Several EU member states are already well ahead in eIDAS 2.0 implementation, with countries like Germany, the Netherlands, and the Nordic nations leading the way. The 24 December 2026 legal deadline for member states to make a European Digital Identity Wallet available to all citizens and businesses has pushed national governments into action at different speeds. This article walks through who is furthest ahead, what the large-scale pilots involved, and what it all means for organizations operating across borders.
Which EU member states are furthest ahead with eIDAS 2.0?
Germany, the Netherlands, Austria, and the Nordic and Baltic countries are among the most advanced in their eIDAS 2.0 implementation efforts. These countries already had mature national digital identity infrastructure in place before eIDAS 2.0 came into force, which gave them a significant head start in adapting their systems to the new requirements.
Germany has been actively developing its digital identity ecosystem, building on its existing national ID card infrastructure. The Netherlands has a strong foundation through its existing digital identity infrastructure, including DigiD as an authentication mechanism and eHerkenning for business interactions, which serve millions of citizens and businesses daily. Austria has the existing ID Austria digital identity infrastructure, which is widely used for accessing government services and is being developed further in the context of eIDAS 2.0.
The Nordic and Baltic countries stand out as a particularly cohesive group. Denmark, Finland, Norway, Sweden, Estonia, Latvia, and Lithuania have long invested in cross-border digital identity and collaborated directly through the NOBID Consortium, one of the four EU large-scale pilot projects focused specifically on payments. Estonia, in particular, has one of the most developed digital identity ecosystems in the world and has been a reference point for other member states for years. It is worth noting that national eID systems such as BankID in Sweden and BankID in Norway are separate systems operating within their respective national frameworks and should not be treated as a single cross-border scheme.
Southern and Eastern European countries are generally progressing more gradually, often due to differences in existing national infrastructure, administrative capacity, and the pace of domestic alignment with the updated eIDAS 2.0 regulation.
What were the EU Large Scale Pilots and who was involved?
The EU Large Scale Pilots were four major testing programs launched in April 2023 to evaluate the European Digital Identity Wallet before its official rollout. They involved over 350 entities, including private companies and public authorities from 26 EU member states, as well as Norway, Iceland, and Ukraine. Each pilot was structured as a public-private consortium and was co-funded by the European Commission. The four pilots ran from April 2023 to 2025 and have concluded.
The four pilot projects each focused on different use cases:
- EU Digital Identity Wallet Consortium (EWC): Covered Digital Travel Credentials, payments, and organisational digital identity.
- NOBID Consortium: A group of Nordic and Baltic countries, together with Italy and Germany, piloted the use of the EUDI Wallet for authorizing domestic and cross-border payments.
- POTENTIAL: Covered government services, opening a bank account, SIM card registration, mobile driving licences, remote qualified signing, and electronic prescriptions.
- DC4EU: Covered the education and social security sectors, deploying interoperable digital service infrastructures across borders.
Together, these pilots tested the wallet across a range of real-world scenarios. The feedback collected was used to refine the wallet’s technical architecture, security model, and interoperability standards ahead of the mandatory rollout.
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 is the eIDAS 2.0 implementation deadline for member states?
The legal deadline for EU member states to make a European Digital Identity Wallet available to all citizens, residents, and businesses is 24 December 2026. This obligation is set out in Regulation (EU) 2024/1183, which amends Regulation (EU) 910/2014, and applies to all 27 member states without exception.
However, it is important to distinguish between several related but separate milestones: the legal deadline itself, national wallet availability, certification and notification of wallet solutions, operational interoperability across borders, and acceptance by relying parties. The 24 December 2026 date is a legal deadline, not a guarantee that every national wallet will have the same level of maturity or that every possible cross-border use case will be fully operational throughout Europe on that date. Practical interoperability and national rollout are likely to develop in phases beyond that point.
Two separate acceptance obligations apply to relying parties. From 24 December 2026, public bodies must accept notified wallets for online services that require electronic identification. From 24 December 2027, Article 5f of the amended regulation applies to relevant regulated private sectors where strong user authentication is legally or contractually required. Those sectors include banking and financial services, healthcare, telecommunications, energy, transport, education, social security, drinking water, postal services, digital infrastructure, and digital services. Very large online platforms fall under a separate provision of Article 5f: the obligation applies where the platform requires user authentication, on the voluntary request of the user, and limited to the minimum necessary data. Micro and small enterprises, defined as organizations with fewer than 50 employees and an annual turnover or balance sheet total not exceeding ten million euros, are exempt from the Article 5f obligation.
The technical requirements that wallets must meet are set out in the implementing acts adopted by the European Commission, which contain the legally binding requirements. The Architecture and Reference Framework (ARF) provides the technical elaboration of those requirements and was developed collaboratively with input from the European Digital Identity Cooperation Group (EDICG), which supports cooperation and cross-border alignment among member states. Governance 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; national competent authorities and registrars, wallet providers, issuers of Person Identification Data and attestations, qualified trust service providers, and relying parties each carry distinct roles within the overall framework.
