eIDAS2 Implementers Guide
All you need to become eIDAS2 compliant.
This guide gives you the why and the how: a clear overview of eIDAS2, the ARF, and the LSPs, followed by role-based responsibilities and step-by-step guidance to achieve compliance—whether you build in-house or use proven solutions.
Introduction
This eBook shows you how to make your organization eIDAS2-compliant, following a simple structure:
Learn: a high-level overview of eIDAS2 and the core terms—the Architecture and Reference Framework (ARF), Large-Scale Pilots (LSPs), the Implementing Acts, and the PID—plus a timeline so you know exactly when compliance is required.
Plan: the use cases eIDAS2 enables; the ecosystem actors (Issuers, Verifiers, and Wallet Providers) and the responsibilities, requirements, and go-to-market options for whichever role your organization falls into.
Build: a deep dive into each role (Issuer, Verifier, Wallet) and their sub-types—such as issuers of PID, PuB-EAA, QEAA, and EAA, and wallets (eIDAS2-certified and organizational/commercial)—with concrete technical requirements so you can start building.
Once you have read this eBook, you should be well equipped to start your eIDAS2 journey and will be able to ensure compliance before the upcoming regulatory deadlines.
Learn | eIDAS2
The problem eIDAS2 solves
In 2016 the eIDAS (electronic Identification, Authentication and Trust Services) regulation created a framework for cross‑border electronic identification. It focused on a small set of trust services, notably electronic signatures, and left wide latitude to Member States. As a result, national implementations diverged, interoperability remained limited and citizens lacked a harmonised digital identity. During the pandemic, physical presence requirements made identity proofing difficult and fragmentation slowed adoption beyond the public sector.
The eIDAS2 regulation
eIDAS2 (Regulation (EU) 2024/1183) was created to address these shortcomings by introducing European Digital Identity (EUDI) wallets for every EU citizen. Its main goals are to provide user‑controlled digital identities, reduce fraud and enable trustworthy digital interactions across borders.
Under eIDAS2:
Governments must issue digital identity credentials and provide wallets.
Citizens receive a Person Identification Data (PID) credential from their Member State as well as other types of identity credentials .
Businesses are required to accept these credentials for onboarding and authentication.
High levels of security and privacy are mandated and compliance is audited.
Wallets support selective disclosure so users can share only what is necessary.
The regulation effectively bootstraps the market by forcing the issuance and acceptance of digital identity credentials in all EU member states. This accelerates adoption and lowers the “cold‑start” barrier for decentralised identity solutions.
If you want to learn more about eIDAS2 and its impact on governments and business across industries, check out our “eIDAS2 is here” ebook.
The Architecture and Reference Framework (ARF)
The Architecture and Reference Framework (ARF) is the technical companion to eIDAS2 describing how the “law” could be implemented in practice. It defines:
High-level requirements for each party (Issuer, Relying Parties aka. Verifiers and Wallet Providers).
How parties must interact to ensure ecosystem security, user privacy and EU-wide interoperability.
Common schema catalogues and a shared trust infrastructure (with issuer catalogues) to ensure the authenticity and reliability of digital interactions.
The ARF is published on the official EUDI Wallet Dev Hub (GitHub) here, with releases and updates announced on the European Commission's EUDI Wallet site here.
The Large-Scale Pilots (LSPs)
The Large-Scale Pilots (LSPs) are EU-funded, cross-border projects that implement the ARF in real services. They validate protocols (OID4VCI/OID4VP, ISO/IEC 18013-5/-7), data formats (SD-JWT VC, mDL, selected W3C VC profiles for EAAs), Wallet Unit components (WSCD, WUA/WIA/WTE) and end-to-end user journeys across Member States.
Four LSPs have been successfully concluded (POTENTIAL, EWC, NOBID, DC4EU) while two (APTITUDE, WE BUILD) started in 2025 and are currently active. More details on each LSPs focus below:
POTENTIAL - Pilots the EUDI Wallet across six sectors: government services, banking, telecom, mobile driving licence, electronic signatures, and health; runs cross-border interoperability tests (e.g., mDL and e-prescription trials).
EWC - Focused on Digital Travel Credentials (DTC) and end-to-end travel flows, building on the Commission’s reference wallet.
NOBID - Concentrates on the payments use case for domestic and cross border usage with the wallet, piloted by Nordic-Baltic countries plus Italy and Germany.
DC4EU - Targets education, professional credentials/qualifications, and social security, providing feedback to the Commission on interoperability and scalability.
APTITUDE - Tests the wallet across a broad range of use cases including travel and mobile vehicle registration certificates (mVRC); aims to demonstrate interoperability, usability and scalability.
WE BUILD - Focuses on business and payment use cases that streamline B2B, B2G, and B2C processes.
The findings of LSPs (interoperability gaps, edge-case UX, policy clarifications) will feed back into the ARF.
