EUDI Wallets – Key Questions & Answers for Businesses
Digital identity is a cornerstone for the future of digitalization in Europe. With the European Digital Identity Wallet (EUDI Wallet), the European Union aims to establish a unified standard that is user-friendly, secure, and economically relevant.
On March 26, 2024, the EU’s 27 member states adopted the eIDAS 2.0 regulation, committing to provide their citizens and legal entities with at least one standardized EUDI Wallet by November 21, 2026.
Here, we address the 11 most important questions regarding the practical implications for businesses in Germany.
11 Key Questions for Businesses
1. What are EUDI Wallets, and when will they be available?
EUDI Wallets (European Digital Identity Wallets) are digital wallets, available as apps on smartphones. They allow citizens to securely use identity data and other verified attributes from key documents, such as ID cards, driver’s licenses, or diplomas, in digital applications. Additionally, users can create legally binding digital signatures within the EUDI Wallet. These wallets will be free to use.
All EU member states are obligated to offer at least one nationally certified and approved EUDI Wallet to their citizens by the end of November 2026. Another eIDAS deadline requires member states to launch a wallet within 24 months of specific implementing acts coming into force. However, with many of the nearly 50 implementing acts still under discussion at the EU level, the rollout timeline has shifted to late December 2026, making early 2027 the realistic start for implementation.
To support the rollout, technical standards are being developed under the Architectural Reference Framework (ARF). Nearly 50 implementing acts are expected to ensure unified standards for a European, interoperable ecosystem.
In Germany, political changes, such as the potential shift in government following elections in March 2025, could result in delays. For example, the eIDAS Implementation Act II was not passed as planned in December 2024. Germany aims to launch its own EUDI Wallet by the end of 2026 while also building the necessary ecosystem. The private sector requires significant preparation time to adapt existing processes to the new ecosystem’s defined standards.
2. How will customer onboarding change with the introduction of EUDI Wallets?
In Germany, the EUDI Wallet will build on the eID function of ID cards, which had a usage rate of only 22% among citizens according to the 2024 E-Government Monitor. The initialization of a German EUDI Wallet will likely require the use of the eID function.
EUDI Wallets will complement existing identification methods for onboarding. Some sectors and businesses will be required to accept EUDI Wallets. However, approved wallets will not be available in the market until early 2027 at the earliest, with gradual relevance expected over the course of that year. Established identification methods, such as photo ID verification, bank ID, or local ID verification, will remain essential for broad practical reach, while EUDI Wallets will serve as an additional option.
Many use cases touted as success drivers for EUDI Wallets, such as age verification, mobile payments, or organizational identity management, are already addressed through existing methods. While EUDI Wallets may introduce new technical standards, they are unlikely to significantly impact practical relevance, market penetration, or customer acceptance initially.
The primary challenge lies not in technical implementation—many solutions already exist—but in creating incentives for businesses and users to adopt EUDI Wallets. Broad acceptance requires a well-functioning ecosystem.
3. What should businesses consider regarding EUDI Wallet adoption?
EUDI Wallets will introduce new technical standards and protocols for identity verification and the transfer of verified attributes. All EUDI Wallets from across Europe must be accepted without exception.
The core identity verification through EUDI Wallets relies on “Personal ID Data” (PID) attributes, such as name, birthdate, and nationality. However, attributes like address or ID card numbers are not mandatory. This results in fewer attributes being transmitted for identity verification compared to Germany’s current eID function.
This change requires adjustments to established identification and business processes, as greater distinction must be made between pure identity verification and attributes relevant for the business process. Businesses must decide whether to integrate the new standards into their processes or transform the protocols into existing formats. Early preparation for the introduction of EUDI Wallets is crucial.
4. What trust level do EUDI Wallets provide?
The PID attributes in EUDI Wallets are defined at a “high” trust level and are designed to meet the requirements of regulated sectors for identity verification of EU residents. These attributes can be used for compliance with regulations such as the Anti-Money Laundering Act (GwG), Telecommunications Act (TKG), and within the eIDAS framework, including the German healthcare sector’s telematics infrastructure.
