eIDAS 2.0

Standardised wallets for the management of digital identity data, known as EUDI wallets (European Digital Identity Wallet), are coming to Europe. With the adoption of the eIDAS 2.0 regulation on 26 March 2024, 27 EU member states have committed to providing their citizens and all legal entities with at least one such EUDI wallet by 21 November 2026. We answer the most important key questions for the practical consequences in companies in Germany:

What are EUDI Wallets and when do they come?

The EUDI wallets (European Digital Identity Wallet) are digital wallets in the form of an app for smartphones. They enable citizens to use their identity data and verified attributes from important documents such as ID cards, driving licences or certificates securely in digital applications. Users can also generate legally binding digital signatures in the EUDI wallet. EUDI wallets will be available to use free of charge.

All EU member states have committed to offering their citizens at least one nationally certified and approved EUDI wallet from the end of November 2026. Another deadline set by eIDAS states that each member state must only provide such an EUDI wallet within 24 months of the entry into force of the designated implementing acts – as of October 2024, the almost 50 implementing acts in question are still under discussion at the EU level.

Various technical standards are currently being developed within the framework of the Architectural Reference Framework (ARF) for implementation. A total of almost 50 EU implementing acts are expected, defining harmonised implementation standards to create a European and interoperable ecosystem.

How will the onboarding of customers change with the launch of the EUDI wallets?

The EUDI Wallet in Germany will be based on the eID function of the ID card, which, according to the E-Government Monitor 2024, is currently only used by 22% of the population. Even the initialisation of a German EUDI Wallet will require the use of the eID.

The EUDI Wallet will thus supplement the range of identification methods for onboarding, with certain sectors and companies being obliged to accept EUDI Wallets. The first functional EUDI Wallets will not be visible on the market until the end of November 2026 at the earliest, and a possible market relevance can only gradually develop from 2027 at the earliest. The established identification methods, such as photo ID, bank ID or local ID, will thus continue to be of great importance for the practical reach of customer onboarding.

What should be considered when accepting EUDI wallets?

EUDI wallets introduce new technical standards and protocols for proof of identity. At the same time, all international EUDI wallets from all over Europe must always be accepted. The proof of identity with EUDI wallets is mapped in full via the PID attributes (‘Personal ID Data’), which, for example, include name, date of birth and nationality, but not the address or ID card number. This means a change for established identification and business processes. In addition, the acceptance partner must decide in each case whether the new technical standards are to be incorporated into their own business processes or whether the protocols are to be transformed into the established formats at the outset. Preparation for the introduction of EUDI wallets should therefore start at an early stage.

Will the use and acceptance of EUDI wallets be free of charge?

For citizens, the use of the EUDI wallets, including the creation of the PID (in Germany using the eID function) and the issuance of private signatures (QES), is free of charge. Companies register as acceptance partners (‘verifier’ or ‘relying party’) in the publicly administered ecosystem as part of a chargeable process. Likewise, attribute issuers must register, with there being three types of attributes: firstly, the PID, secondly official attributes, e.g. from authorities, and thirdly private-sector attributes, which can be verified accordingly. The specific fees are still being worked out with a view to the market-relevant launch of EUDI wallets from the end of 2026.

The technical and procedural integration of EUDI wallets as an (additional) identification method will entail costs for the relying parties. A process for the issuance of attributes is also required. In October 2024, the German government presented the basic business model for EUDI wallets in Germany: ‘Open free data’. This means that relying parties can obtain all attributes from a user's EUDI wallet free of charge. Similarly, attributes from issuers are provided free of charge for storage in the EUDI wallet. Consequently, there is no billing relationship between the issuer, the wallet operator and the relying parties – which, given the openness of the ecosystem, would hardly be possible without further eIDAS specifications.

Should companies offer their own EUDI wallets?

It is possible to offer your own EUDI-Wallet solution to your customers. In the specific context of a company or ecosystem, it can make a lot of sense to integrate your own EUDI-Wallet into your own apps, for example to optimise the digitalisation of business processes in your own ecosystem, to provide customer service or to retain customers.

Companies can also decide whether they want to act as an issuer of verified attributes and/or as a verifier in the ecosystem. Offering your own EUDI wallet is particularly suitable if specific attributes are required for digitisation and your own EUDI wallet can be tailored to these – always in compliance with the non-discriminatory acceptance requirements.

An EUDI wallet and its EUDI wallet infrastructure must undergo a national certification procedure in each EU member state. It is currently unclear what advantages could result if a provider is already approved in an EU member state with its EUDI wallet application and infrastructure, and the EUDI wallet is also offered to citizens of other member states and is to be approved nationally for this purpose.

For private sector offerings, it may be useful to build on an already approved white label platform with modular components in order to efficiently structure initial development efforts, the effort for approval processes, and ongoing development and operational efforts.

Gimel ID has experience in setting up and operating secure ID wallets and also offers individual solutions for partner-specific wallet offers based on EUDI wallet standards, including a complete white-label EUDI wallet solution under the partner's brand for offering on the market.

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