What is the EUDIW and how does it fit into eIDAS 2.0?

The European Digital Identity Wallet (EUDIW) is a secure digital application that allows EU citizens, residents, and businesses to store, manage, and share verified identity data and documents. It sits at the heart of eIDAS 2.0, Regulation (EU) 2024/1183, which amends Regulation (EU) 910/2014 and transforms how digital identity works across Europe. This article answers the most important questions about the EUDIW and what it means for your organisation.

How does the EUDIW fit into the broader eIDAS 2.0 framework?

The EUDIW is the central instrument of eIDAS 2.0. While the original eIDAS regulation created a framework for recognising national electronic ID systems across EU member states, eIDAS 2.0 goes much further by requiring every member state to provide a digital identity wallet to all citizens, residents, and businesses. The EUDIW is how that obligation becomes reality.

The original eIDAS regulation allowed member states to notify their national eID schemes so they would be mutually recognised across borders. In practice, this led to significant fragmentation. Some countries built strong national eID systems; others did not. Cross-border recognition was inconsistent, and private sector use was largely excluded from the framework.

eIDAS 2.0 changes this fundamentally. It introduces a common standard for digital identity wallets, a harmonised trust framework, and an obligation for both public and certain regulated private sector services to accept the wallet under specific conditions. The EUDIW is the mechanism through which eIDAS 2.0 delivers a unified, interoperable digital identity layer across Europe.

Governance of the EUDIW is a shared responsibility across multiple actors. The European Commission manages the legal framework and adopts implementing acts that contain the legally binding requirements. 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. 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.

What can the European Digital Identity Wallet actually do?

The EUDIW allows users to securely store verified identity attributes and digital documents, authenticate themselves to online services, and sign documents electronically, all from a single application. It gives users direct control over what data they share and with whom, without relying on passwords or third-party platforms.

In practical terms, the wallet supports a wide range of everyday interactions. The large-scale pilot programmes that tested the EUDIW explored use cases across multiple areas, including:

• Accessing government services such as applying for a passport, filing taxes, or accessing social security information
• Opening a bank account online without repeatedly providing the same personal information
• Registering a SIM card and proving identity to a mobile network operator
• Presenting a mobile driving licence or other credentials
• Sharing educational qualifications and professional certificates
• Authorising payments for products and services
• Accessing healthcare records and services across borders

One of the most important features of the wallet is selective disclosure. Users can share only the specific data needed for a transaction, for example confirming they are over 18 without revealing their full date of birth, or sharing their nationality without disclosing their home address. This is achievable through selective disclosure of individual attributes and does not require zero-knowledge proofs. It reduces the risk of unnecessary data exposure and gives individuals genuine control over their personal information.

Who is required to accept the EUDIW?

Under eIDAS 2.0, certain categories of public and regulated private sector service providers are legally required to accept the EUDIW as a means of authentication and identity verification. The timelines and scope differ between the public and private sectors.

For public sector services, the deadline is 24 December 2026. From that date, public bodies and public service providers must accept notified wallets as a means of identification for online services where electronic identification is required.

For the private sector, the mandatory acceptance obligation under Article 5f comes into effect on 24 December 2027. This obligation applies to regulated private sector services operating in contexts where strong user authentication is legally or contractually required. The relevant sectors include banking and financial services, healthcare, telecoms, energy, transport, education, social security, drinking water, postal services, digital infrastructure, and digital services. Very large online platforms with more than 45 million users in the EU are also covered by Article 5f, though under a distinct set of conditions: for those platforms, the obligation applies where the platform requires user authentication, on the voluntary request of the user, and for the minimum necessary data. The general condition of legally or contractually required strong user authentication does not apply to very large online platforms in the same way. The obligation does not apply to all businesses generally. Micro and small enterprises with fewer than 50 employees and an annual turnover or balance sheet total not exceeding 10 million euros are exempt.

Before a relying party can request wallet data, it must register with the national authority of the member state where it is established, in accordance with CIR (EU) 2025/848 of 6 May 2025. Registration specifies the intended use and the attributes and attestations the relying party is permitted to request. The wallet checks each presentation request against this registered scope. A relying party must be able to accept every relevant notified wallet regardless of which wallet provider issued it.

This is particularly relevant for organisations in financial services, where strong customer authentication requirements already create a clear overlap with EUDIW acceptance obligations. Healthcare providers, insurers, and government service platforms are also directly in scope. Organisations in these sectors should not treat EUDIW acceptance as optional. It is a regulatory requirement that will need to be built into their digital infrastructure ahead of the applicable deadline.

How is the EUDIW different from existing national eID systems?

The EUDIW combines authentication, document storage, and electronic signatures in a single interoperable tool designed to work across all EU member states, regardless of which country issued it.

Existing national eID systems, such as Germany’s eID, the Netherlands’ DigiD, or Austria’s ID Austria, were designed primarily for domestic use. They vary significantly in technical design, assurance levels, and cross-border compatibility. While eIDAS 1.0 created a mechanism for mutual recognition, cross-border use remained limited and inconsistent in practice. It is also important to note that an existing national eID system is not automatically an EUDI Wallet, even where it shares some technical characteristics or serves as part of the underlying infrastructure.

The EUDIW addresses fragmentation by establishing a common architecture through the Architecture and Reference Framework (ARF), which provides the technical elaboration of the requirements set out in the implementing acts. A wallet certified and notified by one member state can be used with an appropriate relying party in another member state. However, this does not mean that every use case will immediately be available in every member state, that national registration requirements disappear, or that every credential automatically carries the same legal consequence everywhere. Practical interoperability and the availability of specific cross-border use cases will develop in phases. Relying party registration remains connected to the applicable national registration framework under CIR (EU) 2025/848.