Whether biometric authentication will be available for attribute access, how it might affect trust levels and acceptance, and what the user experience for onboarding with EUDI Wallets will look like—these aspects remain unclear as of January 2025.
5. Will EUDI Wallet usage and acceptance be free?
For citizens, EUDI Wallet usage, including the creation of PID attributes (via the eID function in Germany) and private signatures (QES), will be free.
Businesses must register as acceptance partners (“verifiers” or “relying parties”) within the publicly administered ecosystem, typically involving fees. Issuers of attributes also need to register. There are three types of attributes: PID, official attributes (e.g., from authorities), and privately verified attributes. Fee structures for participating in the ecosystem are still being developed, with a market-relevant start expected by late 2026.
The technical and procedural integration of EUDI Wallets as an identification method involves costs for relying parties. Similarly, issuers face costs for issuing attributes. The German government’s business model for EUDI Wallets, introduced in October 2024, is based on “open free data.” Attribute retrieval by relying parties and attribute provision by issuers will be free of charge. This model ensures interoperability and non-discrimination within the EU-wide ecosystem.
The only potential cost involves issuing verified digital attributes, which could be borne by the user. For official attributes, issuing fees could be added to existing fee schedules, while for private attributes, user willingness to pay remains uncertain. Relying parties might offset such costs by offering incentives to users, as process efficiencies primarily benefit relying parties once a critical mass is achieved.
6. Who Provides EUDI Wallets?
Every EU member state is obligated under the eIDAS 2.0 regulation to offer at least one EUDI Wallet solution for its citizens by the end of 2026, either through a state-provided offering or via the approval of private-sector solutions. Each EUDI Wallet requires appropriate national certification or approval.
According to the German Bundestag document 20/12796 from September 19, 2024, the German government plans to release a non-certified preliminary version of a German EUDI Wallet. Initially, this version will only allow for the identification of natural persons. Additional functionalities, such as qualified electronic signatures (QES), verified attributes (e.g., driver’s license, university diploma, membership cards), and in-person use, are to follow later. The full functionality of a certified EUDI Wallet is expected 24 months after the relevant EU implementing acts (nearly 50 in total) come into effect, many of which are still under discussion as of January 2025.
The Federal Office for Information Security (BSI) and the German Accreditation Body (DAkkS) are mentioned as certification authorities. The practical significance of a non-certified preliminary version for acceptance partners in the private and public sectors remains unclear. Similarly, certification requirements and processes are not yet known.
Initially, there will be a state-provided EUDI Wallet in Germany. It is considered likely that private-sector EUDI Wallet solutions will subsequently be approved via a national certification process yet to be defined. Given the lack of a direct business model for operating a standalone EUDI Wallet, it is expected that primarily large-scale providers or those targeting specific user groups or ecosystems will integrate a EUDI Wallet into their offerings. Potential motives include indirect business models, optimized digital processes, or aspects like customer service and retention.
It is also plausible that EUDI Wallets will become an integral part of iOS/Android operating systems or native smartphone wallets across Europe. This would greatly support rapid adoption and ease of use, similar to mobile payments. The EU’s Architectural Reference Framework (ARF) mandates all EUDI Wallet providers to meet specific requirements for the digital sovereignty of sensitive identity data, monitored through national approval processes. Private providers must weigh the market relevance and cost-benefit ratio of offering a standalone EUDI Wallet within a discrimination-free ecosystem.
At launch, there will be at least 27 distinct EUDI Wallets in the EU, plus additional private-sector wallet offerings, all of which must be accepted indiscriminately by issuers and relying parties across the region.
7. How Will the Widespread Use of EUDI Wallets Be Ensured in Practice?
EUDI Wallets form the core of an ecosystem for digital identities. Their success depends critically on widespread use by citizens, the availability of numerous (verified) attributes, and broad acceptance by businesses and institutions. Regulated and large companies are mandated to accept EUDI Wallets for onboarding and authentication processes, which provides a strong starting point but does not yet establish everyday relevance.
