The EU Digital Identity Wallet stores personal data that users actively choose to add, such as government-issued identity attributes, professional qualifications, health information, and other certified credentials. This data lives on the user’s own device, not on a central government or company server. The sections below explain what types of data the wallet can hold, how that data is protected, and what privacy rights users have under eIDAS 2.0, which amends Regulation (EU) 910/2014.
Who controls the personal data in the EUDI Wallet?
The user controls their own personal data in the EUDI Wallet. Under the eIDAS 2.0 framework, the wallet is designed around the principle of user sovereignty: you decide what credentials to store, what data to share, and with whom. No third party, including the wallet provider or any government authority, can access or share your data without your explicit approval.
This is a significant departure from many existing digital identity systems, where identity data is held and managed by a central authority. With the European Digital Identity Wallet, the user holds the keys, both literally and figuratively. The wallet uses cryptographic mechanisms that ensure only the user can authorize disclosure. Wallet providers are required by regulation to be neutral infrastructure, not data processors with access to the contents of your wallet.
Governance of the EUDI Wallet is a shared responsibility. The European Commission manages the legal framework and adopts implementing acts that contain legally binding requirements. EU 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 responsibilities within this structure. No single central European authority operationally manages all EUDI Wallets.
For organizations in regulated sectors such as finance, healthcare, or government, this user-centric model has important implications. When a customer presents credentials from their wallet, those credentials carry a high level of assurance precisely because the user has actively chosen to share them, and the underlying data has been certified by a trusted issuer.
What types of credentials and attributes can the wallet hold?
The EUDI Wallet can hold a wide range of certified credentials and personal attributes, from government-issued identity documents to professional qualifications, health data, and beyond. The wallet is designed to be a flexible container for any verifiable credential issued by a trusted source within the European digital identity ecosystem.
The most foundational credential is the Person Identification Data (PID), which is issued by a government authority and includes core identity attributes such as:
- Full name
- Date of birth
- Place of birth
- Current address
- Nationality
- A unique identifier tied to the national identity system
Beyond the PID, the wallet can also hold what the eIDAS 2.0 framework calls Electronic Attestations of Attributes (EAAs). These are credentials issued by qualified or non-qualified trust service providers and can cover a much broader range of use cases. The framework distinguishes between Qualified Electronic Attestations of Attributes (QEAAs), issued by qualified trust service providers, Public Body-issued EAAs (PuB-EAAs), and non-qualified EAAs. Examples of attestations include a mobile driving licence, a university diploma, a professional licence, a health insurance card, or an age verification credential. Over time, as more sectors adopt the wallet standard, the range of supported attestations is expected to grow significantly.
One of the most practical features is selective disclosure: a user can choose to share only a specific attribute from a credential. For example, a user can confirm they are over 18 by disclosing a single attribute, without revealing their date of birth or any other detail. Zero-knowledge proofs are not required for this; selective disclosure of a specific attribute is sufficient.
How is personal data protected inside the wallet?
Personal data inside the EUDI Wallet is protected through a combination of device-level security, cryptographic binding, and regulatory safeguards. The data is stored in an encrypted format on the user’s device, and each credential is cryptographically linked to that specific wallet unit, making it extremely difficult to copy, forge, or misuse.
At a technical level, the wallet relies on the Wallet Secure Cryptographic Device, which on modern smartphones may take the form of a secure enclave or equivalent secure hardware element, to store private keys and sensitive credential data. These keys never leave the secure element. When a user presents a credential to a relying party, a cryptographic proof is generated on the device and shared. The relying party receives only what is necessary to verify the claim.
Verification of a presented attestation involves three distinct checks: first, verification of the issuer’s signature against the relevant national trusted list, which is part of the EU List of Trusted Lists (LOTL); second, a check of the revocation status using the issuer’s status information; and third, validation of 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. Describing attestation verification as a single cryptographic check, or as entirely independent of any online contact, would therefore be an oversimplification.
From a regulatory standpoint, the implementing acts under eIDAS 2.0 mandate that wallet providers undergo conformity assessments and meet strict security requirements before they can operate. The Architecture and Reference Framework (ARF) provides the technical elaboration of those requirements. The framework also prohibits wallet providers from tracking users’ transactions or building profiles based on wallet usage, which is a meaningful privacy protection built into the regulation itself.
What data is shared when you use the wallet to log in or verify identity?
When you use the EUDI Wallet to log in or verify your identity, only the specific data attributes that you explicitly approve are shared with the requesting party. The wallet uses a selective disclosure mechanism, meaning a relying party receives the minimum data necessary for the transaction.
The exact data shared depends on what the relying party requests and what you agree to. A typical login to an online service might only require your name and a verified email address. An age-restricted purchase might only require a confirmation that you meet the age threshold, disclosed as a single attribute without revealing your date of birth. A financial services onboarding process might require a more complete set of identity attributes, including your address and document number, to satisfy KYC requirements.
Before approving any disclosure, the user sees a clear, readable summary of what is being requested. You can accept or decline the request. This transparency is a core requirement under eIDAS 2.0 and is intended to give users genuine informed control over every interaction. It is important to note that approving a data request in the wallet is a separate matter from consent as a legal basis under the GDPR. A relying party must have its own GDPR legal basis for processing the data it receives. For KYC purposes, that basis is typically a legal obligation.
