Halfway through 2026, eIDAS 2.0 has shifted from a regulation to monitor into a deadline to meet. By December 2026, every EU Member State must provide at least one certified EU Digital Identity (EUDI) Wallet, and roughly twelve months later a long list of organisations will be legally obliged to accept it.
According to Hopae, readiness, however, means two very different things depending on where an organisation sits in the trust chain. Qualified Trust Service Providers (QTSPs), the certified entities issuing qualified certificates for electronic signatures and seals, face a re-certification and re-engineering challenge built on new technical standards, new identity proofing rules and a wallet that changes how signatures are created.
RegTech firm Hopae recently delved into how firms can fully be eIDAS 2.0 ready in the year of 2026.
Relying parties, meanwhile, banks, platforms and regulated enterprises that verify identities, face an integration and acceptance challenge, needing to register as wallet-relying parties and embed wallet verification into user journeys before acceptance becomes mandatory.
Since the regulation entered into force in May 2024, the technical rulebook has filled in rapidly. The core wallet implementing acts were adopted in late 2024, starting the 24-month countdown to December 2026, while the Commission adopted trust service implementing acts throughout 2025 covering qualified certificates, validation, remote signature creation devices, identity verification, timestamps, preservation and new services such as qualified archiving and electronic ledgers.
Member State readiness remains uneven, with fewer than a third currently meeting readiness benchmarks. Germany has scheduled its state wallet for early January 2027, France plans public testing in the second half of 2026, and Poland is folding the wallet into mObywatel.
For QTSPs, the 2025 implementing acts set binding reference standards across core services, while stricter identity verification rules under IR 2025/1566 have applied to remote identity proofing since May 2026. Harmonised conformity assessment, mandatory incident reporting aligned with NIS2 and annual supervisory reporting replace fragmented national approaches.
From December 2027, EUDI Wallets must let citizens create qualified electronic signatures free of charge for non-professional use, turning the wallet into both a distribution channel and a competitive constraint. The real difficulty is sequencing: re-certification against standards still being amended, limited conformity assessment body capacity, and a business-model shift towards B2B signing volume, qualified attestations of attributes and value-added services.
Relying parties face blunter obligations. Private relying parties in banking, telecoms, energy, transport and healthcare, alongside very large online platforms, must accept the EUDI Wallet where they perform strong customer authentication — around December 2027. Before integrating, they must register as wallet-relying parties in their national register, declaring what data they will request and why.
The technical stack spans OpenID4VP, mDoc and SD-JWT VC formats, with selective disclosure by design. Fragmentation across 27 Member States, registration lead times and dual-track user journeys through 2027–2028 make the intermediary model, which eIDAS 2.0 explicitly recognises, increasingly the default architecture. The upside is concrete: verification that took minutes and lost 20–40% of users becomes a two-tap consent flow at Level of Assurance High.
The broader reframe is that an EUDI Wallet project is really a digital identity project. India’s Aadhaar-based stack, Singapore’s Singpass, the Nordic BankIDs, Belgium’s itsme and US mobile driver’s licences are converging on the same promise of verified, reusable, high-assurance identity.
This is the thinking behind Hopae Connect, which will be certified in the first group of eIDAS 2.0 intermediaries, giving customers compliant EUDI Wallet acceptance from day one alongside access to eID schemes worldwide through a single API.
Read the full Hopae post here.
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