EUDI, EUBW, d-you: What Does This Mean for Obliged Entities, and Do I Have to Accept Wallets?

According to the European legislator, digital identities are to play a central role, for instance in customer identification under the AMLR. At the heart of this, for natural persons, is the European Digital Identity (EUDI), which will launch in Germany on 2 January 2027 as "d-you". What does this mean for obliged entities that wish to use the EUDI wallet in future?

The (Reformed) eIDAS Regulation

The legal framework for digital identities is the eIDAS Regulation. The 2024 reform of eIDAS ("eIDAS 2.0") gave digital identification in the European Union a new legal framework. A key innovation of the reform was to create the legal conditions for identity wallets, in particular the EUDI wallet.

In Germany, the Digital Identities Act (Digitale-Identitäten-Gesetz, DIdG), which as of September 2026 is still in the legislative process, is intended to adapt national law on the acceptance of the EUDI wallet.

What Is the EUDI Wallet?

The European Digital Identity Wallet (EUDI wallet) is a digital means of identification with which users can securely store identity data and electronic attestations and present them to businesses. It is intended to be usable online and offline. The German EUDI wallet is scheduled to be available under the name "d-you" from January 2027.

The EUDI wallet contains person identification data (PID) for establishing identity and enables the presentation of electronic attestations of attributes (EAA), for example for driving licences, educational qualifications or other attributes. In addition, users can sign documents digitally with legal effect by means of a qualified electronic signature (QES).

For citizens, use of the EUDI wallet is voluntary and free of charge. Businesses can use the wallet in particular for digital identification and for verifying required evidence.

The German EUDI wallet is being developed under the name "d-you" and under the lead of the Federal Ministry for Digital Affairs and State Modernisation (BMDS). It is intended to make identification and verification processes more secure and efficient and, in particular, to allow businesses to simplify KYC processes, with the associated cost and security advantages.

Cross-Border Acceptance of Foreign EUDI Wallets

The EUDI wallet is designed to work across borders. Businesses subject to the acceptance obligation must therefore, in principle, accept not only the German "d-you" but EUDI wallets from all EU Member States. This makes cross-border KYC procedures possible in particular: customers from other Member States can identify themselves digitally and present evidence, which can reduce manual document checks and previous special procedures.

The interoperability required for this is ensured by common European standards and the Architecture and Reference Framework (ARF). Standardised data formats such as SD-JWT VC and ISO/IEC 18013-5 mdoc enable businesses to integrate different national wallets into their systems through uniform procedures.

Member States are taking different approaches to national implementation. While Germany with "d-you" and the Netherlands with the "Public NL Wallet" are developing new state wallets, Poland with "mObywatel" and France with "France Identité" build on existing digital identity solutions. Irrespective of the approach, the wallets must meet the European requirements and be interoperable across borders.

eIDAS, the EUDI Wallet and the AMLR

A central use case of the EUDI wallet is the storage of Person Identification Data (PID). PID means, quite generally, the identification of a person in various contexts – but in particular also identification for anti-money laundering purposes, as today under Section 10(1) GwG and in future under Art. 20 et seq. of the AMLR.

The PID process follows a standardised procedure for exchanging the data required for identification and for the wallet provider's confirmation of identity, which is specified in detail in the PID-based identification for online services Manual.

Do I Have to Accept the EUDI Wallet?

To date, the GwG leaves obliged entities free to choose the means of identification they use. eIDAS 2.0, by contrast, contains the following wording in Art. 5f(2) eIDAS 2.0:

Where private relying parties providing services, with the exception of microenterprises and small enterprises as defined in Article 2 of the Annex to Commission Recommendation 2003/361/EC ( ⁵ ), are required by Union or national law to use strong user authentication for online identification, or where strong user authentication for online identification is required by contractual obligation, including in the areas of transport, energy, banking and financial services, social security, health, drinking water, postal services, digital infrastructure, education or telecommunications, those private relying parties shall, no later than 36 months after the date of entry into force of the implementing acts referred to in Article 5a(23) and Article 5c(6) and solely upon the voluntary request of the user, also accept European Digital Identity Wallets provided in accordance with this Regulation.

There is no longer any mention of voluntary acceptance here. eIDAS sets out a firm acceptance obligation, subject to the conditions stated.

Which Businesses Are Obliged?

