2026 Is the Year of the EUDI Wallet — What Banks & Fintechs Must Do Now
Have you got a question?
2026 is shaping up to be a milestone year for digital identity in Europe. The long-awaited European Digital Identity (EUDI) Wallet will finally roll out across EU member states – a secure mobile app that lets people prove who they are online, across borders, with just a smartphone. This isn’t just another tech gadget; it’s a regulatory game-changer that banks and fintech companies cannot afford to ignore. By the end of 2026, every EU country must offer its citizens a digital identity wallet, and by 2027 financial institutions will be required to accept it as an official form of ID. In other words, Europe’s entire financial sector is on the cusp of a new identity era.
As a banking lawyer focused on financial regulation, I see the EUDI Wallet as more than a compliance mandate – it’s a catalyst for innovation in customer onboarding and authentication. In this article, I’ll break down what the EUDI Wallet actually is, why 2026 is the tipping point for this initiative, and most importantly, what banks and fintechs should be doing right now to prepare. The goal is to keep it practical and forward-looking, so that whether you’re a compliance officer, fintech product manager, or banking executive, you come away with a clear sense of the road ahead.
I. What Is the EUDI Wallet?
Simply put, the EUDI Wallet is Europe’s new digital identity wallet – a smartphone app (or equivalent digital service) that allows citizens to securely store and share verified personal credentials (e.g. proof of identity, addresses, licenses, certificates) for both public and private services. Instead of photocopying passports or awkward video ID checks, individuals will be able to present certified digital identity data on demand. For example, a customer could instantly share just their name and birth date (and nothing more) to prove they are over 18, or present a verified digital ID card to open a bank account in another EU country. The wallet uses a “selective disclosure” approach, meaning users stay in control of what data they share and only the minimum necessary information is revealed. This privacy-by-design element is a key feature – Europe wants a solution that enhances user privacy while streamlining verification.
Technically, the EUDI Wallet is being introduced under the EU’s updated electronic identification regulation (often called eIDAS 2.0). It builds on national eID schemes but adds a unifying layer: each member state will issue (or authorize) at least one wallet app that meets common European standards. These wallets can hold your national ID (digital ID card or similar) and also link to other attestations about you – from your driving license to diplomas, even bank account information or payment credentials in the future. In essence, it’s one wallet for all your important digital identity documents, accepted across the EU. And crucially, it’s not limited to government services; private companies (including banks, insurers, fintechs, etc.) will be able – and in some cases required – to rely on the EUDI Wallet for customer identification and authentication.
It’s important to clarify that there won’t be one single “EU app” for everyone. Each country will have its own wallet solution (some countries may offer several competing certified apps), but thanks to common EU standards they will be interoperable and trusted across borders. For consumers, using the wallet is entirely voluntary – you can always choose traditional ID methods – but the hope is that the convenience and security benefits will drive adoption. The EUDI Wallet is designed to be free of charge for citizens (at least for personal use), and to work seamlessly anywhere in Europe. If it succeeds, it could finally eliminate the patchwork of national ID rules and login systems that have made cross-border banking and e-commerce cumbersome.
I. Why 2026 Is a Turning Point
The year 2026 is being heralded as “the year of the EUDI Wallet” for good reason. After years of planning and pilot projects, the regulatory stars have aligned for a Europe-wide digital identity rollout. In mid-2024, the EU formally adopted the European Digital Identity Framework Regulation (Regulation (EU) 2024/1183), which set a tight timetable for implementation. By December 2026, every EU member state must provide at least one compliant EUDI Wallet to all its citizens and residents. This deadline is legally binding – not a vague target, but a mandate. It means that over the next year, governments across Europe are rushing to build or adapt digital identity apps that meet the EU’s technical standards and security requirements. Several countries are ahead of the game: Poland, for instance, is expanding its existing mObywatel mobile ID (already with 18+ million users) into an EUDI Wallet, and Italy and Austria are likewise upgrading their national digital ID apps. Germany is taking a slightly different route by accrediting multiple private-sector wallet providers on top of its national eID infrastructure – adding some complexity, but ultimately giving consumers a choice of wallet apps. Come 2026, we will see a variety of wallet solutions country by country, but all adhering to the common EU framework and mutually recognized across borders.
