What Is the EUDI Wallet and Why Is the EU Introducing It?
From December 2027, certain organisations operating in the EU will be legally required to accept the EU Digital Identity (EUDI) Wallet for online identification where users choose to use it. Businesses that rely on customer onboarding, identity verification or electronic signatures should already be assessing how the new framework will affect their systems, compliance obligations and customer journeys.
The EUDI Wallet is more than a new digital identification tool for individuals. It has the potential to change how organisations verify customers, conduct digital transactions and manage trusted digital credentials across borders. With every Member State required to offer a wallet by December 2026, and many regulated businesses required to accept it by December 2027, this is no longer a distant prospect. For UK organisations serving EU customers or operating through EU group companies, these developments may have direct legal and operational implications.
Key Dates
- May 2024: The revised eIDAS (electronic identification, authentication and trust services) framework entered into force.
- December 2026: Member States must provide at least one EUDI Wallet.
- July 2027: The new EU Anti-Money Laundering Regulation begins to apply.
- December 2027: Many regulated organisations must accept EUDI Wallets.
To support implementation, the European Commission developed a wallet prototype. From April 2023, it also funded four large-scale pilot projects to test the EUDI Wallet across sectors such as banking, payments, telecommunications, healthcare, education, travel and public services. These projects were intended to refine aspects of the framework ahead of wider deployment. As those pilots were concluding, two further pilots, WE BUILD and APTITUDE, were launched in 2025 to continue developing and validating the EUDI Wallet ecosystem.
How the EUDI Wallet Could Transform Digital Identity in Europe
The revised eIDAS framework introduces the EUDI Wallet as a secure and interoperable mechanism for digital identity and credential sharing across the EU. Use of the wallet will be voluntary and free of charge for individuals. Users will be able to store and manage their own credentials, such as diplomas, driving licences or professional qualifications, and use them to authenticate themselves, share information selectively and sign documents using qualified electronic signatures.
A key objective of the framework is to give individuals greater control over their personal data through selective disclosure (for example, proving that they are over 18 without disclosing their date of birth), while supporting trusted cross-border digital transactions. The framework aims both to strengthen trust in digital transactions and to support a more integrated Digital Single Market.
Which Businesses Should Be Preparing for the EUDI Wallet?
Businesses that rely on identity verification, authentication or electronic signatures are likely to be affected, particularly in regulated sectors such as banking, telecommunications, healthcare, education and transport. SIM card registration and bank account opening, for example, were both tested in the pilots.
For some organisations, engagement will not be optional. By December 2027, certain private sector businesses (other than micro and small enterprises) will be required to accept the EUDI Wallet for online identification where a user chooses to use it. This applies where the business is legally or contractually required to use strong user authentication. Examples of sectors likely to be affected include banking and financial services, telecommunications, transport, energy, health, education, postal services and digital infrastructure. Very large online platforms that require users to authenticate will be subject to a similar obligation, and public sector bodies that require electronic identification for online services must also accept the wallet.
For these organisations, the EUDI Wallet could streamline onboarding, authentication and credential verification processes and reduce reliance on repeated identity checks. Businesses operating across multiple Member States may also benefit from a more consistent approach to digital identity, helping to facilitate cross-border transactions and customer interactions.
Opportunities and Compliance Challenges for Businesses
For businesses, the EUDI Wallet has the potential to improve efficiency, security and customer experience through trusted digital identity solutions and eIDAS trust services. These tools can support activities ranging from customer due diligence and contracting to document verification, with potential benefits across sectors that rely on secure digital interactions, including professional services, transport, online retail and financial services.
In the EU, the new Anti-Money Laundering Regulation, which applies from July 2027, permits the use of electronic identification means that meet the relevant eIDAS assurance requirements, including the EUDI Wallet, as part of customer identity verification processes.
Organisations planning to accept EUDI Wallet credentials should review privacy, cybersecurity and governance requirements; confirm any relying-party registration obligations; and assess whether existing customer verification and digital trust processes are compatible with wallet-based authentication across the EU. Since use of the wallet is voluntary, organisations will also need to maintain alternative verification routes for customers who do not use it.
Preparing for the EUDI Wallet: Practical Steps for UK Organisations
Although the EUDI Wallet is an EU initiative, its impact may extend beyond EU Member States, particularly for organisations that offer services within the EU or interact with EU-based customers and partners. The UK is developing its own regime in parallel: the Data (Use and Access) Act 2025 has placed certified digital verification services on a statutory footing, and the government has begun rolling out GOV.UK Wallet. The two regimes are separate, and UK-qualified trust services are not automatically recognised in the EU, so UK businesses with EU operations may need to work within both. Registration as a relying party takes place in the Member State where the business is established, and the current rules do not yet provide a clearly defined route for businesses established only outside the EU. UK businesses without an EU establishment should therefore consider whether an EU group company can act as the relying party. UK organisations that conduct business in the EU should review their existing identity verification, onboarding and digital trust processes now. The European Commission has also published practical resources to help businesses identify relevant eIDAS solutions and assess potential implementation needs.
A useful first step is to identify where identity verification, authentication or electronic signatures are critical to existing services. Businesses can then determine which systems, policies and contractual processes may need to interact with digital identity credentials. This assessment will help them prioritise technical and compliance work according to operational importance.
Organisations should consider:
- whether they, or their EU group companies, fall within the sectors required to accept the EUDI Wallet from December 2027;
- whether existing systems and third-party arrangements can support wallet-based verification;
- how verified digital credentials could affect onboarding and customer verification processes;
- whether current privacy, data governance and cybersecurity frameworks are fit for purpose;
- what relying-party registration and data minimisation requirements may apply; and
- whether existing provider contracts and cross-border operations are prepared for wallet-based transactions.
The precise impact on each organisation will depend on its services, the jurisdictions in which it operates and the extent to which its processes rely on identity verification or eIDAS trust services. However, with wallets due to be available by the end of 2026 and acceptance obligations following in 2027, businesses that begin this assessment now may be better placed both to manage compliance and to take advantage of the opportunities the wallet creates.
Please contact Xavier Prida for detailed advice on the above.
The material contained in this article is only for general review of the topics covered and does not constitute any legal advice. No legal or business decision should be based on its content.
This article is written in the English language. Preiskel & Co LLP is not responsible for any translation of all or part of its content into any language.