Private businesses must therefore accept the EUDI wallet if, on the basis of Union, national or contractual requirements, they require strong user authentication for online identification. Art. 5f names in particular the sectors of transport, energy, banking and financial services, social security, health, drinking water, postal services, digital infrastructure, education and telecommunications. However, belonging to one of these sectors does not in itself give rise to an acceptance obligation. What matters is that the further conditions of Art. 5f(2) eIDAS are met.

Microenterprises and small enterprises within the meaning of Recommendation 2003/361/EC are exempt from this obligation. The exemption does not, however, apply to medium-sized enterprises.

In the area of financial services, the obligation to use the wallet therefore already arises where there is a legal obligation to apply strong customer authentication, and thus for all credit institutions that maintain payment accounts and for payment service providers that must apply strong customer authentication. The Commission also expressly clarifies this in its FAQ.

Special Case: Very Large Online Platforms

A separate rule applies to very large online platforms (VLOPs) within the meaning of Art. 33 of the Digital Services Act. If they require user authentication, they must also accept the EUDI wallet at the user's request. Only the data required for the respective service may be requested.

Quick check: The following decision matrix shows, in simplified form, the conditions under which businesses must accept the EUDI wallet.

Voluntary Integration

Businesses that are not subject to the acceptance obligation remain free to accept the EUDI wallet voluntarily, given the associated advantages (integrity of the data, high level of identification assurance, evidence in case the customer disputes the conclusion of a contract, costs, etc.).

From When Does the Acceptance Obligation Apply?

A transitional period of 36 months after the entry into force of the relevant implementing acts applies to obliged private businesses. These entered into force on 24 December 2024. Businesses subject to the acceptance obligation are therefore obliged to accept the EUDI wallet for identification no later than 24 December 2027.¹

How Can Businesses Integrate the EUDI Wallet?

Registration as a Relying Party

Businesses that wish to use the EUDI wallet for identification or to retrieve digital attestations must register as relying parties (Relying Party). Implementing Regulation (EU) 2025/848 provides for national registers for this purpose. On registration, businesses must state in particular their identity and contact details, the intended purpose of use and the data or attributes to be requested via the wallet. On this basis, the business receives the permissions required to interact with the EUDI wallet.

The detailed design of the registration procedure in Germany, in particular the competent contact point and the operational process, is still being implemented.

Technical Connection and Architecture

The technical integration of the EUDI wallet follows the European Architecture and Reference Framework (ARF) and the relevant national requirements. Businesses can integrate the wallet into their existing systems and specialist applications through standardised interfaces.

Use of Service Providers and Intermediaries

Businesses do not have to implement the technical connection entirely themselves but can use specialised service providers or intermediaries for this. These support the integration of the wallet infrastructure into existing systems and processes.

Further information on possible integration partners is provided in the FAQ of the German EUDI wallet.

Testing in the State Sandbox

For technical testing, BMDS and SPRIND provide a national sandbox as a test environment. There, businesses can use test data to try out concrete use cases, in particular the handling of person identification data (PID) and electronic attestations of attributes (EAA), and prepare their integration. Source code and technical documentation are made available via the open-source platform OpenCoDE.

What Data May Businesses Process via the EUDI Wallet?

Origin and Reliability of Digital Attestations

The authenticity and reliability of the data provided via the EUDI wallet is ensured by trusted sources and issuers. Digital attestations are issued by authorised public or private issuers, digitally signed and made available via the wallet.

Which Data May a Business Request?

Businesses may not request data via the EUDI wallet at will. Already when registering as a relying party, they must state for what purpose they use the wallet and which data or attributes they need for it. In addition, the data protection principles of purpose limitation and data minimisation apply in particular. For each use case, it must therefore be determined which information is actually required.

Status and Validity Checks

When a digital attestation is presented, the business can check its authenticity and validity automatically. To this end, the technical specifications of the EUDI wallet provide in particular for mechanisms with which it can be determined whether an attestation has been revoked.

The procedures used for this must at the same time safeguard privacy. In particular, status and revocation checks are to be designed so that they cannot be used to track or link individual uses.

Data Minimisation and Selective Disclosure

The EUDI wallet enables selective disclosure (Selective Disclosure). Users can thereby release only the information required for the respective transaction. For example, it can be proven merely that a person is over 18 years old without disclosing the full date of birth. The identity data is, in principle, exchanged directly between the wallet and the business.