The Implementing Acts
The implementing acts turn the high-level eIDAS2 regulation into concrete rules and laws building on top of the ARF and the LSP results. The rules come in dedicated regulations (list below & in Annex)–covering core functionality, protocols, PID/EAA data handling, certification, notifications and registers–everything needed so ID wallets (and their ecosystem) can become a reality across member states.
Below is an excerpt of the list of already adopted regulations. In the Annex you can find the full list.
(EU) 2024/2979 — Integrity & core functionalities of EU Digital Identity Wallets.
(EU) 2024/2982 — Protocols and interfaces to be supported by the EU Digital Identity Framework.
(EU) 2024/2977 — Person Identification Data (PID) & Electronic Attestations of Attributes (EAAs) issued to wallets.
The PID
The Person Identification Data (PID) is a special type of digital credential defined under the eIDAS2 regulation. It’s issued by appointed institutions (“PID Providers”) in each member state to their citizens and will act as the core “digital ID” that is recognised across member states. A PID will be required to “activate” and use an eIDAS2 certified wallet.
Mandatory attributes of a PID:
Family Name
Given Name
Birth Date
Birth Place
Nationality
Optional attributes of a PID include:
Resident Address
Resident Country
Resident State
Resident City
Resident Postal Code
Resident Street
Resident House Number
Personal Administrative Number
Portrait
Family Name Birth
Given Name Birth
Sex
Email Address
Mobile Phone Number
Note: The mandatory and optional attributes of a PID are defined in the (EU) 2024/2977 regulation.
The Timeline
While eIDAS2 entered into force in May 2024. Governments and businesses will have till the end of 2026 or 2027 to become fully compliant.
Governments (Member States)
Must launch at least one EUDI wallet per member state by the end of 2026.
Must ensure qualified trust service providers (QTSPs) have a way to verify required user attributes against authentic sources by the end of 2026
Must ensure public-online services that already ask for eID/auth today, accept EUDI wallets once available.
Businesses (Relying Parties - Verifiers)
Private-Sector businesses that require e.g. strong user authentication (e.g. transport, energy, banking/financial services, …) and are not micro or small enterprises (< 50 employees & ≤ €10 million annually), must enable EUDI wallet usage for user authentication (sign-in, step-up auth, onboarding) by the end of 2027.
Very Large Online Platforms (≥ 45 million average monthly users in the EU) must accept EUDI wallets for user authentication (sign-in, step-up auth, onboarding) as soon as the wallets are available (approx. end of 2026).
The timelines and use cases above mark when organisations and Member States must comply by law. But they’re only the starting point. As millions of users gain access to a digital ID wallet, businesses can deploy many more use cases to cut costs, streamline processes, reduce fraud and deliver a better UX. The businesses that move quickly can gain a first-mover advantage in the space.
Plan | Steps to Get Started with eIDAS2
In the upcoming section, we look at the various use cases that digital IDs under eIDAS2 enable and help you decide which of these might be a good starting point for your organization.
As any digital ID ecosystem consists of actors (Issuers, Verifiers, and Wallet Providers), we will also explore who they are—their responsibilities and requirements.
Finally, we will look at the options for bringing a working solution to market.
Use Cases
Digital identity will touch virtually every sector and industry across the EU. From governments to businesses, the opportunities are immense:
cutting costs,
streamlining operations,
automating manual processes,
reducing fraud and creating
more seamless user experiences.
The most common ones—and those legally required under eIDAS2 (as discussed in “The Timeline” section)—center around user authentication. This includes:
sign-in/sign-up,
step-up authentication (extra-auth),
user onboarding in general.
To understand the impact, let’s take a closer look at the user onboarding journey and compare how it works today versus how it will work with digital IDs:
Beyond Authentication
While authentication and onboarding are the starting point, there are various other use-cases that digital IDs will unlock across industries. A few examples include:
| Industry | Use-Cases |
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Financial services
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Healthcare
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Education
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Travel & Mobility
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Public services
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Employment
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eCommerce & Retail
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Real estate & Housing
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Telecommunications
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Legal & Notarial Services
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How to Pick a Use Case
Generally speaking, if you are a government or technology provider for governments, use-cases with a legal deadline (as explained in “The Timeline" section) become the highest priority. The same goes for larger businesses that require strong user auth and don’t fall under the exemption rule of micro or small enterprises.
That being said, the highest priority use-cases are:
Wallets | Actor: Wallet Provider
Governments (each member state) must provide an eIDAS2 compliant wallet solution by the end of 2026.
Online User Authentication | Actor: Relying Party (Verifier)
Large businesses must enable user-auth with wallets by the end of 2027 while Very Large Online Platforms and public-services (e.g., government services) must enable it as soon as wallets are available (approx. end of 2026).
For detailed user flows, please see the Use-Case section above.
Use case without a regulatory deadline
All other use-cases don’t have a legal deadline and can therefore be prioritized on a case-by-case basis. As a helper, you can use the following matrix.
