European Business Wallets: Developments impacting the EIDAS ecosystem

Context

On 19 November 2025, the European Commission presented a legislative package for regulatory simplification, known as the "Digital Package", which aims to streamline and harmonise the regulatory framework applicable to AI, cybersecurity, privacy, personal data protection, digital services and electronic identification. This package includes:

• The Proposal for a Digital Omnibus Regulation, to review and simplify scattered regulatory practices.
• The Data Union Strategy.
• The Proposal for a Regulation on the establishment of European Business Wallets (EBW), designed as a harmonised digital solution for businesses and public bodies to facilitate identification and authentication, enable the secure exchange of data and documents, and reduce administrative burdens across the Union through a legally recognised digital instrument.

This new milestone in legislative simplification at European level coexists with the recent amendment to Regulation (EU) 2014/910 eIDAS, by Regulation (EU) 2024/1183 with regard to the establishment of the European digital identity framework, in force since 20 May 2024 (hereinafter, the eIDAS Regulation), which introduces European Digital Identity Wallets (EUDI Wallets) as alternative means of identification to other means of identification recognised until that time; with the aim of strengthening the identity verification processes of European citizens and facilitating their interoperability and cross-border interactions with the public and private sectors throughout the Union.

In this context, the amended eIDAS Regulation and its implementing acts include EUDI Wallets as an additional user identification/authentication mechanism for the provision of trust services for the issuance of EAA and QEAA electronic certificates and attribute statements [24.1 bis) eIDAS Regulation]. Similarly, they must be accepted for the reliable identification of the sender and recipient within the framework of the qualified certified electronic delivery service as set out in the Implementing Act of the eIDAS Regulation CIR 2025/1946.

In this scenario, the Omnibus Law and the European Business Wallets (EBW) Regulation do not amend the eIDAS Regulation as a base text; both initiatives interoperate with its deployment in relation to wallets, their implementation and supervision. They also announce a future operational integration of the single point of incident reporting at European level, with eIDAS and other regimes such as NIS2, GDPR, DORA and CER.

What new features do European Business Wallets introduce within the eIDAS framework?

European Business Wallets meet the requirement of the eIDAS Regulation, amended in 2024, that Member States offer digital identity wallets for legal entities in order to optimise their cross-border digital interactions and procedures with the public and private sectors. That is why the proposed Regulation introduced as part of the digital simplification package provides for EBWs to inherit the organisational, technical and functional framework designed by eIDAS for European Digital Identity Wallets (EUDIWallet).

In this regard, the proposal for European Business Wallets incorporates the technical and functional architecture framework (ARF) of the EUDIWallet, as well as all the requirements defined for them in the eIDAS Regulation and its implementing acts (certification of wallets, lists of certified wallets, registration of wallet users, management of wallet security breaches, etc.). In this way, the European Commission ensures that European Business Wallets are created under harmonised structural and technical-functional requirements, while also fulfilling its objective of regulatory simplification.

How will European Business Wallets impact the different players in the eIDAS ecosystem?

1. For businesses 

European Business Wallets offer numerous advantages for companies regardless of their category (large companies, SMEs, start-ups), such as:

• they will have a unique digital identity throughout the Union, using a harmonised digital identity infrastructure that is legally recognised by all Member States.
• the possibility of creating, storing and exchanging documents and credentials relating to their identification and associated attributes, as well as receiving official notifications throughout the EU, streamlining identification/authentication processes in relations with public administrations (B2G) and businesses (B2B).
• the possibility of creating electronic signatures/stamps and time stamps on electronic documents, equivalent in terms of validity and probative value to handwritten signatures, with the maximum guarantees of linking the signatory to the signed document, as well as the presumption of the integrity of the signed document and the accuracy of the date and time of the signature.
• A secure, interoperable and efficient channel of communication with other companies and public administrations throughout the Union.
• A considerable reduction in paper and administrative costs by speeding up cross-border procedures, among other things...

In short, the EBW is positioned as a strategic pillar for consolidating digital trust in the EU, offering companies a single system for interacting with authorities and other companies and complying with their regulatory obligations.

2. For government authorities 

Following the adoption of EBWs, all levels of the EU public administration, including EU institutions, bodies and agencies, will have two years to implement the use of these business wallets. This deadline undoubtedly poses a challenge for Member States, which must design strategies to adapt their digital procedure infrastructures to the new demands of society, ensuring secure interconnection, personal data privacy and, above all, interoperability with these wallets.

3. For Digital Identity Wallet developers 

EBWs offer numerous advantages for developers, as in this case they do not have to deal with additional technical and legal requirements that require significant effort and investment in time and resources. On the contrary, this new European initiative allows them to benefit from all the standardised technical and legal infrastructure that is being deployed for EUDIWallets. This promotes the optimisation of development processes and stimulates competitiveness in the digital identity market for the development of digital identity solutions that are fully aligned with the security and privacy requirements defined in the eIDAS Regulation and the GDPR, while offering functionalities for both citizens and businesses.

4. For Trusted Service Providers

New business channels are also opening up for Trust Service Providers with EBWs, as demand grows for services such as the issuance of electronic signature and seal certificates, the issuance of electronic declarations of EAA and QEAA attributes, and timestamps. On the other hand, it allows them to integrate these portfolios into remote document contracting and electronic signature processes. It also allows them to send certified electronic communications in relations with other private sector entities, as well as in electronic processing procedures with public administrations and public services.

Conclusions

The proposed Regulation for the issuance of the European Business Wallet marks a milestone in European corporate digital identity by creating a single, harmonised and legally robust system for businesses and public entities.

For Trust Service Providers, the EBW represents an immediate opportunity to:

• integrate qualified services into future portfolios,
• issue electronic attributes for representation and compliance,
• participate as notified providers or even as wallet developers,
• and position themselves in new B2G and B2B business flows.

As the process moves forward in Parliament and the Council, it will be essential to follow the implementing acts and technical specifications, which will determine the final certification, security and interoperability requirements.

Information note written by ECIJA's Data Protection Department.