What is the Large Scale Pilot program for eIDAS 2.0?

The Large Scale Pilot (LSP) program for eIDAS 2.0 was a set of four major EU-funded pilot projects launched in April 2023 to test the European Digital Identity Wallet in real-world conditions before its official rollout across Member States. The pilots were designed to validate the technical specifications, identify practical challenges, and gather feedback from real users and organizations across a wide range of sectors. The sections below answer the most common questions about how the program worked, what was tested, and what your organization should take away from the results.

Which pilots are part of the Large Scale Pilot program?

The Large Scale Pilot program consisted of four consortia, each funded under the European Commission’s DIGITAL Europe Programme. Together, they covered a broad range of use cases and brought together public authorities, private organizations, and technology providers from across the EU and beyond.

The four pilots were:

• POTENTIAL: a large consortium that tested government-focused use cases such as accessing public services, opening bank accounts, registering a SIM card, presenting a mobile driving licence, using qualified remote signatures, and accessing e-prescriptions across multiple Member States.
• EWC (EU Digital Identity Wallet Consortium): focused on Digital Travel Credentials, payments, and organisational digital identity, including use cases such as travel document management and cross-border credential sharing.
• DC4EU (Digital Credentials for Europe): tested the wallet for education and social security use cases, such as verifying diplomas, professional qualifications, and benefit entitlements.
• NOBID (Nordic-Baltic eID): a consortium of Nordic and Baltic countries, together with Italy and Germany, focusing specifically on domestic and cross-border payment use cases.

Each consortium operated independently but contributed to a shared goal: providing the European Commission with structured, evidence-based feedback on the Common Toolbox that underpins all future EUDI Wallets.

A second wave of pilots started in 2025. WE BUILD focuses on business wallets and payments. APTITUDE covers travel, ticketing, vehicle registration, and payments.

What use cases were tested in the EUDI Wallet pilots?

The first four EUDI Wallet pilots tested a wide variety of real-world use cases spanning both public and private sector interactions. These included identity verification for public services, cross-border payments, educational credential sharing, travel document management, and access to healthcare and social security systems.

Some of the most concrete examples that were piloted include:

• Opening a bank account using wallet-based identity verification
• Presenting Digital Travel Credentials in a travel context using a mobile credential
• Presenting a university diploma or professional certificate to an employer
• Accessing cross-border social security benefits
• Making domestic and cross-border payments linked to a verified digital identity
• Registering a SIM card or accessing government portals without a physical document
• Using a qualified remote signature via the wallet

What made these pilots particularly valuable was that they tested the wallet as a complete user experience. Participants experienced what it actually felt like to share only the data that is necessary, such as confirming age or nationality without revealing a full date of birth or home address. This selective disclosure capability is one of the wallet’s most important privacy features, and the pilots generated direct evidence of how it works in practice. Age confirmation without revealing a date of birth can be achieved through selective disclosure of an attribute such as “age over 18”, without requiring zero-knowledge proofs.

For organizations in financial services or healthcare, the pilot results are especially relevant because these sectors are among the first where wallet-based identity verification is expected to become a compliance requirement.

How do the Large Scale Pilots connect to the final eIDAS 2.0 rollout?

The Large Scale Pilots fed directly into the eIDAS 2.0 implementation process. The feedback and findings from each pilot informed the Architecture and Reference Framework (ARF), which is the technical elaboration of the requirements set out in the implementing acts adopted by the European Commission. The implementing acts are legally binding; the ARF provides the technical detail needed to apply them. In this way, the pilots were an integral part of building the final standard.

The European Commission has also developed a reference implementation of the EUDI Wallet, made available as open-source code. This prototype was tested and refined using insights gathered during the pilots. Member States and private developers can use this reference implementation as a foundation when building their own wallet solutions.

eIDAS 2.0, formally Regulation (EU) 2024/1183, amends Regulation (EU) 910/2014. It entered into force on 20 May 2024. Under eIDAS 2.0, all Member States are legally required to make a certified EUDI Wallet available to citizens, residents, and businesses by 24 December 2026. That date is the legal deadline for Member States’ wallet obligations. It does not mean 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 moment. Practical interoperability and national rollout are expected to develop in phases, shaped by each Member State’s certification and notification process, the readiness of relying parties, and sector-specific requirements.

From 24 December 2026, public bodies must accept notified EUDI Wallets for online services that require electronic identification. From 24 December 2027, the acceptance obligation under Article 5f extends to relevant regulated private sectors where strong user authentication is required by law or contract. Those sectors include financial services, healthcare, telecoms, energy, transport, education, social security, drinking water, postal services, digital infrastructure, and digital services. Micro and small enterprises are exempt: organisations with fewer than 50 employees and an annual turnover or balance sheet total of no more than 10 million euros fall outside the obligation. Very Large Online Platforms are subject to a separate provision under Article 5f: the obligation applies where the platform requires user authentication, on the voluntary request of the user and for the minimum necessary data.