First, take a sub-set of use cases listed above (e.g. use onboarding, authentication, ID wallet, check-out), which are relevant to your organization and prioritize them based on your strategy and product or service portfolio.
This matrix offers a simple way to prioritize use cases based on their impact on your organization (RoI) and ease of implementation (resources, time).
Here’s a few tips on how to use the matrix:
You can find a more detailed list for prioritizing use cases in the Annex.
Explained: Issuer, Verifier, Wallet Provider
Below, we define Issuer, Verifier and Wallet Providers–the required actors for any digital ID ecosystem–and their responsibilities and high-level requirements under eIDAS2. The more detailed technical requirements, we will discuss in the upcoming “Build” section.
The Issuer
Issuers are governments and/or businesses that attest claims about a user or legal entity (e.g. name, VAT ID) in the form of a digital credential, also called Electronic Attestations of Attributes (EAAs) in eIDAS2 terms. These credentials are a piece of data that is cryptographically signed by a key only the issuer controls and verified using the public counterpart of the key. Trust is established through official lists and registries each actor (Issuer, Verifier and Wallet Provider) must be listed on in order to be trusted by other actors in the ecosystem. The credential data format will follow technical standards such as mdoc/mDL, SD-JWT VC IETF and/or W3C VC v2.0 and are delivered over the internet to end-users using protocols like OID4VCI/ISO-18013-7.
Under eIDAS2 the credentials (attestations) issuers can issue are divided into five categories:
Person Identification Data (PIDs) - PIDs are the core “digital ID” attribute set (e.g. name, address, nationality, …) every wallet user gets issued by the PID Providers in each member state.
Legal Person Identification Data (LPIDs) - LPID is the counterpart for natural persons PID for legal persons (e.g. companies, organisations, institutions) also issued by the PID Providers in each member state.
Public Body Authentic Source Electronic Attestation of Attributes (PuB-EAAs) - PuB-EAAs are official documents (e.g. birth certificate, residence permits, tax IDs) in their digital form and they hold the same legal value as their paper counterpart. They are issued by registered PuB-EAA providers.
Qualified Electronic Attestation of Attributes (QEAA) - QEAAs are attestations whose attributes are verified against authentic sources (e.g. company formation documents sourced from a Companies Register). They also hold the same legal value as paper documents. They are issued by registered qualified trust service providers.
Non-Qualified Electronic Attestation of Attributes (EAAs) - are all other types of attestations (e.g. boarding passes, online learning badges, membership cards, gym passes). They are issued by non-qualified trust service providers.
The concrete attributes (e.g. name, address, …) of each credential type (e.g. PID, QEAA, EAA) and sub-type (e.g. birth certificate, boarding pass) will be defined via so-called rulebooks. The rulebook, next to the schema of the credential, might also define sector specific rules (e.g. for banking) and information on if a credential must be revocable or not.
In the table below you will find the high-level requirements overview for each issuer of the different attestation types.
| Requirement | PID/LPID | PuB-EAA | QEAA | EAA |
|---|---|---|---|---|
| Register as Issuer (become trusted actor in the ecosystem) | ✅ | ✅ | ✅ | ✅ |
| User Identity Proofing with Level of Assurance High before issuance | ✅ | ✅ (can use PID for LoA) | ✅ (can use PID for LoA) | – (depends on the rulebook) |
| Authentication of the wallet before issuance | ✅ | ✅ | ✅ | ✅ |
| Support credential standards ISO/IEC 18013-5 & SD-JWT VC (IETF) | ✅ | ✅ | ✅ | ✅ |
| Support credential standards W3C VC VCDM v2.0 | – | – | – | ✅ |
| Support for the OID4VCI / ISO-18013-7 issuance protocols | ✅ | ✅ | ✅ | ✅ |
| Issued credential must contain a status (e.g., revocation if validity > 24h) | ✅ | ✅ | ✅ | – (depends on the rulebook) |
| Ensure alignment with attestation rulebook | ✅ | ✅ | ✅ | ✅ |
| Provide embedded disclosure policies which specify who (relying party) may receive the credential | - | Optional | Optional | Optional |
The Verifier (Relying Party)
Verifiers are governments and/or businesses that want to request and verify a set of claims about a user (e.g. is over 18). Verifiers, like Issuers, will need to be registered in order to be trusted by the wallet. They will need to support the required credential exchange protocols like OID4VP/ISO-18013-7 for online verifications and ISO-18013-5 for offline verification depending on their use-case. As well as, be able to interpret the different credential formats and types (e.g. mdoc/mDL, SD-JWT VC IEFT, W3C VCDM v2.0).