The wallet also extends beyond authentication. It can carry verifiable attestations such as diplomas, professional licences, and health documents, which national eID systems typically cannot. National eID systems were largely designed for government services. The EUDIW is explicitly designed for both public and private sector use, making it a genuinely cross-sector identity infrastructure.

When will the EUDIW be available and what is the rollout timeline?

Member states are legally required to make at least one certified EUDIW operational for all citizens, residents, and businesses by 24 December 2026. This is a legal deadline, 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 point. Rollout is actively underway, with member states at different stages of implementation depending on their existing digital identity infrastructure and national readiness. Practical interoperability and national rollout are expected to develop in phases beyond the initial deadline.

The groundwork for the wallet has been laid through a structured preparation process that unfolded in several phases:

1. Regulation entered into force (20 May 2024): Regulation (EU) 2024/1183 entered into force, amending Regulation (EU) 910/2014 and establishing the legal basis for the EUDIW.
2. First implementing acts adopted (end of 2024): The first five core implementing acts were adopted, covering technical specifications, security standards, and interoperability rules for the EUDIW. These acts contain the legally binding requirements that wallet providers, issuers, and relying parties must meet, and they started the relevant 24-month countdown.
3. Second wave of implementing acts published (2025): A second set of implementing acts was published, addressing qualified electronic archiving, validation, certificates, and qualified trust service providers (QTSPs). CIR (EU) 2025/848 on relying party registration was adopted on 6 May 2025.
4. Large-scale pilots (April 2023 to 2025): Four major pilot consortia tested the wallet across real-world use cases and provided feedback on the Architecture and Reference Framework. EWC piloted Digital Travel Credentials, payments, and organisational digital identity. POTENTIAL covered government services, bank account opening, SIM registration, mobile driving licences, remote qualified signatures, and e-prescriptions. NOBID focused on payments. DC4EU addressed education and social security. These pilots 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.
5. Reference implementation released: The European Commission published an open-source reference implementation of the EUDIW, giving member states and private developers a tested baseline to build from.
6. National rollouts and public sector acceptance (24 December 2026): Member states are required to issue certified and notified wallets, and public bodies must accept them from this date. For regulated private sector organisations, this is also the point at which wallets become available to test acceptance ahead of their own deadline. Member states are at different stages of national preparation, and the precise certification status of any national wallet should be verified against current authoritative sources before publication.
7. Private sector acceptance obligation (24 December 2027): Regulated private sector organisations in the relevant sectors must accept the EUDIW where strong user authentication is legally or contractually required, and very large online platforms must do so on the voluntary request of the user for the minimum necessary data. This deadline applies 36 months after the relevant implementing acts entered into force at the end of 2024.

For organisations in scope, neither 2026 nor 2027 is a distant deadline. There is no single European go-live moment to wait for. Preparation should already be in progress.

What should organisations do now to prepare for the EUDIW?

Organisations should start by assessing whether they fall within the scope of mandatory EUDIW acceptance, then map the technical and compliance changes needed to support wallet-based interactions. Waiting for full national rollouts before acting is a risk. The organisations best positioned for the EUDIW transition are those that started preparing early.

Practically, preparation involves several parallel workstreams. First, organisations need to understand the regulatory scope. Does your service fall within the categories required to accept the EUDIW? If you operate in banking or financial services, healthcare, telecoms, energy, transport, education, social security, or digital services, or if you run a very large online platform with more than 45 million users in the EU, the answer is very likely yes. Micro and small enterprises with fewer than 50 employees and an annual turnover or balance sheet total not exceeding 10 million euros are exempt.

Second, organisations should review their existing identity infrastructure. Can your current systems handle wallet-based authentication and verifiable attestations? Most legacy identity systems were not designed with the EUDIW architecture in mind, and integration work takes time. Relying party registration under CIR (EU) 2025/848 is required before wallet data can be requested, and organisations operating across multiple member states will need to account for the national registration processes in each relevant jurisdiction.

Third, consider what wallet acceptance makes possible beyond compliance. The EUDIW enables reusable, verified identity data. Organisations that build for this can significantly reduce onboarding friction, eliminate repeated identity checks, and improve the customer experience. The compliance requirement and the operational opportunity point in the same direction.

How TrustTech helps organisations prepare for the EUDIW

TrustTech supports organisations across regulated sectors in preparing for eIDAS 2.0 and the European Digital Identity Wallet through the ID Connector. 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.

Concretely, the ID Connector handles:

• Wallet acceptance: Connecting your existing systems to wallet-based authentication and verifiable credential flows, so your organisation can accept every relevant notified wallet regardless of provider
• Trust management and verification: Verifying issuer signatures against the relevant national trusted lists, which are brought together in the EU List of Trusted Lists, checking revocation status via issuer status information, and validating wallet unit attestations to confirm that a presenting wallet runs on a certified wallet solution
• Attribute scope management: Ensuring that presentation requests stay within the scope registered under CIR (EU) 2025/848, so your relying party interactions remain compliant
• Reusable identity infrastructure: Enabling verified identity data to flow across your onboarding, compliance, and signing processes without restarting verification each time
• Qualified signing: Supporting qualified electronic signatures via a connected QTSP, within the legal framework of eIDAS 2.0

The ID Connector is relevant for organisations in financial services preparing for the overlap between PSD2 strong customer authentication and EUDIW acceptance obligations, for healthcare organisations handling cross-border health data and e-prescriptions, for pharma organisations managing professional credential verification, and for government bodies required to accept notified wallets by 24 December 2026. Contact TrustTech to discuss what EUDIW acceptance means for your organisation and how the ID Connector fits into your identity infrastructure.