Head of Marketing & Communication at Namirial

Jörg Lenz is Head of Marketing and Communication at Namirial, one of the leading providers of qualified trust services in accordance with the EU eIDAS regulation. Since 1999, he has been dealing holistically with the legal, technical, business and organisational requirements for the application of electronic signatures in the private sector as well as in public administration.

Jörg Lenz’s specialist topics include the orchestration of signature workflows, procedures for identification and authentication including biometrics, digital identity, ID wallets and various procedures for generating electronic signatures and seals.

He is intensively involved with the framework conditions for the use of these technologies for their application in regulated industries such as finance, telecommunications and energy supply as well as in public administration. He contributes his expertise to the working groups and discussion groups of various national and international organisations.

In doing so, he follows the design and revision of guidelines, regulations and laws – among others in the Bitkom working group on the application of electronic trust services. Currently, he is particularly concerned with the revision of the eIDAS Regulation.

Status-Check | 9 months to the EUDI Wallet: are we ready enough?

April 9, 2026

Stories

Digital Identity eIDAS 2 – EUDI Wallet

What our Q1 2026 country review says about the decisive stretch toward the December 2026 deadline

The countdown is now operational. The Architectural Reference Framework has reached version 2.8, with almost 30 implementing acts already published, referring to tens of technical standards. One of the key implementation pieces is expected to be published shortly, having been voted on 25 February 2026: the European Commission’s Implementing Regulation on wallet enrolment under Article 5a(24) of the amended eIDAS framework. This missing act is important because the first real test of the EUDI Wallet rollout will be whether citizens can be brought into a wallet simply, securely and at scale, rather than whether Member States can point to an architecture on paper. Since wallet usage will be voluntary rather than mandatory, simplicity in onboarding is not a secondary design issue. It is a primary condition for adoption.

Against this backdrop, the European Commission’s implementation timeline means that EU Member States must make at least one European Digital Identity Wallet available by 24 December 2026, with regulated entities mandated to accept it one year later. This seems straightforward: a country either provides a wallet or it does not. However, the closer one looks, the more obvious it becomes that some countries are clearly moving into the final delivery phase, while others are still converting pilots, legal texts, and existing identity apps into something that can credibly meet the EUDI standard in time. The question is therefore no longer whether wallets are coming. Rather, the question is where the first usable, scalable and regulatorily credible wallets will be ready – and where ‘ready’ may initially refer to a limited initial release rather than full functional maturity.

This status check combines official and public progress indicators, as well as direct market conversations. It also draws on primary on-site research from the first quarter of 2026, as well as ongoing exchanges across the ecosystem at several working group meetings of industry associations focusing on digital identity.

What “ready enough” should mean in 2026

At this stage, ‘ready enough’ cannot be defined as having full feature parity across Europe. That would be unrealistic. Rather, it should mean that a Member State can provide at least one officially endorsed digital wallet offering a reliable onboarding process, basic trust and privacy controls, a viable certification process, and sufficient operational stability to support genuine public and private applications. However, ‘credible onboarding’ now deserves more emphasis than many strategies still give it. Since wallet use will be voluntary, legal availability is not the only decisive threshold. Rather, it is whether the initial registration process is straightforward, trustworthy and useful enough for citizens to adopt. The practical threshold is not perfection. Rather, it is whether the wallet can function as a trustworthy part of the European digital identity infrastructure, rather than merely existing as a symbolic pilot with a launch press release.

In our working assessment of the 27 EU Member States, three countries currently look almost certain, five very likely, eight likely, seven might and four unlikely for the December 2026 deadline. We will discuss these countries in more detail later in this article.

That is a better picture than some observers expected, but it still leaves a large middle group capable of delivering something on time with real uncertainty around scope, certification according to national conformity assessment schemes that are yet work in progress, onboarding or operational completeness, and a smaller but still material group that remains clearly at risk. In other words: the launch is likely to be real, but it will also be staggered, asymmetric and, for some time, uneven in everyday value.

One important scope note: this assessment is about the EU Member State obligation for December 2026. EEA countries such as Norway, Iceland and Liechtenstein follow a later timetable and should not be mixed into the same deadline analysis. That sounds technical, but it matters strategically because it changes how international service providers should sequence market readiness and onboarding plans.

The European picture is getting clearer and more differentiated with top-tier cases

The clearest top-tier cases today are France, Italy and Poland. These countries are not starting from scratch.