In the table below we will see the high-level requirements overview for relying parties depending on if they operate online or offline.
| Requirement | Online | Offline |
|---|---|---|
| Register as Verifier (become a trusted actor in the ecosystem) and state which attributes you want to request. | ✅ | ✅ |
| Support credential standards SD-JWT VC (IETF) & W3C VC VCDM v2.0 | ✅ | – |
| Support credential standards ISO/IEC 18013-5 | ✅ | ✅ |
| Support for the OID4VP / ISO-18013-7 verification protocols | ✅ | – |
| Support ISO-18013-5 verification protocol (offline) | – | ✅ |
| Ensure to request only attributes listed during registration | ✅ | ✅ |
| Validate presented credential (signature check, user binding check, rulebook-specific checks, …) | ✅ | ✅ |
| Keep logs relating to an identity matching process and its outcome (max 12 months) | ✅ | – |
| Support pseudonym authentication (if user identity not required by service) | ✅ | – |
| Allow remote presentation via the W3C Digital Credentials API once the API is fully standardised & supported | ✅ | – |
The Wallet Provider
Wallet providers under eIDAS2 are either
member states or
certified organisations that offer wallets to users.
They must only deliver the software (the Wallet Instance) and ensure it fulfills all security requirements to reach Level of Assurance “High”. They are responsible for issuing Wallet Unit Attestations which are digital credentials stating the technical capabilities of the wallet during the wallet activation process. The attestation will be used in exchanges with other ecosystem participants such as Issuers to establish trust. Also, wallet providers must ensure the wallet supports all required exchange protocols (e.g. OID4VCI) and credential formats (e.g. mdoc/mDL). They must manage the whole lifecycle of wallets from installation, activation, management and uninstallation, while ensuring the user retains sole control over their digital IDs.
Next to the certified wallet providers, there will also be a market for non-certified wallets for consumers or businesses use cases where certification is not required. Organisations that already have a strong, trusted user base could enhance their apps with wallet capabilities and thereby become an even stronger focus in the everyday life of their users. Every time users need to access their credentials, they’ll open their ID wallet app, deepening engagement and opening moments for value capture. Early movers in industries like banking and finance, tech and telecommunications, social media and large platforms, travel, education and health care providers therefore greatly benefit from increased app usage by becoming an everyday identity hub for their users and their digital lives.
In the table below we will see the high-level requirements overview for wallet providers (certified or non-certified).
| Requirement | Certified | Non-Certified |
|---|---|---|
| Distribute the wallet solution via the official OS app stores or side-loading. | ✅ | ✅ |
| Enforce OS-level user auth | ✅ | Optional |
| Prompt user for provider account setup + link account to wallet unit instance | ✅ | Optional |
| Use device WSCA or deploy remote HSM for key management | ✅ | ✅ |
| Activate wallet unit only if at least one WSCA/WSCD is certified for LoA. | ✅ | Optional |
| Issue Wallet Unit Attestation (WUA) | ✅ | Optional |
| Support credential standards ISO/IEC 18013-5 & SD-JWT VC (IETF) & W3C VC VCDM v2.0 | ✅ | No requirement for all types |
| Support for the OID4VP/ISO-18013-7 verification protocols | ✅ | No requirement for all standards |
| Support for the OID4VCI/ISO-18013-7 issuance protocols | ✅ | No requirement for all standards |
| Provide Trust Mark View (user can verify certification status) | ✅ | – |
| Ingest & use trusted lists | ✅ | Optional |
| Publish trust anchor & enable trust processing by other parties (e.g. Issuers) | ✅ | Optional |
| Present requested attributes & party details when user interacts with relying parties | ✅ | Optional |
| Maintain a transaction log of actions (presentation, issuance) available for users | ✅ | Optional |
| Provide backup, recovery, migration options | ✅ | Optional |
| Support pseudonyms and passkeys | ✅ | Optional |
| Enable users to create qualified electronic signatures/seals | ✅ | Optional |
| Enable issuance & remote presentation via the W3C Digital Credentials API once the API is fully standardised & supported | ✅ | Optional |
| Revocation and suspension management (e.g., user or PID provider requests revocation) | ✅ | Optional |
| Undergo conformity assessment by an accredited body and obtain a certification | ✅ | – |
Should my Organization be an Issuer, Verifier or Wallet Provider?
To understand into which role (Issuer, Verifier or Wallet Provider) your organization falls, let’s look at the following:
Issuer
| Guiding Question | Do we manage or control data that could be issued as a digital credential? |
| You're in this role if… | The data your org holds has legal, commercial, or operational value for you, partners, or the market. |
| Typical Examples | Government authority issuing PIDs, university issuing diplomas, health provider issuing insurance cards. |
Note: For more details on the type of issuer your organization might be (PID/LPID, QEAA, EAA) refer to the “Build” section.