Member states can provide wallets directly through government channels or through certified private providers, as long as those providers are officially recognized under the applicable national trust framework.
The deadline applies to availability, not to adoption. Member states must make the wallet available to anyone who wants to use it, but citizens and businesses are not obligated to use it. Uptake will depend on how well the wallets are integrated into both public and private digital services. Organizations should not wait for a single European go-live moment, as readiness will vary by country and sector.
How does national implementation differ across EU countries?
National implementation of eIDAS 2.0 varies significantly depending on each country’s existing digital identity infrastructure, regulatory environment, and level of investment in digital public services. Countries with mature eID systems are adapting and extending existing solutions, while others are building more foundational components from scratch. It is also important to distinguish between an existing national digital identity system and a certified EUDI Wallet: a country may have a well-established national eID scheme without yet having a notified EUDI Wallet in place.
A few patterns are visible across the EU:
- Countries with advanced eID systems (such as Estonia, the Netherlands, Germany, and Austria) are focusing on upgrading and connecting existing infrastructure to meet the EUDI Wallet technical specifications.
- Countries that participated in large-scale pilots gained practical experience early and are better positioned to meet the 2026 deadline with tested, real-world solutions.
- Countries with less developed national eID infrastructure are investing in foundational identity systems alongside the EUDI Wallet requirements, which makes the implementation timeline more demanding.
- Countries leveraging private sector involvement are moving faster by allowing certified commercial providers to develop and operate compliant wallets under national supervision.
Denmark’s AltID is a notable example of a national wallet initiative taking shape. It operates alongside MitID and does not replace it. This signals a broader trend of member states moving from pilot participation toward actual product deployment, which is relevant for organizations that need to plan their own integration timelines. Because national wallet status is time-sensitive, organizations should consult current authoritative national sources when assessing the maturity of any specific country’s EUDI Wallet.
What does eIDAS 2.0 implementation mean for organizations operating across borders?
For organizations operating across EU borders, eIDAS 2.0 implementation means that a new, standardized layer of digital identity infrastructure is becoming available across all member states. This creates both an opportunity and a compliance obligation: organizations in regulated sectors will increasingly be expected to accept and integrate EUDI Wallet credentials as a valid form of identity verification.
From a practical standpoint, cross-border organizations should be thinking about several things:
- How their onboarding and identity verification flows will connect with wallet-based credentials
- Whether their current systems can accept verifiable credentials issued by another member state
- How reusable identity data from the wallet can reduce friction for customers who have already been verified elsewhere
- What their obligations are under sector-specific regulations such as AML, KYC, and PSD2 in combination with eIDAS 2.0
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 in every member state, that national registration requirements disappear, or that sector-specific legislation no longer applies. 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 specific intended uses, attributes, and attestations the relying party is authorized to request, and the wallet checks each request against that registered scope.
Not every credential will automatically carry the same legal consequence in every jurisdiction. When a customer in Germany can use their EUDI Wallet to open a bank account in France or access a healthcare service in Spain without re-verifying from scratch, it removes a significant friction point in European digital services. The conditions under which that becomes possible will depend on the relevant national and sector-specific rules being in place. Organizations that prepare their infrastructure now will be better positioned to capture this efficiency as wallets reach critical adoption. For organizations in financial services or government services, regulatory alignment with eIDAS 2.0 is a legal requirement.
How TrustTech helps with eIDAS 2.0 implementation
Navigating eIDAS 2.0 is complex, particularly for organizations that need to stay compliant across multiple EU member states while keeping digital interactions fast and user-friendly. TrustTech’s ID Connector is built specifically for this challenge.
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 working through eIDAS 2.0 implementation, the ID Connector handles several concrete functions:
- Wallet acceptance across member states: The ID Connector accepts every notified EUDI Wallet, regardless of which member state issued it, so organizations do not need separate integrations per country.
- Verification against trusted lists: The ID Connector verifies issuer signatures against the relevant national trusted lists, which are consolidated in the EU List of Trusted Lists (LOTL), checks revocation status using issuer-provided status information, and validates wallet unit attestations to confirm that a presenting wallet runs on a certified wallet solution.
- Registered attribute scope management: The ID Connector ensures that data requests stay within the scope registered under CIR (EU) 2025/848, so organizations remain aligned with their registration at all times.
- Reusable verified identity data: Instead of asking customers to re-verify at every touchpoint, the ID Connector enables secure reuse of verified identity data across services and borders.
- Qualified signing via a connected QTSP: The ID Connector connects to a qualified trust service provider for qualified electronic signatures, creating a tamper-evident and auditable record that meets the highest eIDAS standards.
TrustTech works with organizations in financial services, government, healthcare, and pharmaceuticals. With an average of under five months to production, the ID Connector moves organizations from compliance planning to live deployment without unnecessary delays. Get in touch with TrustTech to discuss your digital identity integration.