The pilots helped ensure that when those obligations take effect, the wallets are technically sound, grounded in shared specifications, and genuinely usable in everyday situations. The transition from pilot to production is already underway, with several Member States moving toward national wallet deployments based on what the pilots demonstrated.

Who can participate in the Large Scale Pilots?

The first four Large Scale Pilots ran from April 2023 to 2025 and have concluded. Direct participation as a new consortium member in those pilots is no longer possible.

However, organizations can still engage with the pilot program and its outputs in meaningful ways:

1. As relying parties: Organizations can integrate with the EUDI Wallet ecosystem as service providers that accept wallet-based credentials, testing how the wallet works within their own onboarding or verification flows. Under CIR (EU) 2025/848, adopted on 6 May 2025, a relying party must register with the national authority of its Member State of establishment before it can request wallet data. Registration covers the intended use and the specific attributes and attestations the relying party intends to request. The wallet checks each request against that registered scope.
2. As observers and stakeholders: Many pilot consortia published reports, technical documentation, and open datasets that any organization can use to inform their own planning.
3. Through national initiatives: Some Member States are running complementary national pilots or sandbox environments that organizations can participate in directly.
4. Via the open-source reference implementation: Developers and technology teams can access the Commission’s open-source wallet code and build their own implementations based on the tested specifications.
5. Through the second pilot wave: The WE BUILD and APTITUDE consortia, which started in 2025, are active and cover business wallets, payments, travel, ticketing, and vehicle registration.

For organizations in the public sector or regulated industries, engaging with the pilot outputs now is a practical way to prepare for the formal rollout without waiting for a single European go-live moment that will not arrive uniformly across all Member States and use cases.

What should organizations learn from the pilot results?

The pilot results offer organizations a preview of what the EUDI Wallet ecosystem will look like in practice. The most important lesson so far is that the wallet requires organizations to rethink how they collect, verify, and store identity data, and how they interact with users during onboarding and authentication.

Key takeaways from the pilot program include:

• Interoperability is real but requires preparation: The EUDI Wallet framework is designed so that a certified wallet from one Member State can be used with an appropriate relying party in another Member State. This does not mean that every use case will immediately be available everywhere, that national registration requirements disappear, or that sector-specific legislation is overridden. Organizations need to align their systems with the ARF specifications and understand which elements of interoperability are governed at European level and which remain national or sector-specific.
• User experience matters as much as compliance: Pilots showed that wallet adoption depends heavily on how easy the experience is. Friction in the flow leads to drop-off, even when the technology works correctly.
• Selective disclosure changes data collection practices: Organizations will need to adjust their data requests to ask only for what is strictly necessary, which may require updates to existing onboarding and KYC processes. Note that KYC re-use is governed by AML regulation, not by eIDAS itself.
• Sector-specific requirements vary: Financial services, healthcare, and education each have different credential types and verification standards. The pilots surfaced these differences, and organizations should review the findings relevant to their own sector.
• Verification involves multiple checks: When a relying party verifies a wallet presentation, three separate checks are relevant: verifying the issuer’s signature against the applicable national trusted list, which is part of the EU List of Trusted Lists (LOTL); checking the revocation status via the issuer’s status information; and verifying the wallet unit attestation to confirm that the presenting wallet runs on a certified wallet solution. Only the first check can be performed fully offline.

Governance of the EUDI Wallet ecosystem is a shared responsibility. The European Commission manages the legal framework and adopts implementing acts. Member States provide or mandate wallet solutions, certify and notify them, and supervise actors within their jurisdiction. The European Digital Identity Cooperation Group supports 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. Organizations that understand this governance structure and treat the pilot results as a planning resource will be better positioned when wallet-based identity becomes a standard part of digital interactions across Europe. Reviewing the published ARF documentation and consortium reports is a concrete first step that any team can take today.

How the ID Connector supports EUDI Wallet acceptance

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 Large Scale Pilots and the broader rollout, the ID Connector addresses several practical challenges that organizations face when preparing for wallet acceptance:

• Connecting to the EUDI Wallet ecosystem as a relying party, in line with the registration requirements under CIR (EU) 2025/848
• Verifying issuer signatures against national trusted lists and the EU List of Trusted Lists (LOTL)
• Checking revocation status and validating wallet unit attestations as part of a complete verification flow
• Enforcing the registered attribute scope so that only the attributes declared during registration are requested
• Supporting wallet-ready onboarding flows that use selective disclosure and reusable credentials
• Connecting to a qualified trust service provider for qualified signing where required

Organizations in financial services, healthcare, pharma, and government face the earliest and most concrete obligations under eIDAS 2.0. If you want to understand what wallet acceptance means for your specific situation, get in touch with TrustTech to discuss how the ID Connector fits into your setup.