Verifier (Relying Party)
| Guiding Question | Do we need to authenticate users or validate claims about them? |
| You're in this role if… | You must check identity attributes or entitlements to deliver a service or meet compliance needs. |
| Typical Examples | Bank verifying income statements, healthcare provider checking patient data, online platform requiring strong auth. |
Wallet Provider
| Guiding Question | Do we want to provide end-users with a digital wallet to store and present credentials? |
| You're in this role if… | You plan to ship and maintain a wallet app/service for users. |
| Typical Examples | eIDAS2-certified citizen wallets; non-certified enterprise/consumer wallets bundled with a product or service. |
Note: An organization may hold multiple roles at the same time (e.g. acting both as an Issuer and a Verifier).
Build vs. Buy
Now that you have a good understanding of the roles, high-level requirements and use cases, it is time to ask the question of whether you should build your own solution (in-house) or buy an existing one.
There are three options to choose from:
Build apps, buy infra (only build UI and apps, outsource infrastructure)
Build apps, own infra (use open source to own the infrastructure)
Build everything (build and maintain the whole stack in-house)
Each option comes with advantages and disadvantages:
What “build everything” really entails
Implementing an eIDAS2-aligned solution in-house means tackling multiple domains. Teams must implement and stay up-to-date with:
Credential standards: ISO/IEC 18013-5, SD-JWT VC (IETF), W3C VCDM 2.0
Exchange protocols: ISO/IEC 18013-7, OID4VCI, OID4VP
Key management: integrate a KMS or build your own
Revocation: sign/manage/publish Attestation Status/Revocation Lists
Data sourcing: connect authentic sources/DBs for issuance data
Disclosure policies: embed EDPs at issuance; interpret at verification
Privacy measures: e.g. avoid correlating issuance batches
Certification management: access certificates for issuers/verifiers and audits
… all of this is in addition to a product’s own applications and business logic.
The model most teams adopt: Build Apps, Buy/Own Infrastructure
Governments and businesses must adopt digital ID wallets, but struggle with:
Urgency from regulatory deadlines and competitive/customer pressure
Limited talent pool (protocols & standards) for building in-house
Technical complexity (PKI, KMS, sigs, credentials, protocols) raising failure risk
Fast-moving standards (W3C, OIDF, ISO, IETF, …) inflating maintenance cost
Compliance risks (e.g. from eIDAS2) increasing audit scope and liability
Most organizations want to launch applications and solutions quickly without owning technical and regulatory complexity and risks.
As a result, most organizations use existing infrastructure (open or closed-source) and build custom apps on top (inhouse or with partners). They prefer (open source) infrastructure that can be operated by themselves (“self-managed”) to maximize control, while offloading the most significant implementation work and complexity to existing solutions in order to reduce costs, risk and speed up time to market.
A starting point when it comes to open source solutions are e.g. the EUDI Wallet Reference Implementation (B2C wallet app) or the walt.id Community Stack (Issuer, Wallet, Verifier). When it comes to closed-source options you can take a look at the walt.id Enterprise Stack.
Since technology and vendor selection can be complex, we also created a checklist based on how other organizations across industries evaluate their options:
You can find a detailed checklist for technology and vendor evaluation in the Annex.
Build | Issuer, Verifier, Wallet & Technical Requirements
In this section, we take a closer look at the roles (Issuer, Verifier, Wallet Provider) introduced earlier. We’ll explore each role in more detail and outline the specific technical requirements they must meet. This will give you the knowledge for building your chosen use case.
Issuers
PID/LPID Providers (natural/legal person identifiers)
PID providers are organizations appointed by member states to issue PIDs/LPIDs. PIDs act as the core identity data credential which each eIDAS2 wallet must hold in order to be valid. “LPIDs” are the core identity data for legal persons.
The data set in the PID/LPID is officially defined, trusted and acts as the user's “digital ID” across all member states.
The PID:
For a detailed overview of the attributes of a PID, please refer to the section “The PID” at the beginning of this document
The LPID:
Mandatory attributes of an LPID:
Current Legal Name
Unique Identifier constructed by the issuing Member State (compliant with cross-border specifications)
Optional attributes of an LPID include:
Current Address
VAT Registration Number
Tax Reference Number
European Unique Identifier (Directive (EU) 2017/1132)
Legal Entity Identifier (LEI)
Economic Operators Registration And Identification (EORI) Number
Excise Number
Note: The mandatory and optional attributes of a PID/LPID are defined in the annex of the (EU) 2024/2977 regulation.
Organizations that want to become a PID provider need to fulfill the following requirements:
| Identity proofing and LoA |
PID providers must verify the identity of the wallet user at Level of Assurance (LoA) High.
Typical methods include:
|
|---|---|
| Wallet unit attestation verification |
Before issuing a PID, the provider must authenticate the wallet unit.
Required checks:
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| Issuance protocol and formats |
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| Status management & revocation |
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| Registration and trust lists |
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| PID Content and Data Integrity |
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| Privacy Enhancing Measures for Presentation |
|
PuB‑EAA and QEAA providers
PuB-EAA providers are public-sector bodies (public authorities) that want to issue their official documents as digital credentials. These digital credentials will hold the same legal status as their paper originals.