In Germany, a significant entry barrier for citizens remains the eID via the online ID function of the national ID card, which, as of 2024, has only about 22% adoption. It is also possible that, with the introduction of EUDI Wallets in the near future, established optical identification methods, such as video identification and photo identification, may be banned in regulated sectors due to security concerns—similar to what happened in the German healthcare sector in 2022. This could accelerate the transition to secure digital methods like EUDI Wallet, eID, and bank identification. However, regulated use cases generally show limited relevance for everyday applications.
A secure digital ID on a smartphone offers limited value without practical use cases. Private-sector EUDI Wallets could accelerate adoption and usage by being directly integrated into the smartphone user experience and frequently used applications. It could also be helpful to offer—perhaps outside the EUDI Wallet itself—lower levels of trust and simpler biometric authentications for mass-market applications to ensure a convenient user experience.
Beyond “online identification” as the current core use case for EUDI Wallets, the ecosystem for other verified attributes still needs to evolve. In addition to identification and the transmission of verified attributes, strong authentication could play a crucial role in adoption—such as replacing the current photo TAN or push TAN apps used by online banks with a centralized, bank-independent EUDI Wallet function.
Processes still need to be established for identifying and verifying a wide range of relevant attributes. Newly defined qualified trust service providers (qTSPs) under the eIDAS regulation will help deliver so-called QEAA (qualified electronically attested attributes), which confirm the authenticity and validity of these attributes. In practice, attributes could also be issued as EAA (electronically attested attributes) without the “qualified” designation, as qualification is primarily relevant for cross-border use cases, which are unlikely to form the majority of applications.
Processes and applications must also be developed on the side of acceptance partners to enable users to use their digital attributes from EUDI Wallets in practice. A verified attribute will have little value without broad acceptance by companies and public authorities. Such acceptance will primarily be driven by improved economics, which can only emerge with a broad ecosystem.
Resolving the “chicken-and-egg” dilemma of achieving widespread EUDI Wallet adoption is currently unclear. What remains certain is that market acceptance will heavily depend on the practicality of the ecosystem and corresponding incentives. Successful digital ecosystems have had significantly better starting conditions.
For example:
- The e-prescription: Mandatory use and acceptance by all participants in the closed eHealth ecosystem (such as doctors, pharmacists, and health insurers), established technological infrastructure, and clear economic incentives for certain acceptance partners (particularly online pharmacies) enabled a supported rollout through visible communication.
- Mobile payments: Quickly established due to the proven technical, procedural, and commercial infrastructure of the payments market.
In comparison, numerous challenges remain to be addressed for the EUDI Wallet, making a rapid adoption unlikely, at least initially.
Until the planned launch of the EUDI Wallet, it remains crucial to rely on proven digital identification solutions like Ident & Sign. At the same time, close collaboration between public and private stakeholders is needed to lay the groundwork for widespread use.
8. Should Companies Offer Their Own EUDI Wallets?
It is possible for companies to offer their own EUDI Wallet solutions to their customers. In the specific context of a company or ecosystem, integrating a proprietary EUDI Wallet into existing apps can make sense to optimize digital business processes, enhance customer service, or foster customer loyalty.
Companies can also decide whether to act as issuers of verified attributes (“Issuer”) and/or as acceptance partners (“Verifier”) within the ecosystem. Offering a proprietary EUDI Wallet is particularly suitable when specific attributes are needed for digitalization, and the wallet can be tailored to these needs—while always adhering to non-discriminatory acceptance requirements.
In each EU member state, an EUDI Wallet and its infrastructure must go through a national certification process. It is currently unclear what advantages may arise if a provider has already been approved for its EUDI Wallet application and infrastructure in one EU member state and seeks to offer the EUDI Wallet to citizens in other member states, where it would require separate national approval.
For private-sector offerings, building on an already widely approved white-label platform with modular components can be an efficient way to structure initial development efforts, certification processes, and ongoing development and operational costs.
Verimi has extensive experience in developing and operating regulated ID wallets and also offers customized solutions for partner-specific wallet offerings based on EUDI Wallet standards, including fully white-labeled EUDI Wallet solutions under the partner’s brand for market deployment.
