As it is known, e-IDAS[1], which establishes the framework for cross-border identification (limited to public services) and trust services (e-signature, e-seal, timestamp, e-registered delivery, website authentication) to enhance trust in the online environment, entered into force on 1 July 2016.
Meanwhile, based on the rapid expansion of digital services and the need to make e-IDAS more efficient, the European Commission announced in its Communication “Shaping Europe’s Digital Future” of 19 February 2020 that e-IDAS should be modified to support trusted digital identities, including for the private sector. Following this announcement, the European Council called on the European Commission to initiate the work and as a result, Regulation (EU) No 2024/1183 amending e-IDAS to establish the European Digital Identity Framework[2] was adopted on 11 April 2024 and entered into force on 20 May 2024 (with the new regulation, e-IDAS started to be called e-IDAS 2.0).
In line with e-IDAS 2.0, the European Commission is expected to establish implementation acts by 21 November 2024, concerning the features and certification of the European Digital Identity Wallet. Member States are required to provide at least one European Digital Identity Wallet within 24 months of the implementation acts taking effect.[3] Additionally, service providers in sectors requiring strong identity verification, such as financial services, must accept the European Digital Identity Wallets within no later than 36 months from the date of entry into force of the implementing acts, upon voluntary request by the user.[4] It should be noted that, the use and discontinuation of European Digital Identity Wallets are left to the discretion of the users, without any obligation being imposed.
Thus, by the second half of 2026, we will begin to see the option “Verify with EU Digital Identity” in the remote customer onboarding processes of financial institutions providing services in the EU. By the way, Belgium has already partially launched its national digital identity wallet[5] and Italy is expected to launch its own digital identity wallet by January 2025[6].
The European Digital Identity Wallet is defined as “an electronic identification means which allows the user to securely store, manage and validate person identification data and electronic attestations of attributes for the purpose of providing them to relying parties and other users of European Digital Identity Wallets, and to sign by means of qualified electronic signatures or to seal by means of qualified electronic seals.” [7] Therefore, the EU Digital Identity (EUDI) can be used for everyday tasks such as providing identification to online and offline public and private services, displaying your mobile driving license, authorizing payments, presenting medical prescriptions, and signing documents electronically.[8]
EUDI is designed to be accessible via mobile applications and digital wallets on various devices. It utilizes blockchain technology and data sharing among the governments of member states to function. This involves creating a digital profile where personal information and official documents are collected and stored. When public or private organizations request identity verification, the necessary information and documents are transmitted through the European Digital Identity Wallet, ensuring verification through this data. Additionally, while accessing the digital wallet will also involve identity verification, I believe that the liveness test practices conducted by financial institutions for preventing fraud during remote customer acquisition, will continue. [9]
Under the current e-IDAS regulation, Article 6 facilitates mutual recognition, where Member States recognize each other’s electronic identification means, allowing access to each other’s identity verification systems. While some Member States have advanced digital identity applications, the most commonly used electronic identification tool remains the physical electronic IDs. Identity verification using physical electronic IDs, involves transferring identity information into electronic forms using OCR (Optical Character Recognition) or NFC (Near Field Communication) tools on a person’s phone, and querying this information through the online identity verification system of the Member State of which the person is a citizen.
In practice, ensuring accurate identity matching often requires additional information about the user and specific, complementary identity verification procedures at the national level. Therefore, the existing mutual recognition system may not function effectively, and it has been emphasized that Member States need to implement additional measures to ensure precise identity matching.[10]
However, with a digital identity card, these steps can be eliminated, and identity verification can be conducted directly through the EU Digital Identity Wallet. This is because digital wallet applications are directly controlled by Member States and are integrated with their own identity verification systems.
Finally, the European Digital Identity Wallets can be provided by the Member States themselves, an approved institution, or an institution recognized by the Member State after preparation. To ensure compliance, the European Digital Identity Wallets and their associated electronic identity verification schemes will need to meet the requirements, standards, and technical specifications set out in e-IDAS 2.0. These will be certified by conformity assessment bodies designated by the Member States.[11] The certificates issued will be valid for five years, provided that vulnerability tests are conducted every two years.[12]
[1] Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2014.257.01.0073.01.ENG.
[2] Regulation (EU) 2024/1183 of the European Parliament and of the Council of 11 April 2024 amending Regulation (EU) No 910/2014 as regards establishing the European Digital Identity Framework, https://eur-lex.europa.eu/eli/reg/2024/1183/oj.
[3] e-IDAS 2.0, Article 5a/1.
[4] e-IDAS 2.0, Article 5f/2.
[5] https://www.biometricupdate.com/202405/belgium-launches-national-digital-identity-wallet
[6] https://www.biometricupdate.com/202405/move-over-armani-italys-it-wallet-is-the-digital-id-accessory-of-the-season
[7] e-IDAS 2.0, Article 3/42.
[8] European Digital Identity Wallets will enable the creation and use of qualified electronic signatures and seals, which are recognized across the Union. Once individuals are onboarded to a European Digital Identity Wallet, they will be able to sign using qualified electronic signatures as a default and free of charge, without the need for any additional administrative procedures (Regulation (EU) 2024/1183, Recital 19).
[9] COMMISSION STAFF WORKING DOCUMENT, IMPACT ASSESSMENT REPORT, Accompanying the document, Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) n° 910/2014 as regards establishing a framework for a European Digital Identityhttps://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:52021SC0124#_Ref68967950.
[10] Regulation (EU) 2024/1183, Recital 41.
[11] e-IDAS 2.0, Article 5a.
[12] e-IDAS 2.0, Madde 5c/1-4.