Examples include:
Government authorities - Ministries, Registries, Municipalities
Civil registries - Birth certificates, marriage certificates, death certificates
Immigration & residence authorities - Passports, visas, residence permits
Tax authorities - Tax IDs, income/tax reports
Social security agencies - Social insurance numbers, health cards
Driver licensing authorities - Driving licenses, vehicle registrations
Public universities (for diplomas with legal effect) - Degrees recognized in law
QEAA providers are certified private businesses or organizations that want to issue digital credentials containing official and verified data sets from public authorities (authentic sources). QEAA providers need to be Qualified Trust Service Providers, otherwise their issued digital credentials are EAAs from an eIDAS2 point of view.
Examples include:
Identity Verification Companies (IDVs) - Postal identity services or remote-ID providers authorized to attest identity/residence as digital credentials (e.g., Post-ID/Video-ID operators).
Accredited testing & inspection bodies (TIC) - Roadworthiness/vehicle inspection centers, metrology & conformity-assessment labs issuing statutory certificates.
Corporate service providers acting on official data - Company registrars’ agents or trust/corporate service providers attesting director/representative roles and UBO status against the business register.
Accredited private universities / schools (state-recognized) - Degrees/diplomas with legal effect.
Notaries / civil-law notaries - Notarial deeds, certified copies, company formation documents, or powers of attorney.
Organizations that want to become a PuB-EAA or QEAA provider need to fulfill the following requirements:
| Identity proofing and LoA |
Note:PuB-EAA providers, which are public sector bodies (such as government agencies) responsible for issuing electronic attestations of attributes, are not themselves Qualified Trust Service Providers (QTSPs). However, to ensure the trustworthiness and legal effect of the attestations they issue, a PuB-EAA provider obtains a qualified certificate from a QTSP. This qualified certificate then allows the PuB-EAA provider to legally and securely sign their attestations. When a third party (Relying Party) verifies such an attestation, they check the signature of the PuB-EAA provider (which is based on the certificate issued by the QTSP) and also verify the QTSP's certificate |
|---|---|
| Wallet unit attestation verification |
Before issuing a QEAA/PuB-EAA attestation, the provider must authenticate the wallet unit.
Required checks:
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| Issuance protocol and formats |
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| Status management & revocation |
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| Registration and trust lists |
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| QEAA and PuB-EAA Content and Data Integrity |
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| Embedded disclosure policies |
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| Privacy Enhancing Measures for Presentation |
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| Attribute sourcing |
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Non-Qualified EAA Provider
Non-Qualified EAA Providers are all types of private-sector businesses and organizations that want to issue digital credentials to streamline operations, reduce costs, and improve the user experience.
Examples include:
Commerce & Retail → loyalty cards, memberships, discount programs
Banking & Finance → customer onboarding, KYC-light checks, account access
Travel & Hospitality → hotel check-in, boarding passes, car rentals
Events & Entertainment → concert tickets, festival wristbands, sports passes
Education & Training → course completion certificates, student IDs, online learning badges
Workforce & HR → employee badges, professional training credentials, workplace access
Telecommunications & Utilities → SIM registration, service contracts, customer identification
Insurance → policyholder cards, claims process credentials
Mobility & Transport → public transport passes, bike/scooter rentals, parking permits
Clubs & Associations → membership cards, gym passes, NGO or community access
Organizations that want to become a Non-Qualified EAA provider need to fulfill the following requirements:
| Identity proofing and LoA |
|
|---|---|
| Wallet unit attestation verification |
Before issuing an EAA attestation, the provider must authenticate the wallet unit.
Required checks:
|
| Issuance protocol and formats |
|
| Status management & revocation |
|
| Registration and trust lists |
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| EAA Content and Data Integrity |
|
| Embedded disclosure policies |
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| Privacy Enhancing Measures for Presentation |
|
Wallet Providers (Certified)
Wallet Provider: A Member State or an organisation mandated/recognised by a Member State that provides the EUDI Wallet solution—operating the wallet for users and issuing wallet attestations/trust evidence for its management and authentication.
Wallet Unit: A specific, user-controlled configuration of a wallet solution—comprising the wallet app (wallet instance), secure cryptographic application and device—provided by a Wallet Provider to an individual user as the vehicle for storing and presenting PID and (Q)EAAs.