9. Are the Technical EUDI Wallet Standards Relevant for My Identity Management?
The EUDI Wallet introduces new technical standards that significantly enhance the efficiency and security of processing digital identity data. These standards are highly relevant for proprietary corporate solutions, enabling businesses to leverage the benefits of trusted digital identity processing in Europe for their specific applications and business processes. Additionally, this ensures that users’ attributes could potentially be used within the open ecosystem at a later stage with other acceptance partners.
At the same time, businesses must evaluate when the appropriate time is to implement or transition to these new standards within their own processes. Until then, the new EUDI Wallet protocols can be transformed to integrate with existing systems.
Verimi brings years of experience in integrating digital identity data into individual use cases and can provide guidance on which aspects to consider within the context of your systems.
10. What About Organizational Identities—Are There Separate EUDI Wallets for Natural and Legal Persons?
According to the eIDAS regulation, EUDI Wallets are designed to process the identities of both natural and legal persons. However, current discussions and pilot projects are focused exclusively on EUDI Wallets for natural persons. The mandatory attributes of the PID (Person Identification Data) form the foundation of every EUDI Wallet for natural persons.
A comparable, standardized dataset for legal persons does not exist across Europe, making it inherently difficult to establish a dedicated EUDI Wallet solely for legal entities. For example, proofs of existence, legal form, characteristics, or representation rights of a company are stored in various national registries, which often lack comprehensive digital processing capabilities.
Developing a dedicated EUDI Wallet for legal persons remains a distant goal, as the corresponding ecosystem has yet to evolve.
Instead of aiming for a universal EUDI Wallet for legal persons, specialized wallets within specific, closed ecosystems could provide a practical alternative. These wallets could adapt selected elements of a EUDI Wallet to meet the specific needs of companies. For instance, modules from EUDI Wallets for natural persons could be combined with tailored components to verify representation rights.
For now, a dedicated EUDI Wallet for legal persons remains a vision. Complexities such as the wide variety of legal forms in Germany and the existing challenges with PID for natural persons underscore how far away this goal is. In the meantime, specialized solutions within specific ecosystems that integrate elements of EUDI Wallets could serve as a practical alternative.
11. What Can Companies Do Now?
EUDI Wallets are expected to become certified and market-relevant at the earliest by the end of 2026. However, it is not unlikely that the timeline for their launch will face further delays. While their practical relevance among citizens will take time to develop, regulated and large companies are required to accept EUDI Wallets for customer identification (onboarding) and as an authentication channel (2FA) from the outset.
The acceptance obligation raises fundamental questions for companies, as EUDI Wallets introduce new technical and procedural standards that must be integrated into existing systems. After establishing a foundational understanding of the implications within the organization, companies need to validate established interfaces and business processes for EUDI Wallet compatibility. Decisions regarding the scope, timeline, and priorities of adjustments must then be made, and systems must be prepared accordingly. Ideally, these changes should be tested through pilot applications and proof-of-concept implementations well before the market launch. Therefore, it is advisable to start these initiatives early.
Verimi has extensive expertise and experience in integrating ID Wallet-based processes and offers support in validating your organization’s readiness for EUDI Wallet compatibility.
Classification – How Do EUDI Wallets Impact Verimi’s Offerings?
EUDI Wallets and eIDAS standards are an integral part of Verimi’s service portfolio. The standards for “verified credentials” are already a productive component of the Verimi ID Wallet.
In Verimi’s identification services, EUDI Wallets and identity verification via the EUDI Wallet will—once available—be offered alongside all established identification methods for Verimi’s partners. Users will be able to verify their identity using the EUDI Wallet conveniently as an alternative to methods like Photo-Ident, Bank-Ident, Video-Ident, and Local-Ident. The Verimi ID Wallet itself will be updated to comply with all relevant EUDI Wallet standards as soon as practical and will be approved as an EUDI Wallet. For partners, the relevant datasets and protocols will be expanded, while existing integrations will remain functional.
In Verimi’s white-label platforms, the EUDI Wallet will be available “as a service.” Verimi develops and operates customized identity management solutions for its partners. This includes solutions ranging from closed ecosystems for company-specific applications to company-specific EUDI Wallets as part of the open ecosystem for digital identities in Europe.
