The EUDI implementing acts provide the necessary technical specifications and standards intended to make the European Digital Identity Wallet (EUDI) a secure, interoperable, and, user-friendly tool. The establishment of the EUDIW implementing acts aims to ensure consistent, high-level security across all Member States, allowing citizens and businesses to easily and securely authenticate, sign documents, and share digital credentials across borders.
Key envisioned benefits of the EUDI implementing acts include:
- Standardized Interoperability: They define common, technical standards (e.g., for wallets, trust services, and qualified electronic signatures/seals), enabling seamless cross-border use of the EUDI wallet across the EU.
- Enhanced Security and Privacy: Implementing acts define security requirements, including high-level certification, ensuring the EUDIWs are robust against threats, supports privacy-preserving functionalities (i. e. selective disclosure), and protects personal data.
- Uniform Implementation of the EUDIW and the EUDIW trust environment: They prevent fragmentation by setting uniform, binding rules for Member States on how to implement, certify, and operate the wallets and trust services.
- Simplified User Experience: By standardizing, the implementing acts aim to facilitate the creation of user-friendly interfaces for citizens to manage their identity and data. Users will be enabled to store, share, and sign documents (QES) directly from their EUDIWs. The EUDIWs will support selective disclosure (data minimization) as well.
- Support for Specific Sectors: The acts and related Large-Scale Pilots facilitate the development of use cases in education and research sectors among others.
Some challenges related to the application of the specific EUDIW Implementing Acts adopted in 2024/2025 are:
Challenges due to unclear distinction between cases where a relying party is legally required to identify wallet users and other scenarios where such identification is optional.
Examples:
1. PIDs for Research vs PIDs for studying
2. eduID vs national digital eID as PID
Article 5a: Protocols and Interfaces
Interoperability challenges: connectors needed to interact with the EUDIW versions of the 27 EU Member States.
Article 5a: Integrity and Core Functionalities
Challenges regarding how/how often should PID/EAA providers monitor the revocation of the EUDIW.
Challenges due to uncertainties about whether critical assets (i. e. academic credentials) should be remotely stored for backup purposes in case of losing the wallet.
Challenges specifying who should offer backup and recovery of data objects for cases of losing the wallet.
Electronic Attestations of Attributes
Challenges Managing the versioning: Different temporality of identity attributes and revocation (education, research, academy membership).
Article 7 (2): Challenges due to uncertainty about who can make the request for including or modifying an attribute in the European catalogue of attributes.
Challenge of providing effective information to relying parties and users in case of identity loss.
Challenge of establishing responsibilities in case that the users get the information about loss of identity too late. Inclusion of information about revocation/re-establishment of academic identity in case of identity loss.