Organizations that want to become a Wallet Provider need to fulfill the following requirements:
| Wallet unit installation |
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|---|---|
| User accounts and authentication |
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| Wallet unit activation |
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| WUA issuance |
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| Protocols for issuance and presentation |
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| Trust mark and certification | Provide a Trust Mark view so users can verify certification status of the Wallet Solution. |
| Trust management |
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| User privacy & selective disclosure |
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| Transaction log | Maintain a transaction log accessible via the wallet’s dashboard; ensure the user can view, delete, or report transactions. |
| Revocation, backup, recovery and migration |
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| Pseudonym and passkey support |
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| Qualified electronic signatures/seals |
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| Digital Credentials API | Enable issuance and remote presentations via the W3C Digital Credentials API once it is fully standardized and broadly supported by relevant browsers and operating systems. |
| Accessibility and user experience | Ensure the wallet application meets accessibility standards (Directive (EU) 2019/882). |
| Revocation and suspension management |
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| Conformity assessment and obtain certification | Follow the Commission’s technical specifications for wallet units, undergo a conformity assessment by an accredited body, and obtain certification. |
Wallet Providers (Non-Certified)
Non-certified wallet providers are private-sector businesses that want to add to their existing apps or platforms digital-wallet capabilities without the formal eIDAS2 certification. This is ideal for many day-to-day use-cases where high-level compliance is not required.
Examples include:
Banking & Finance → account access, KYC-light, card controls
Telecommunications → SIM/eSIM registration, contract signing
Social Media Apps → age/attribute proofs, creator verification
Travel & Hospitality → boarding passes, hotel check-in, car rentals
Healthcare → patient IDs, e-prescription pickup
Education & Training → student IDs, course badges, exam eligibility
Commerce & Retail → loyalty, memberships, age-gated purchases
Events & Entertainment → tickets, passes, backstage credentials
Mobility & Transport → transit passes, bike/scooter rentals, parking
Workforce & HR → employee badges, building/IT access
Organizations that want to offer non-certified wallets need to fulfill the following requirements:
| User accounts and authentication (optional) |
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|---|---|
| Wallet unit activation (optional) |
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| WUA issuance (optional) |
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| Protocols for issuance and presentation |
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| Trust management (optional) |
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| User privacy & selective disclosure |
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| Transaction log (optional) |
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| Revocation, backup, recovery and migration (optional) |
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| Pseudonym and passkey support (optional) |
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| Qualified electronic signatures/seals (optional) |
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| Digital Credentials API (optional) | Enable issuance and remote presentations via the W3C Digital Credentials API once it is fully standardized and broadly supported by relevant browsers and operating systems. |
| Accessibility and user experience (optional) | Ensure the wallet application meets accessibility standards (Directive (EU) 2019/882). |
| Revocation and suspension management (optional) |
|
Verifiers (Relying Parties)
A relying party — also called a verifier — is a public or private service provider that, with the user’s approval, requests and verifies PID or EAA (QEAA/PuB-EAA/non-qualified EAA) attributes from an EUDI Wallet to deliver a service - for example opening a bank account, enrolling at a university, applying for a job, authorising a payment, or identifying yourself for a hotel booking.
Organizations that want to become a Verifier need to fulfill the following requirements:
| Registration and certificates |
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|---|---|
| Protocols for verification |
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| Request only registered attributes | The wallet verifies that requested attributes match those registered. If you request more attributes, the wallet warns the user and may refuse the request. |
| Validating presented credentials |
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| User approval and selective disclosure |
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| Data minimisation and retention |
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| Handling intermediaries |
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| Pseudonym and strong user authentication |
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| Digital Credentials API | Optionally allow remote presentation via the W3C Digital Credentials API once it is fully standardised and supported by relevant browsers and operating systems. |
Annex
List of Adopted Implementing Acts (eIDAS2)
Below is an overview of already adopted regulations grouped into four packages. The first and second packages are important for organisations and businesses that want to act as wallet providers, issuers and/or relying parties. The third package is mostly targeted towards issuers that want issue Q(E)AAs and/or run trust services. The fourth package focuses on qualified electronic signature, seal, time-stamping, registered delivery, validation and preservation services.
Note: The provided list is not yet complete as the Commission is still consulting on additional Implementing Acts right now.
Regulations Package 1:
(EU) 2024/2979 — Integrity & core functionalities of EU Digital Identity Wallets.
(EU) 2024/2982 — Protocols and interfaces to be supported by the EU Digital Identity Framework.
(EU) 2024/2977 — Person Identification Data (PID) & Electronic Attestations of Attributes (EAAs) issued to wallets.
(EU) 2024/2981 — Certification framework for EU Digital Identity Wallets.
(EU) 2024/2980 — Notifications to the Commission.
Regulations Package 2:
(EU) 2025/846 — Cross-border identity matching for natural persons.
(EU) 2025/847 — Reactions to security breaches of EU Digital Identity Wallets.
(EU) 2025/848 — Registration of wallet-relying parties.
(EU) 2025/849 — Submission of information for the EU list of certified wallets.
Regulations Package 3:
(EU) 2025/1566 — reference standards for verifying the identity/attributes when issuing qualified certificates or qualified EAAs.
(EU) 2025/1567 — management of remote QSCDs and QSealCDs as qualified trust services.
(EU) 2025/1568 — peer-review procedures for eID schemes.