To pilot individual components or business processes, productive proof-of-concept applications can be deployed for initial testing.
Fundamentals of the EUDI Wallet
Here is a summary of the key aspects of the EUDI Wallet for your reference. Please note that as of late 2024, the finalization and approval of several details by the EU and national bodies are still ongoing, meaning that certain elements may change.
What Is the Core Identity (PID) of EUDI Wallets?
The core of the EUDI Wallet consists of the Personal ID Data (PID), which includes fundamental personal data such as name, date of birth, place of birth, ID document details, and nationality, mandatory for all EU member states. Optional attributes may include address and ID number.
In Germany, the core identity is derived from the eID (online ID function), ensuring a high level of assurance (LoA High) for populating the German EUDI Wallet. In other European countries, national frameworks define how the core identity is captured in their respective EUDI Wallets.
The core identity (PID) serves as the foundation for identification, authentication, and digital signatures within the EUDI Wallet. This enables companies and public institutions to reliably utilize digital identities and related verified attributes, making processes like onboarding and customer verification more efficient and secure—even across EU borders.
What Additional Attributes and Evidence Can Be Stored in the EUDI Wallet?
In addition to the PID, users can add supplementary attributes and proofs to their personal EUDI Wallet. These include:
- Verified contact details (e.g., address, email address, phone numbers).
- Verified proofs of qualifications, permits, characteristics, or rights (e.g., driver’s licenses, educational certificates, professional certifications, or authorizations).
These verified attributes allow for seamless and rapid use of many existing or emerging digital applications, such as public administration, education, financial services, or mobility.
The qualified verification of attributes is enabled under the eIDAS regulation by introducing a new trust service: Qualified Electronic Attestation of Attributes (QEAA). Qualified trust service providers (qTSPs) are authorized to verify and confirm the authenticity of attributes. The “qualified” status is particularly important for cross-border applications.
What Is the eIDAS Regulation and Its Connection to the EUDI Wallet?
The EUDI Wallet is based on the updated eIDAS regulation (eIDAS 2.0), which mandates all EU member states to introduce a digital wallet by the end of 2026 to unify citizens’ digital identities. By 2027, businesses will be required to accept the EUDI Wallet. The goal is for at least 80% of the EU population to use EUDI Wallets by 2030.
How Are EUDI Wallets Implemented Technically?
The EU and its member states have defined technical specifications in the Architecture and Reference Framework (ARF) to ensure that EUDI Wallets are based on a unified standard and are interoperable across Europe. In Germany, the development process is already underway, using national standards like the eID as a foundation.
What Are the Benefits of EUDI Wallets for Citizens?
The EUDI Wallet offers numerous advantages, especially in simplifying daily processes. By securely storing verified documents like ID cards, driver’s licenses, or other attributes, EUDI Wallets enable fast and secure processes in both public and private sectors.
Users can authenticate themselves online across Europe without repeatedly entering or verifying the same information. Additionally, they retain full control over their data, deciding which information to share and with whom (selective disclosure).
Moreover, the EUDI Wallet allows users to create Qualified Electronic Signatures (QES) directly within the wallet, simplifying and legally binding digital agreements like contracts.
What Are the Benefits of EUDI Wallets for Companies?
EUDI Wallets offer significant efficiency gains in digital business processes. The high level of assurance (LoA High) and quick verification of digital identities help companies reduce costly and time-consuming identity and attribute verification processes. This is especially crucial for businesses that must comply with regulatory requirements, such as KYC processes.
EUDI Wallets also provide flexibility by enabling the inclusion of verified attributes of all kinds, making digital business processes more efficient or even feasible in the first place due to the secured trust network.
Are Companies Required to Accept EUDI Wallets?
- Regulated industries: Yes, eIDAS 2.0 mandates that regulated sectors must accept EUDI Wallets as a means of identification and authentication.
- Non-regulated industries: Very large platforms are also required to accept EUDI Wallets. Other companies can choose to accept them on a voluntary basis.
It is important to note that all certified EUDI Wallets across Europe must be accepted without discrimination. Acceptance partners cannot choose or favor specific EUDI Wallets, which will also impact potential commercial billing models for verified attributes.