European Union · Identity

eIDAS 2.0: the EU Digital Identity Wallet and who has to accept it

Regulation (EU) 2024/1183 requires every member state to offer its people a digital identity wallet. Private firms that must use strong user authentication will have to accept it on request, and the AML rules let firms use it to verify identity.

In brief
  • Each member state must make at least one EU Digital Identity Wallet available within 24 months of the core implementing acts entering into force. Those acts took effect on 24 December 2024, which puts the deadline at about 24 December 2026.
  • Private relying parties that must use strong user authentication by law or contract must accept the wallet when a user asks, within 36 months of the same acts: about 24 December 2027 (Art 5f(2)).
  • Micro and small enterprises are exempt from that acceptance duty, so most accounting and law practices are not required to accept the wallet.
  • From 10 July 2027 the EU AML Regulation lets firms verify identity with eIDAS electronic identification at 'substantial' or 'high' assurance (AMLR Art 22(6)).

European Union · Identity · European Commission and national supervisory bodies · Reviewed 5 Nov 2026

Industries: All industries

What it is

What it is

Regulation (EU) 2024/1183, known as eIDAS 2.0, amends the 2014 eIDAS Regulation on electronic identification and trust services. Its main addition is the European Digital Identity Wallet (EUDI Wallet): an app, issued by or for each member state, that holds a person's identification data and other attested attributes, and can sign with a qualified electronic signature.

The wallet is under the user's control. Users choose what to share, and the wallet must support selective disclosure, so a user can prove one attribute without handing over everything (Art 5a(4)). Issue, use and revocation are free for individuals (Art 5a(13)). Use is voluntary, and people who do not use a wallet must not be disadvantaged in getting public or private services (Art 5a(15)).

The detail sits in Commission implementing regulations. The first five were adopted on 28 November 2024, published on 4 December 2024 and entered into force 20 days later. The Commission's page lists them. The wallet deadlines run from that date.

Who it applies to

Who it applies to

The duties fall on governments and some private firms. For most of StackGo's usual customers the wallet is something clients may bring, and accepting it is a choice.

  • Member states: provide at least one wallet, at assurance level 'high' (Art 5a(1) and (11)), and accept it for public online services that need electronic identification (Art 5f(1))
  • Private relying parties, other than micro and small enterprises, that law or contract requires to use strong user authentication for online identification, in sectors such as transport, energy, banking, health and telecommunications (Art 5f(2))
  • Very large online platforms that require user authentication (Art 5f(3))
  • Any other firm that chooses to rely on the wallet, which must first register as a relying party (Art 5b)

A small enterprise in EU terms has fewer than 50 staff and turnover or a balance sheet of EUR 10 million or less. Even where acceptance is voluntary, EU clients will start to hold wallets and may expect to use them.

The obligations

What you have to do

These duties apply to a firm that must accept the wallet, or chooses to. Each one is matched to the kind of work that meets it.

  1. Decide whether the acceptance duty binds you

    Check your size against the micro and small enterprise exemption, and whether any law or contract requires you to use strong user authentication for online identification. If neither applies, acceptance is voluntary.

    Scoping decision
  2. Register as a relying party

    Before relying on wallets, register in the member state where you are established. Give your name and registration number, contact details, and the intended use, including the data you will ask users for (Art 5b(1) and (2)).

    One-off, then keep current
  3. Ask only for the data you registered

    You must not request data beyond what your registration lists (Art 5b(3)). Design your onboarding request around those registered attributes.

  4. Accept the wallet as a verification route

    Where the duty applies, accept the wallet when the user asks. For AML customer due diligence, eIDAS electronic identification at 'substantial' or 'high' assurance is one of the two verification routes in AMLR Article 22(6).

  5. Keep other routes open

    Wallet use is voluntary for users, so keep a document-based check for clients who do not use one (Art 5a(15)).

Commonly misread

What firms get wrong

The wallet changes how identity is proven. It does not change what due diligence has to cover.

Every regulated firm must accept the wallet from 2027.

Article 5f(2) covers private relying parties required to use strong user authentication, and it excludes micro and small enterprises. Many professional firms fall outside it and accept the wallet only if they choose to.

A wallet check completes customer due diligence.

The wallet proves who someone is. The AMLR still requires beneficial ownership, sanctions and PEP checks, and risk assessment on top of identity verification.

The deadlines are fixed calendar dates.

The Regulation counts 24 and 36 months from the entry into force of the implementing acts. The dates of about 24 December 2026 and 24 December 2027 are calculated from the 24 December 2024 start, and national rollout dates vary.

Key dates

What happens when

  1. In force

    Regulation (EU) 2024/1183 enters into force (published 30 April 2024) Source

    Confirmed by secondary sources; the regulator has not published the exact date.

  2. In force

    First wallet implementing regulations enter into force (published 4 December 2024) Source

    Confirmed by secondary sources; the regulator has not published the exact date.

  3. Commencing

    Each member state must make at least one EUDI Wallet available (calculated: 24 months from the implementing acts, Art 5a(1)) Source

    Confirmed by secondary sources; the regulator has not published the exact date.

  4. Commencing

    EU AML Regulation applies, including the eIDAS verification route in Art 22(6) Source

  5. Commencing

    Private relying parties required to use strong user authentication must accept the wallet on request (calculated: 36 months, Art 5f(2)) Source

    Confirmed by secondary sources; the regulator has not published the exact date.

Also on the regulatory timeline.

Questions

Questions people ask

What is eIDAS 2.0?

eIDAS 2.0 is Regulation (EU) 2024/1183, which amends the EU's 2014 rules on electronic identification and trust services. It creates the EU Digital Identity Wallet and sets who must offer and accept it.

When will EUDI Wallets be available?

Each member state must offer at least one wallet within 24 months of the core implementing acts entering into force, which works out to about 24 December 2026. Some countries may launch earlier or in stages.

Do businesses have to accept the EUDI Wallet?

Only some. Private firms that law or contract requires to use strong user authentication, other than micro and small enterprises, must accept it on request from about 24 December 2027. Very large online platforms must also accept it. Other firms may choose to.

Can an EUDI Wallet be used for AML identity checks?

Yes. From 10 July 2027, AMLR Article 22(6) lets firms verify identity with eIDAS electronic identification at 'substantial' or 'high' assurance. The wallet is issued at 'high'. See the EU AML package.

Where StackGo fits

Where StackGo fits

StackGo is compliance middleware. IdentityCheck verifies identity with a document and selfie check, which is the document route in AMLR Article 22(6). It does not accept EUDI Wallets today, so a firm that wants the wallet route needs another provider for that step.

What IdentityCheck covers today
  • Biometric identity verification: a photo of a government ID document plus a live selfie with liveness, covering 12,500 document types from 230+ countries and territories, for clients who do not use a wallet.
  • PEP, sanctions and adverse media screening, with ongoing monitoring of screened clients, which a wallet check does not replace.
  • Onboarding forms and risk assessment forms with scoring and enhanced due diligence steps.
What it does not do
  • It does not accept EUDI Wallets or other eIDAS electronic identification.
  • It does not register firms as wallet relying parties.
  • It gives no legal advice on whether Article 5f(2) applies to you.

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