(EU) 2025/1569 — (Q)EAAs and EAAs provided by/for a public-sector body responsible for an authentic source.
(EU) 2025/1570 — notification of information on certified QSCDs/QSealCDs.
(EU) 2025/1571 — formats and procedures for annual reports by supervisory bodies.
(EU) 2025/1572 — format/procedures for notification of intention & verification to start qualified trust services.
Regulations Package 4:
(EU) 2025/1929 — Lays down rules on binding date and time to data and on accuracy requirements for time sources used for qualified electronic time stamps.
(EU) 2025/1942 — Defines requirements for qualified validation services for qualified electronic signatures and qualified electronic seals.
(EU) 2025/1943 — Establishes reference standards for qualified certificates for electronic signatures and electronic seals.
(EU) 2025/1944 — Sets reference standards and interoperability rules for processes of sending and receiving data in qualified electronic registered delivery services (QERDS).
(EU) 2025/1945 — Specifies rules for validation of qualified electronic signatures and seals, and of advanced signatures and seals based on qualified certificates.
(EU) 2025/1946 — Lays down requirements for qualified preservation services for qualified electronic signatures and qualified electronic seals.
Guide for prioritizing use cases
Impact (ROI)
| Category | Description |
|---|---|
| Increase revenue | Streamline user flows such as by eliminating passwords, forms or multi-step identification processes during onboarding or check-out to increase conversion or lower dropout rates. |
| Lower costs | Enable online interactions that traditionally required in-person meetings or automate business processes to save costs and resources (e.g. for manual data processing) or even replace third-party services you are currently using to solve related issues with a single, unified solution. |
| Prevent compliance issues | Facilitate regulatory compliance especially with regards to data protection, eID, AML and other relevant regulations (e.g. GDPR, eIDAS2, AML) to avoid penalty payments and brand damage. |
| Prevent fraud | Ensure reliable stakeholder verification and introduce tamper-proof digital documents to prevent identity theft or document forgery. |
| Mitigate security risks | Eliminate main risk factors that cause data breaches such as passwords or aggregated data storage. |
| Strengthen your brand | Offer more seamless user experiences, strengthen security and enhance privacy by giving stakeholders control over their data. |
| Don’t fall behind | Finally, consider the impact on your business if competitors adopt decentralized identity before you do. |
Ease of implementation
| Category | Description |
|---|---|
| UI/UX | Evaluate how different actors in a use case interact and what it would take to offer users a seamless experience with new products or features. |
| Data | Identify what kind of data you will use, where and how this data is currently stored and processed, and whether it needs to be anonymized. |
| Deployment | Evaluate how solutions should be deployed, which environments are used, and the system requirements for staging, testing, and production. |
| Integration | Evaluate the complexity of the business processes and existing IT infrastructure or applications involved in the use cases. |
| Ownership | Identify which departments are involved in your use cases and how they make decisions, especially if you require buy-in for implementations. |
| Buy vs Build | Evaluate whether you will buy or build (potentially using open-source solutions) and how workload will be distributed among internal or external teams. |
Checklist: Technology and vendor evaluation
| Criteria | Description |
|---|---|
| Ecosystem Role | Ensure that your solution enables your business to take on the required role (PID, LPID, QEAA, PuB-EAA, EAA Provider, Relying Party or Wallet Provider). |
| Use Cases | Ensure that your solution fulfills your business requirements and can be used to implement your use cases. |
| Compliance | Ensure that your solution complies with all regulations required by your business operations (eIDAS2, GDPR, AML, TFR…). |
| Standards | Ensure that your solution supports all relevant open standards required by eIDAS2. For example, credential standards like Verifiable Credentials (W3C), SD-JWTs (IETF), mDL/mdoc (ISO) or protocols like OID4VCI/VP. |
| Open Source | Evaluate open and closed source solutions. Many organizations prefer open source solutions to maximize control, reduce vendor risk, ensure transparency on quality and security, and enable faster adoption at lower cost. |
| Flexibility | Solutions that allow you to mix-and-match or switch between different key-management solutions and cloud or trust services (QTSPs) help prevent vendor and technology lock-in and may be required to meet regulatory or business needs (certified KMS, local data storage, etc.). |
| Deployment | Pick a solution flexible enough to support your operational strategy. Consider how you want to run your ID infrastructure over the next years: self-managed on-prem or in your cloud vs. managed cloud services. |
| Integration | Ensure the solution integrates with your existing infrastructure and applications. Avoid rip-and-replace where possible and prevent vendor/technology lock-in. |
| Services | Verify whether vendors offer professional services (consulting, development, integration, technical support) directly or through partners. |
About walt.id
walt.id offers holistic open source digital identity and wallet infrastructure already used by 25K+ developers, governments and businesses globally.
Website: https://walt.id
GitHub (Open Source): walt.id identity
Developer hub: https://docs.walt.id
Contact: https://walt.id/contact
Further Readings

