a person’s identity attributes from one country to a verified record in another requires standardised formats and clear rules. The pilots helped surface gaps in how Member States represent and validate identity data differently.
- Trust anchor recognition: Relying parties need to verify that a credential was issued by a trusted source. Establishing and maintaining national trusted lists that are recognised across all Member States required significant coordination work.
- Credential format consistency: Different sectors and countries had varying preferences for how credentials are structured and encoded, creating friction when a wallet from one country interacted with a relying party in another.
- Revocation and lifecycle management: Handling credential revocation in a privacy-preserving way, without revealing unnecessary information about the user, proved technically nuanced and required iterative refinement.
- Sector-specific requirements: Industries such as healthcare and government services have their own regulatory requirements that had to be reconciled with the wallet’s general architecture. These sector-specific obligations exist alongside the wallet framework and do not disappear because a credential is wallet-based.
The feedback collected by the pilots is being used to refine the ARF and close these gaps before the wallet becomes a mandatory offering for all Member States.
How do pilot findings shape the production eIDAS 2.0 rollout?
Pilot findings directly influence the technical specifications, governance rules, and implementation guidance that will govern the production rollout of the EUDI Wallet. The insights gathered from real-world testing feed back into the ARF through the EDICG, which updates specifications based on what the pilots demonstrated works and what needs further refinement.
In practical terms, this means that organisations preparing for the eIDAS 2.0 production environment are working with a framework that has already been stress-tested across multiple sectors and countries. The open-source reference implementation is continuously updated to reflect pilot learnings, giving developers and solution providers a more reliable foundation to build on.
eIDAS 2.0, formally Regulation (EU) 2024/1183, amends Regulation (EU) 910/2014. It entered into force on 20 May 2024. The legal deadline for Member States to make EUDI Wallets available is 24 December 2026. This deadline marks the point by which Member States must meet their legal obligations under the regulation. From that date, public sector bodies must accept notified wallets for online services that require electronic identification. It does not guarantee that every national wallet will reach the same level of maturity on that date, nor that every cross-border use case will be fully operational throughout Europe from that moment.
The obligation for relevant regulated private sector organisations, covering areas such as financial services, healthcare, telecoms, energy, transport, education, social security, and digital services, takes effect on 24 December 2027 under Article 5f of the regulation. That obligation applies where strong user authentication is required by law or contract. Micro and small enterprises, defined as organisations with fewer than 50 employees and an annual turnover or balance sheet total of no more than 10 million euros, are exempt. Very large online platforms fall under a separate provision of Article 5f: where they require user authentication, they must accept the EUDI Wallet on the voluntary request of the user and for the minimum necessary data.
National rollout, certification, notification, and the acceptance of wallet credentials by relying parties are likely to develop in phases across Member States. Organisations should plan for a phased landscape.
For government organisations and regulated industries, this iterative process is significant. The production architecture has been shaped by the practical realities of cross-border identity exchange, sector-specific compliance needs, and user behaviour. Organisations that followed the pilots closely are better positioned to anticipate what the production rollout will require from their systems and processes. Those exploring their implementation approach now have a clearer picture of what the architecture demands.
How the ID Connector supports eIDAS 2.0 pilot architecture and EUDI Wallet readiness
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 the eIDAS 2.0 pilot architecture, the ID Connector addresses several of the concrete challenges the pilots uncovered:
- Wallet acceptance across certified wallet solutions from any Member State, without requiring separate integrations per country
- Verification against national trusted lists consolidated in the EU List of Trusted Lists, covering issuer signature validation
- Revocation status checks using issuer-provided status information
- Validation of wallet unit attestations to confirm that a presenting wallet runs on a certified wallet solution
- Enforcement of the registered attribute scope as required under CIR (EU) 2025/848, so that only the attributes a relying party has registered for a given intended use are requested
- Support for qualified signing via a connected qualified trust service provider, relevant for organisations in financial services, healthcare, pharma, and government that need legally binding electronic signatures
If your organisation is preparing for the EUDI Wallet rollout and wants to understand what the pilot architecture means for your specific situation, get in touch with TrustTech.