Why the end of 2026? It’s simply the timeline the EU set to make digital identity ubiquitous. The original eIDAS regulation (from 2014) made cross-border recognition of national e-IDs possible, but it was voluntary for countries to even issue digital IDs, and uptake was limited. The new regulation fixes that by requiring every country to offer a digital ID wallet and extending the trust framework to the private sector. The expectation is that by having a wallet in everyone’s hands, digital identity verification will become as common and easy as using a payment app. In fact, the European Commission has an ambitious goal: by 2030, 80% of EU citizens should be using a digital ID solution like the EUDI Wallet. To get there, 2026 is the make-or-break moment when the wallets transition from theory to practice.
Equally important, 2026 is when businesses need to get on board. The regulation doesn’t just mandate governments; it also lays out obligations for private-sector acceptance. Banks, fintechs, and other “service providers legally obliged to identify customers” (think telecoms, utilities, insurance, etc.) will be required to accept the EUDI Wallet as a valid form of identification no later than 2027. In fact, for certain industries like payments, the clock is ticking even faster: payment service providers will need to recognize wallet IDs by mid-2027. Practically, this means that a German bank, for example, must let a customer use their Spanish digital identity wallet to fulfill KYC requirements – and a French fintech must accept an Italian customer’s wallet credentials, and so on. The era of “please upload a scan of your passport and a utility bill” is coming to an end, and 2026 is the pivot point. By the end of that year, the wallets will start rolling out, and by the year after, refusing a wallet as ID will no longer be an option. This regulatory push is why industry observers are calling the EUDI Wallet a turning point for Europe’s digital economy.
It’s worth noting that 2026 is not the end of the journey but the beginning of widespread adoption. There are still open questions and practical challenges (more on those later), and the rollout may be a bit uneven at first. Some government wallets might launch in beta or limited functionality as the technical standards evolve. But from 2026 onward, the trajectory is set: digital identity is moving from niche to mainstream. For the financial sector, this is a huge shift – comparable in significance to the introduction of PSD2’s open banking or even the arrival of the euro, in terms of how transformative it could be. Banks and fintechs that prepare early will have a clear advantage, while those dragging their feet could face compliance headaches and competitive disadvantages.
III. How Will the EUDI Wallet Impact Banks & Fintechs?
For banks and fintech companies, the EUDI Wallet isn’t just another IT project – it’s a catalyst that will touch nearly every aspect of customer interaction, from onboarding and compliance to authentication and user experience. Let’s break down the key implications:
1. Streamlined Onboarding & KYC Compliance
Customer onboarding and Know Your Customer (KYC) checks will become faster and more standardized. Instead of juggling various ID documents and manual verification steps, financial institutions will be able to receive instant, certified identity data from the customer’s wallet (e.g. name, date of birth, address, and ID number, already verified by a national authority). This means no more typing in data from scans or waiting days for document approval – the wallet can confirm identities in seconds. For cross-border customers, the wallet is a game-changer: a Finnish fintech can onboard a Greek customer as easily as a local one, since the European trust framework ensures mutual recognition of the digital ID. From a compliance perspective, the EUDI Wallet can fulfil the customer identification element of KYC at a high level of assurance, while all other AML obligations under the risk-based framework remain fully applicable. Banks can be confident that an identity coming from a wallet is legitimate and meets regulatory standards for customer due diligence. In practical terms, account opening could go from a 30-minute ordeal (or a multi-day back-and-forth) to a quick, seamless process. Early adopters are likely to see lower onboarding costs as well – one analysis noted that identification via the wallet should be many times cheaper than traditional methods like video identification, which can save institutions millions in the long run.
2. Enhanced Customer Authentication (SCA)
The EUDI Wallet will also play a big role in how customers log in and authenticate transactions. Under PSD2’s Strong Customer Authentication (SCA) rules, banks must enforce two-factor authentication for online banking and payments. The wallet is expected to serve as a powerful new SCA tool – it can act as something the customer has (possession of the wallet on their device, akin to a token) combined with something they know (a PIN) or are (biometric ID) for authentication. In theory, a login or payment approval could be as simple as the user scanning a QR code with their EUDI Wallet app and confirming with their fingerprint. The wallet is being designed to meet high security standards, and it will support qualified electronic signatures too, meaning customers can sign financial contracts or payment consents digitally with legal effect. However, it’s not a magic bullet for all authentication needs. In practice, the wallet will likely be one factor in a 2FA flow rather than a standalone solution for everything. For instance, not all wallets may have biometrics enabled initially, and regulators are still mapping the wallet’s security assurance levels to the exact PSD2 requirements. So, banks should view it as a strong additional authentication method that can boost security and user convenience, but they will still need fallback options. Over time, as standards mature, the EUDI Wallet could become a primary means of customer authentication across Europe, reducing reliance on SMS codes or proprietary apps.