What Does the EUDI Wallet Cost?

The EUDI wallet may give rise to implementation and ongoing operating costs for businesses. Their amount depends in particular on the existing IT infrastructure, the number of use cases and the chosen integration model. The European legal framework provides that registration and verification procedures and technical requirements for relying parties are to be designed proportionately and cost-efficiently.²

Against this stand possible savings in identification, registration and KYC processes. Through the automated processing of verified identity data, manual checks can be reduced and processes accelerated. This can lead to lower process costs, in particular where identification and transaction volumes are high. At the same time, standardised digital attestations can reduce the review effort and the risks from incorrect or manipulated identity data.

Model calculations assume that, depending on company size and extent of use, considerable savings potential can result from this. However, the respective implementation and operating costs must be set against the possible savings. Whether integration pays off economically therefore depends in particular on the previous effort for identification and KYC, the transaction volume and the chosen technical implementation. The Commission's model calculations can be found in Chapter 6 of the Impact Assessment SWD(2021) 124 final.

For citizens, the provision and use of the EUDI wallet is, in principle, free of charge. Qualified electronic signatures (QES) are also, in principle, to be made available to natural persons free of charge for non-commercial purposes.

How Does the Wallet Affect Existing eID Procedures?

Impact on KYC and Remote Identification

The AMLR changes the requirements for identifying and verifying customer identity. Under Art. 22(6) AMLR, identity can be verified in particular on the basis of identity documents or by electronic identification means with the eIDAS assurance level "substantial" or "high" as well as relevant qualified trust services. As a result, eIDAS-compliant electronic identification means and in particular the EUDI wallet gain importance for digital KYC processes.

Impact on VideoIdent

For businesses, the question arises in particular what role established VideoIdent procedures will play in future. These have become established under German anti-money laundering law as a widespread form of remote identification, but cannot simply be equated with eIDAS-compliant electronic identification means.

The future requirements for such remote identification procedures will be specified further by regulatory technical standards (RTS). According to the current state of play, other remote identification procedures can be used alongside electronic identification solutions, provided they meet the requirements set for security, reliability and quality of the identity verification. These include in particular requirements for the authenticity and quality of the identity data used and for the secure performance and documentation of the identification process.

It is thus still not conclusively clarified what role the VideoIdent procedures established in Germany will play in future in their existing form. The financial sector in particular points out that alternative procedures may continue to be needed, for example where customers do not have a suitable electronic identification means.

Consequences for Businesses

Businesses that are obliged entities under anti-money laundering law are therefore advised to review their existing remote identification and KYC processes at an early stage. eIDAS-compliant identification means and the EUDI wallet are likely to gain considerable importance for digital identification processes. At the same time, businesses should monitor the conditions under which existing procedures such as VideoIdent can continue to be used under the final regulatory requirements.

Outlook: The European Business Wallet

In addition to the EUDI wallet, the European Commission presented a proposal for a regulation introducing the European Business Wallet (EUBW) on 19 November 2025. It is intended in particular to give businesses and public bodies a digital identity usable across the Union and to simplify the secure exchange of verified company data and attestations.

The EUBW is not intended to replace the EUDI wallet but to complement it and be interoperable with it. While the EUDI wallet is primarily geared towards the digital identity of natural persons, the EUBW addresses business use cases in particular. In addition to identification and the exchange of attestations, these include the digital management of powers of representation and authorisations.

As of September 2026, the proposal is still in the European legislative process.

Conclusion and Recommendations for Action

With the planned launch of "d-you" on 2 January 2027, the practical roll-out of the state EUDI wallet in Germany begins. It will then become apparent what importance wallets gain in identification.

Businesses subject to the acceptance obligation must create the conditions by December 2027 to accept wallets in their onboarding processes and data landscape – with the associated advantages in prospect.

¹ Cf. Art. 5f(2) eIDAS in conjunction with the implementing acts under Art. 5a(23) and Art. 5c(6) eIDAS, in particular Implementing Regulations (EU) 2024/2977, 2024/2979, 2024/2980, 2024/2981 and 2024/2982. ↩

² Cf. Art. 5b eIDAS (Regulation (EU) No 910/2014 as amended by Regulation (EU) 2024/1183). ↩