For organizations in financial services or other regulated industries, this model is particularly relevant. Wallet-based identity verification can satisfy strong customer authentication requirements while simultaneously supporting data minimization principles under GDPR. It is worth noting that relying parties must register under CIR (EU) 2025/848 with the national authority of their Member State of establishment before requesting wallet data, and that sector-specific legislation continues to apply alongside the eIDAS 2.0 requirements.
Is data in the EUDI Wallet stored centrally or on the device?
Data in the EUDI Wallet is stored on the user’s device, not in a central database. This is one of the defining architectural principles of the European Digital Identity Wallet framework. There is no central European repository where all citizens’ identity data is collected and held.
This decentralized approach is deliberate. It reduces the risk of large-scale data breaches, eliminates single points of failure, and ensures that no single authority, whether a government body, a technology company, or a wallet provider, has access to the combined identity data of all wallet users. Each user’s wallet is their own private store of credentials.
Credential issuers, such as a national identity authority or a university, do maintain records of what they have issued. Once a credential is delivered to the wallet, the issuer does not need to be contacted every time the user presents that credential to a relying party for the purpose of verifying the issuer’s signature. However, a check of the revocation status does require contact with the issuer’s status information, and validation of the wallet unit attestation also involves an online step. The issuer does not, however, receive a notification each time you use your diploma or your driving licence.
When a user switches to a new device, private keys cannot be copied from the Wallet Secure Cryptographic Device. Attestations must therefore be re-issued to the new wallet unit rather than transferred directly.
For organizations in the government sector or healthcare, this architecture raises practical questions about credential revocation and updates, which the eIDAS 2.0 technical specifications address through standardized revocation mechanisms that work without compromising user privacy.
What are the data privacy rights of EUDI Wallet users?
EUDI Wallet users have strong data privacy rights that are grounded in both eIDAS 2.0 and the General Data Protection Regulation (GDPR). These rights include the right to access, correct, and delete their personal data, as well as the right to know exactly what data is being requested and why before any disclosure takes place.
The key privacy rights that apply to wallet users can be summarized as follows:
- Right to informed approval: Users must be clearly informed about what data is requested and for what purpose before they approve any transaction. This approval in the wallet is distinct from consent as a GDPR legal basis, which the relying party must establish independently.
- Right to data minimization: Relying parties may only request the data that is strictly necessary for the specific purpose. Requesting more than needed is not permitted. Under CIR (EU) 2025/848, a relying party registers the specific attributes and attestations it intends to request, and the wallet checks requests against that registered scope.
- Right to portability: Users can take their credentials with them and are not locked into a single wallet provider or ecosystem.
- Right to erasure: Users can delete credentials from their wallet at any time. Where personal data has been processed by a relying party, GDPR erasure rights also apply to that processing.
- Right to non-tracking: Wallet providers are explicitly prohibited from tracking users’ interactions or profiling them based on wallet activity. The wallet dashboard is a tool for the user to review their own activity, not a logging facility for the wallet provider.
These rights are regulatory requirements. Organizations that accept wallet-based credentials as relying parties must also comply with these principles, which means building data request flows that respect minimization, transparency, and purpose limitation. For many organizations, aligning existing onboarding and verification processes with these requirements will involve a review of current data practices.
The EUDI Wallet rollout: what organizations should expect
The legal deadline for EU Member States to make EUDI Wallet solutions available is 24 December 2026. This is an outer deadline set by regulation, not a predicted launch date, and it should not be interpreted as a single European go-live moment at which every national wallet will have reached the same level of maturity or every cross-border use case will be fully operational throughout Europe.
From 24 December 2026, public sector bodies must accept notified wallets for online services that require electronic identification. A separate obligation applies to the private sector: from 24 December 2027, Article 5f of eIDAS 2.0 requires relevant regulated private sector organizations, including those in banking and financial services, healthcare, telecoms, energy, transport, education, social security, drinking water, postal services, digital infrastructure, and digital services, to accept the EUDI Wallet where strong user authentication is required by law or contract. Micro and small enterprises, defined as organizations with fewer than 50 employees and an annual turnover or balance sheet total not exceeding 10 million euros, are exempt. Very Large Online Platforms (VLOPs) are subject to a separate provision under Article 5f: where a VLOP requires user authentication, it must accept the wallet on the voluntary request of the user and for the minimum necessary data.
National rollout, certification and notification of wallet solutions, operational interoperability, and acceptance by relying parties are distinct steps that will develop in phases across Member States. Each country is responsible for providing or mandating its own wallet solution and for supervising the actors within its jurisdiction. Organizations should plan for a phased transition and engage with the relevant national registration requirements under CIR (EU) 2025/848 well ahead of the applicable deadlines.
How the ID Connector supports 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.
For organizations preparing for the obligations described in this article, the ID Connector addresses several of the practical challenges that wallet acceptance involves:
- Accepting wallet-based credentials from any notified wallet solution, regardless of the issuing Member State
- Verifying issuer signatures against national trusted lists consolidated in the EU List of Trusted Lists (LOTL)
- Checking revocation status using issuer-provided status information
- Validating wallet unit attestations to confirm that a presenting wallet runs on a certified wallet solution
- Enforcing the registered attribute scope so that data requests remain within the bounds registered under CIR (EU) 2025/848
- Supporting qualified signing via a connected qualified trust service provider
Organizations in financial services, healthcare, pharma, and government can use the ID Connector to build wallet acceptance into their onboarding and authentication flows in a way that is consistent with GDPR, KYC requirements, and the data minimization obligations under eIDAS 2.0.
To see how the ID Connector fits your organization’s specific situation, explore our identity solutions or get in touch with TrustTech.