ANALYSIS · DIGITAL IDENTITY
On 24 December 2026, all twenty-seven Member States will have to offer a certified European Digital Identity Wallet. Here, Europe is doing more than regulating: it is delivering. Building the wallet is not the biggest task; the challenge lies in enabling others to read it.
In eleven weeks, Europe delivers. On 24 December 2026, each of the twenty-seven Member States will have to offer its citizens at least one certified European Digital Identity Wallet, and its public administrations will have to accept it as a means of identification. Use will remain voluntary and free for individuals.
This is not a single application operated by the Union, but an interoperable ecosystem of wallets provided by Member States or under their responsibility, subject to common security, certification and interoperability requirements.
We are no longer at the consultation or roadmap stage. The next milestone is a delivery date. That is precisely why it is useful to revisit the round table on eIDAS wallets and the Business Wallet held at Salon Souveraineté Numérique. Because much of what was said there was not about the wallet itself.
A deadline for states, not businesses
The timetable deserves a careful reading, given how often it is misunderstood. December 2026 is frequently treated as a business deadline; in fact, it applies to states and their administrations. The obligation for the regulated private sector, including banks, to accept wallets comes a year later.
The criterion is authentication, rather than sector of activity. Article 5f of the Regulation covers private relying parties required by Union law, national law or a contractual obligation to use strong user authentication for online identification: banks, payment service providers, telecommunications, healthcare, transport and energy providers, together with very large online platforms. There are two important qualifications: micro and small enterprises are exempt, and the obligation is triggered only at the user's voluntary request. The wallet is an option that services must be able to accept, not a channel imposed on users.
Progress is highly uneven. An assessment of the twenty-seven Member States published this quarter ranked three countries as almost certain to meet the deadline, five as very likely, eight as likely, seven as uncertain and four as unlikely. An August 2026 review placed Denmark, France and Italy among the countries already offering publicly accessible solutions, with differing levels of compliance with the EUDI framework. Having an application does not, in itself, establish compliance: delivery depends on a combination of implementing acts, technical specifications that are still evolving and national certifications. The actual range of available functions will therefore differ between Member States immediately after the deadline.
Few wallets, many services to equip to read them
This was the point made most clearly by Florent Tournois, Director of Digital and National Identity at ANTS. France Identité is intended to become France's sovereign wallet, the national implementation of the European wallet. But there will be few providers of the wallet component itself. Most of the work ahead involves equipping services to receive digital proofs.
These services might include a prefecture, a bank, a landlord, an online retailer or an HR department. The session revealed an economic implication that is rarely articulated: if value is created on the receiving side, that is where the market lies. Wallet protocols also differ from traditional digital identity systems—a wallet intermediary does not store the data—which creates new roles rather than simply extending existing activities.
The Regulation also makes this an administrative obligation, not merely a technical one. Any relying party intending to use the wallet must register in the Member State where it is established, declaring its intended purpose and the data it will request. In other words, reading a wallet requires prior registration and requesting only the data declared. This is a new discipline for many organisations accustomed to collecting data broadly.
Romain Santini, who leads digital identity and eIDAS v2 at Docaposte, described his company's role as a technology provider and facilitator: helping organisations integrate the wallet into user journeys or issue attestations. He expressed a conviction worth highlighting in a sovereignty debate that is often tense: having several providers is healthy for the ecosystem. The state cannot do everything; technology providers take over on the business side.
What the wallet really changes is data, rather than identity.
Jérémie Baboukhian, Executive Advisor at DINUM, advocated a useful shift in the discussion: emphasising the 'why' rather than the 'how'.
It is also necessary to distinguish what the wallet carries. The European framework treats personal identification data—the basic identity details, such as surname, first name and date of birth—separately from electronic attestations of attributes, which may cover a diploma, a driving licence, a professional qualification or bank documentation. These are different objects, issued by different bodies and subject to different evidentiary regimes. A wallet does not simply 'store documents': it receives, holds and presents verifiable attestations. What the wallet delivers is, first and foremost, a change in the way data is handled. Less storage. Signed, tamper-proof data instead of scanned documents. Simpler and faster procedures. Cybersecurity benefits, and even environmental benefits, that follow directly from no longer circulating PDFs of identity documents.
This point is crucial. Any organisation collecting scanned supporting documents today—in other words, almost every organisation—holds sensitive data it does not need, yet must secure, retain and delete. The wallet does more than improve this situation: it removes the need for that data stock. DINUM described its role in this system as coordinating work across ministries, ensuring that all the components—certification, technology and data provision—are in place, building on FranceConnect and France Identité rather than starting from scratch.
Mature use cases, and those still to come
The round table drew clear conclusions about the maturity of use cases. For users, these include age verification, with '15+' and '18+' thresholds, which will be useful for social networks, casinos, alcohol sales and local retailers, among others; and proofs carried by other applications, such as a payment that includes proof of age. For organisations, the first use cases include strong authentication, banking KYC and issuing attestations.
The next deployments are expected to reach sectors such as healthcare, education and training, mobility and travel.
Businesses nevertheless expressed a reservation: before committing, organisations expect functional and legal assurances, not just technical ones. This is a signal that deserves attention fourteen months before the regulated sector's acceptance obligation takes effect.
Sovereignty: a trusted wallet, together with interoperability
The definition of sovereignty that emerged has the merit of being practical. It has two dimensions: protecting highly sensitive data, and enabling the controlled circulation of other data. It requires at least one national sovereign wallet that can always be relied upon, while embracing European interoperability, since that is what enables cross-border uses. Here again, interoperability cannot be established by the wallet alone: it requires a compliant, registered verifier connected to the trust chain and supporting the formats actually used. A French wallet will not work 'everywhere in Europe'; it will work with services compatible with the framework.
One principle remains unchanged: the link between the wallet and the individual remains a sovereign state responsibility, even within an interoperable Europe. Europe standardises the transfer of digital proofs; it does not take over civil registration.
As for concerns about privacy, state control and complexity of use, the answer came down to two principles: data minimisation and keeping users in control of their data.
The real test will be acceptance
A survey published on 8 September, based on 2,000 respondents in France and Germany, described a market in which awareness of the wallet remains low and consumer trust still needs to be earned. Eleven weeks before deployment, this is a signal it would be unwise to ignore.
December 2026 will mark the start of the real test. To prevent the wallet from becoming a European system that is technically impeccable but socially invisible, the decisive measure will be its use by public administrations, followed by regulated businesses over the next year.
Article contributed by Rémi Letemple