3. Regulatory Compliance & Liability
From a compliance standpoint, the EUDI Wallet is both a relief and a new responsibility. The good news is that it offers a EU-harmonized way to satisfy customer identification laws. A bank in any member state can rely on a wallet identity and know it fulfills the legal requirements (since all wallets must meet the eIDAS **“high assurance” level for certain uses, which is comparable to having an official ID check). This harmonization could resolve the long-standing patchwork of national KYC rules that have plagued pan-European banking. Compliance audits should get easier when you can show regulators a trusted digital audit trail of identity verification, rather than copies of passports and utility bills. That said, new questions are emerging about liability and risk. If an identity fraudulently slips through via a wallet (say, someone compromises a device and uses another person’s ID credentials), who bears the liability – the wallet issuer (e.g. government or provider), or the bank that relied on the wallet? These details are still being ironed out. Regulators acknowledge that “scope of obligation and liability” around the wallet ecosystem requires further clarification. We might see guidance on this in 2026 as implementation progresses. Financial institutions should keep an eye on how trust frameworks allocate responsibility for any identity misuse. Nevertheless, using the wallet should reduce certain risks (like fake ID documents or data entry errors) and even reduce liability for banks compared to today’s manual checks, because the identity proof comes vetted and cryptographically secure. In short, compliance departments will need to update policies to incorporate EUDI Wallet verification, but they’ll likely welcome a tool that makes compliance both easier and more uniform across the EU.
4. Technical Integration & Readiness
To leverage the EUDI Wallet, banks and fintechs will need to adjust their technical infrastructure. This means integrating with whatever interfaces the wallets provide – likely scanning wallet QR codes or connecting via APIs to verify credentials. IT teams should be preparing to plug in the wallet as a new identity source in online banking platforms, mobile apps, and branch systems. One challenge is that there won’t be just one wallet but 27 (or more) national wallets. Fortunately, all will follow common standards, but there may be differences in how they technically exchange data or authenticate users. Banks will either build these connections in-house or use third-party identity gateway services to handle multiple wallet formats. The timeline is tight: as of late 2025, no country had a production-ready wallet available, so 2026 will involve rapid testing and deployment. Many large banks are already participating in pilot programs and sandboxes to experiment with wallet integration before the official launch. Beyond the IT plumbing, there’s an operational aspect: staff will need training on the new processes (e.g. how a branch teller or online support agent accepts a wallet credential) and customer-facing teams must be ready to educate users who may not be familiar with the wallet. There’s also an element of customer trust – not everyone will jump on a new digital ID immediately. Banks and fintechs might consider promotional campaigns or incentives for customers to try the wallet once it’s available, highlighting benefits like speed and security. In summary, technical and business teams should treat 2026 as a crucial build-and-learn phase to ensure they are fully wallet-capable by the time regulations make it mandatory.
IV. Preparing for 2026: What Banks & Fintechs Should Do Now
With the EUDI Wallet revolution on the horizon, what practical steps can financial institutions take today to get ready? Here are concrete actions to consider in 2026 (before the hard deadlines hit):
1. Conduct a Digital ID Readiness Audit
Take stock of your current customer onboarding and authentication systems. Identify where and how a customer’s digital identity could be presented (online signup, branch ID checks, login flows, digital signature steps, etc.), and assess what it will take to integrate EUDI Wallet capabilities at those points. Determine if your systems can accept and verify the wallet’s digital credentials and what updates may be needed. This audit will highlight gaps to address – whether in IT interfaces, process workflows, or vendor support.
2. Map and Update Your KYC/AML Processes
Review your KYC, AML, and customer due diligence procedures in light of the new wallet standard. Map existing identity verification steps against the EUDI Framework requirements. For example, if you currently require a certified copy of an ID for certain high-risk clients, decide how a wallet credential will replace or supplement that. Update internal policies to explicitly recognize a customer’s EUDI Wallet as an acceptable (in fact, soon mandatory) form of identification. Engage with your legal and compliance teams to ensure alignment with both EU regulations and any national laws that may need tweaking for digital IDs. Prioritize high-impact use cases – e.g., remote account opening and loan applications – where the wallet can significantly streamline compliance or improve user experience.
