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 involving over 350 organisations across 26 EU Member States plus Norway, Iceland, and Ukraine. This article unpacks what was tested, how the architecture works, and what the findings mean for organisations preparing for production deployment.

What are the Large Scale Pilots testing in eIDAS 2.0?

The Large Scale Pilots are testing 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 examine the wallet’s security, interoperability, and usability across everyday situations that European citizens and businesses encounter. They also collect structured feedback on the wallet’s reference implementation to inform the final production design.

The pilots cover 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 are running these tests. The EU Digital Identity Wallet Consortium (EWC) focuses on digital travel credentials and six identity sectors, including banking, healthcare, and mobile driving licences. The NOBID Consortium, a group of Nordic and Baltic countries joined by Italy and Germany, pilots wallet-based payment authorisation. Two further consortia support governmental services and cross-border educational and social security infrastructure. Each consortium blends public and private sector expertise and is co-funded by the European Commission through grants under the DIGITAL Europe Programme.

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 work 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, is responsible for maintaining and evolving the ARF. It 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 (EAA) to qualified electronic signatures, trust service notifications, and cross-border identity matching.

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 can use 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 precisely which data to share and with whom.

Rather than transmitting a full identity document, 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 sovereignty over their personal information. From a technical standpoint, the data exchange relies on standardised protocols and interfaces defined in the ARF, ensuring that a wallet issued in one Member State works seamlessly with a relying party in another.

For organisations in financial services, this matters directly. The pilot use case for opening a bank account demonstrates how a customer can authenticate their identity once using their wallet and reuse that verified identity across multiple services, eliminating repetitive onboarding steps and 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:

1. 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.
2. Trust anchor recognition: Relying parties need to verify that a credential was issued by a trusted source. Establishing and maintaining trusted lists that are recognised across all Member States required significant coordination work.
3. 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.
4. 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.
5. 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.

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 demonstrate works and what needs further refinement.

In practical terms, this means that organisations preparing for the eIDAS 2.0 production environment in 2026 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.

For government organisations and regulated industries, this iterative process is significant. It means the production architecture is not a theoretical design but one 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 TrustTech helps with eIDAS 2.0 pilot architecture and EUDI Wallet readiness

Understanding the eIDAS 2.0 pilot architecture is one thing. Translating it into a working implementation for your organisation is another. TrustTech helps organisations in regulated sectors move from awareness to readiness, without getting lost in the technical complexity.

Working with TrustTech gives your organisation access to:

• Expertise in the Architecture and Reference Framework and what it means for your sector
• Infrastructure built on European digital identity standards, covering identity verification, reusable compliance, and qualified electronic signatures
• Practical implementation support for onboarding flows, credential exchange, and cross-border interoperability
• eIDAS 2.0-ready solutions designed from the ground up for regulatory compliance
• Guidance tailored to your industry, whether you operate in finance, government, healthcare, or another regulated sector

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 to start the conversation.