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The Future of Digital Identity in Europe: The EUDI Wallet and the Challenge of Trust

Digital identity has long been a weak point in the European Union’s digital landscape. While the eIDAS Regulation (Regulation (EU) No 910/2014) established a framework for recognising national electronic identification systems across borders, its practical impact remained limited. Digital identity solutions continued to operate largely within national boundaries, constraining the development of a truly integrated Digital Single Market.

This is now changing. Through the revised eIDAS framework (Regulation (EU) 2024/1183), the European Union introduces the European Digital Identity Wallet (EUDI Wallet) a tool intended to enable seamless identification, authentication, and data sharing across Member States. More than a technical upgrade, this initiative represents a shift toward building a common digital identity infrastructure.

Yet this transformation raises an important question: will the EUDI Wallet empower users and facilitate cross-border interaction, or will it introduce new risks related to privacy, security, and control? The answer depends less on the existence of the wallet itself than on how it is implemented, governed, and used in practice.

From Fragmentation to Infrastructure

The original eIDAS Regulation was built on a relatively light-touch model of interoperability. Member States retained control over their national identity systems, while the regulation ensured mutual recognition and harmonised rules for trust services such as electronic signatures. This approach created a legal baseline, but it did not result in a widely adopted or user-friendly cross-border identity ecosystem.

The revised framework takes a more ambitious approach. Instead of merely coordinating national systems, it requires each Member State to offer at least one digital identity wallet that can be used across the Union. This marks a shift from interoperability through recognition to integration through infrastructure.

Digital identity is thus no longer treated as a technical accessory to public administration. It becomes a foundational layer of the European digital economy, comparable to payment systems or telecommunications networks.

The EUDI Wallet: A New Identity Model

At the centre of this framework is the European Digital Identity Wallet. The wallet is designed as a secure, user-controlled tool that allows individuals and businesses to identify themselves, authenticate transactions, and share verified information.

Unlike earlier identity systems, the wallet is intended to function across both public and private sectors. It can be used to access government services, open bank accounts, verify age, or prove qualifications. This broad scope transforms digital identity into a general-purpose infrastructure for online interaction.

A key feature of the wallet is its ability to handle electronic attestations of attributes. Rather than disclosing full identity profiles, users can share specific pieces of verified information for example, confirming that they are over 18 without revealing their exact date of birth. In principle, this supports the data protection principle of minimisation and enhances user autonomy.

However, whether these benefits materialise depends on how the system is implemented. Technical design, user interfaces, and the practices of service providers will all influence whether the wallet genuinely empowers users or simply reorganises existing power dynamics.

Cross-Border Identity and the Digital Single Market

One of the central goals of the EUDI Wallet is to enable frictionless cross-border authentication. Individuals and businesses should be able to access services in other Member States as easily as in their home country.

If successful, this could significantly reduce administrative barriers and transaction costs. Digital identity would function as a form of economic infrastructure, facilitating cross-border mobility in areas such as employment, education, healthcare, and finance. It would also support remote onboarding and digital service provision, strengthening the overall coherence of the Digital Single Market.

However, interoperability alone is not enough. Trust must be established across different legal systems, administrative cultures, and levels of digital maturity. Without this broader institutional trust, technical compatibility may not translate into widespread adoption.

Privacy and the Limits of “User Control”

Despite its emphasis on privacy and user empowerment, the EUDI Wallet raises important concerns under the General Data Protection Regulation.

One key issue is linkability. Even if users share only minimal data in each transaction, repeated use of the same identity system may allow interactions to be linked over time, enabling profiling and tracking. This risks undermining the very privacy protections the system is designed to promote.

Another challenge concerns over-disclosure. In practice, service providers may require more information than strictly necessary, particularly in regulated sectors such as finance. Users may have little choice but to comply, limiting the effectiveness of data minimisation.

There is also a broader risk of function creep. Systems introduced for identification purposes can gradually expand in scope, becoming tools for monitoring or behavioural analysis. Even if the legal framework sets clear limits, market dynamics and technological evolution may push the system in new directions.

Perhaps most importantly, the concept of “user control” deserves careful scrutiny. While the framework emphasises consent and selective disclosure, real control is shaped by interface design, default settings, and power imbalances between users and service providers. As academic commentary suggests, user control in digital identity systems is often more constrained in practice than it appears in law (Wong-Toropainen, 2024).

Security and Trust

The success of the EUDI Wallet depends fundamentally on trust and trust, in turn, depends on security. Identity systems are high-value targets, and failures can have serious consequences, including identity theft, fraud, and systemic disruption.

For this reason, the framework places strong emphasis on certification, technical standards, and incident management. These mechanisms are intended to ensure that wallets and related services meet high levels of security assurance and that vulnerabilities are addressed effectively (ENISA, 2024).

Cybersecurity is therefore not just a technical issue; it is a legal and institutional prerequisite. Without credible guarantees of security, the benefits of interoperability may be outweighed by increased systemic risk.

Conclusion

The European Digital Identity Wallet represents a significant step toward a more integrated and functional digital identity system in Europe. By moving beyond fragmented national solutions, the revised eIDAS Regulation seeks to create a shared infrastructure that supports cross-border interaction and economic activity.

At the same time, the EUDI Wallet introduces new challenges. Its impact will depend on how effectively the European Union can balance interoperability with privacy, usability with security, and innovation with fundamental rights.

Ultimately, the EUDI Wallet is more than a technological tool, it is a test of whether Europe can build a digital identity system that is both efficient and rights-preserving. Its success will be determined not only by its adoption, but by whether it earns and maintains the trust of those who use it.

Sources

European Commission. (2023). European Digital Identity.

European Union. (2014). Regulation (EU) No 910/2014 on electronic identification and trust services.

European Union. (2024). Regulation (EU) 2024/1183 establishing the European Digital Identity Framework.

European Union Agency for Cybersecurity (ENISA). (2024). The European Digital Identity Wallet: An EU challenge.

European Data Protection Supervisor. (n.d.). Digital identity wallet.

Wong-Toropainen, S. (2024). Problematising User Control in the Context of Digital Identity Wallets and European Digital Identity Framework. In Digital Governance: Confronting the Challenges Posed by Artificial Intelligence (pp. 115–136). The Hague: TMC Asser Press.