3. Develop & Test Integration Early
Don’t wait until every wallet is live to start integrating. In 2026, participate in pilots or sandbox programs if available, or use the documentation and test environments provided by the EU and national authorities. Many countries are releasing SDKs and technical specs for their wallets – get your developers to experiment with them. If you use third-party providers for identity verification (RegTech solutions), talk to them about their roadmap for EUDI Wallet support. The goal is to have at least a basic working integration in place ahead of the 2027 compliance deadlines. Early testing will surface any technical quirks in handling the wallets’ authentication flows or reading credential attributes. It will also help estimate performance impacts, so you can scale systems to handle potentially large volumes of wallet verifications.
4. Train Teams & Update Customer Education
Introduce the EUDI Wallet concept to your organization. Ensure that compliance officers, customer onboarding teams, IT security personnel, and customer support agents all understand what the wallet is and how it will change their processes. Closer to launch, provide hands-on training for staff on accepting wallet-based ID verification – for instance, how a branch employee would scan a QR code from a customer’s app, or how an online support agent might guide a user through wallet authentication. Also plan customer communications: you might create FAQs or in-app tips about the new “Digital Identity” option for login or KYC. Being proactive in educating customers will not only boost adoption (which can reduce your reliance on older, costlier methods) but also position your brand as a forward-thinking player in digital innovation.
5. Stay Flexible and Monitor Developments
While preparing, keep in mind that 2026 will be a transition period. Not every customer will use the wallet on day one, and not every scenario will be covered perfectly by it. Design your workflows to remain flexible – for example, support the EUDI Wallet alongside existing ID verification methods for a few years, until adoption grows. Likewise, maintain backup authentication options (SMS OTPs, etc.) as the wallet establishes its track record in SCA. Monitor regulatory updates and industry guidance on the EUDI Wallet throughout 2026 and 2027. Regulators and the European Banking Authority may issue clarifications on liability, security standards, or specific use cases. Participate in industry forums or working groups if you can; many banks are jointly navigating standards for wallet acceptance. In short, treat 2026 as an adaptive phase: be ready to comply, but also ready to adjust as real-world experience starts to shape best practices.
By taking these steps, banks and fintechs can turn what might seem like a compliance burden into a competitive advantage. Those who move early will be well-positioned to offer smoother customer journeys, reduce fraud and costs, and even attract customers who value modern, privacy-friendly solutions
V. Conclusion: Embracing the Digital Identity Future
The European Digital Identity Wallet is coming, and it promises to redefine how we verify identity in financial services and beyond. 2026 is the year it shifts from vision to reality. For the banking and fintech sector, this is a time to lean in and lead. Yes, there are uncertainties to resolve and technical work to be done, but the direction is clear – Europe is betting big on digital identity as the foundation of future innovation.
Banks and fintech firms that embrace the EUDI Wallet early will not only stay on the right side of compliance, but can also deliver a better customer experience (think one-click onboarding), strengthen security, and streamline operations. Meanwhile, laggards risk being left with clunkier processes and higher costs in a world where customers increasingly expect digital-first convenience. In my view, the EUDI Wallet initiative is a positive opportunity wrapped in a regulatory requirement – it’s pushing us to modernize and collaborate across borders in a way we’ve never done before.
As we enter this new era, it will be crucial to maintain a dialogue between regulators, banks, fintechs, and tech providers to iron out the remaining kinks (from interoperability issues to liability frameworks). But come what may, the digital identity revolution in Europe is underway. 2026 will be remembered as the year the EUDI Wallet changed the game. The best thing financial institutions can do now is to prepare, adapt, and ultimately embrace this change. By doing so, they’ll not only comply with the law but also build trust with customers and stay ahead in the digital economy. In short, now is the time to unlock the EUDI Wallet’s potential – and ensure your organization is ready for the future of finance.
Book a call back
Share this article
Got a question?
Please complete this form to send an enquiry. Your message will be sent to one member of our team.
Related posts

Data Protection Consultancy with Oracle Solicitors
Ensuring Compliance with GDPR & Albanian Data Protection Laws for Your Business In today’s digital age, safeguarding personal data has never been more

WHO Drafts Historic Pandemic Treaty
A historic agreement has been reached in Geneva: the World Health Organization (WHO) has formalized the draft of an international treaty for pandemic

Expert Insights: Kai Scholz on China-Germany Financial Dialogue and EU-China Economic Relations
Our Partner and Head of Legal & Operations, Kai Scholz, LL.B. appeared live on CGTN Europe’s “The World Today” to provide expert commentary on the

Stablecoins in the European Legal Order: Regulation, Systemic Risk and the Transformation of Financial Infrastructure (2025 Update)
Stablecoins have evolved from an experimental crypto-instrument into a potential pillar of Europe’s emerging digital financial architecture. With the EU’s Markets in Crypto-Assets