France Identité is already a live production service, visibly expanding its functionality and ecosystem integration as it becomes an official EUDI Wallet. It has also started conducting initial tests with relying parties.
Italy‘s case should be described more precisely as the IT Wallet System, rather than just the IO app. The Italian framework is explicitly designed as a national IT wallet system consisting of a public wallet accessible through the IO app, as well as additional private wallets that may be offered by accredited private providers. These will be introduced simultaneously, giving users the option to select their preferred wallet. This could make Italy the only large European country where private providers can enter the wallet market relatively quickly, alongside the public solution. The enrolment logic is also strategically important. According to official sources, citizens can access the system using CIE or SPID. This means that Italy can build on an already established national identity infrastructure for wallet activation, rather than relying on an entirely new registration model. Considering the continued growth of the SPID ecosystem, which now has more than 41.5 million registered users, this makes Italy one of the most operationally advanced EUDI transition cases in Europe.
Poland has paired a substantial installed base of mObywatel users with a public commitment to integrate the EUDI Wallet into the mObywatel ecosystem by the end of 2026. However, the transition from version 2.0 (with almost 10 million users) to version 3.0 could cause significant delays to the rollout due to some unknown factors at this stage.

Germany is an instructive stress test

Germany has announced that it will launch its state-driven version of the EU Digital Identity Wallet on 2 January 2027, before opening the market to private companies the following year. This demonstrates that the remaining nine months of this year will focus more on programme control and good project governance than on vision. The work on the wallet thus far, including the prototype challenge and sandbox phase, demonstrates significant progress given the initial conditions. Germany may ultimately deliver a robust digital identity ecosystem.

Given the country’s current low usage of digital identity, German politicians are demonstrating greater ambition in embracing EUDI wallets than some other EU member states with higher digital identity adoption rates and more efficient eGovernment services. However, with only nine months to go until the official launch date, there is a greater risk of schedule delays than in France or Italy. This is an important lesson for relying parties: technical sophistication does not automatically equate to early availability.

The next group is strong, but not equally de-risked

Austria, Belgium, Greece, Portugal, Spain and Sweden form a strong second tier.

Austria benefits from the combination of ID Austria and eAusweise, meaning the country already has a functioning mobile credential system in place.
Belgium’s position has become materially stronger as the Belgian Digital Transformation Office (BOSA) has presented MyGov.be as the country’s response to the eIDAS 2.0 wallet obligation, while itsme continues to be widely used by Belgian citizens for daily authentication with private relying parties.
Greece and Portugal both benefit from the strategic advantage that matters most at this stage: they already have wallet-like citizen-facing services in production. However, public details on timing, production scope and opportunities for private wallet providers remain limited.
Spain also belongs in this second group. At the EUDI Wallet Launchpad in December 2025, the first wallet version leveraging the existing Cl@ve system was presented. This is significant because Cl@ve already has over 24 million registered users and over 1.1 billion annual authentications on its gateway, according to official Spanish government statistics. However, the implementation roadmap is not yet publicly available.
Sweden, while less visible than some southern European frontrunners on a consumer scale, now demonstrates the kind of public mandate, sandbox work and implementation structure that usually precedes serious delivery.

These are not “concept countries.” They are execution countries. But unlike France, Italy or Poland, they still carry a somewhat higher risk that December 2026 will arrive with a narrower initial scope or a later ramp-up in real-world use cases.

What separates the leaders from the rest

Across the country review, one pattern stands out very clearly: the strongest predictor of readiness is not the quality of conference slides or the sophistication of policy language. It is the existence of a live, trusted and already-used national identity app that can be upgraded rather than invented. Countries with a production platform, a named institutional owner, and an existing base of credential issuance are simply operating on a different timeline. They have already solved the hardest political and behavioral questions: who owns the service, how citizens access it, and whether the public will use it at all.

A country that already runs a national wallet-like app is not automatically EUDI-ready. It still has to address interoperability, certification, issuer and verifier integration, relying-party access, and privacy-preserving data exchange in line with the Architecture and Reference Framework. But it does not need to solve first-time product delivery and public adoption at the same moment. That is why countries such as France, Italy, Poland, Austria or Belgium currently look structurally stronger than countries whose most important recent milestone is still the publication of a draft law or the launch of a limited pilot.

Why legal progress matters but does not yet equal delivery confidence

That distinction is important for interpreting the countries that have improved most in recent months. Bulgaria is a good example. The publication of a draft Law on the European Digital Identity Wallet in February 2026 is a real and relevant signal. It shows that the question of national implementation is no longer abstract. But late-stage legal movement does not remove the practical risk of late-stage technical delivery. A country can be clearly more active than it was three months ago and still remain risky for December 2026 if the public evidence for a production wallet, a rollout plan and an operational ecosystem is still thin.

Some upward revisions are more substantial

Slovakia is one of the most interesting positive cases of progress made in the last three months. Its eDoklady programme now shows a much more concrete milestone structure than late-2025 observers were working with, including a public timeline for further features and a specific reference to EUDIW offline verification planned for the second quarter of 2026.

Denmark also looks stronger because the implementation path for AltID is now explicit and staged, rather than merely aspirational.

The Czech Republic and Slovenia also look better than the older “laggard” narrative suggested. They are not yet obvious frontrunners, but they now have enough visible programme substance to sit in the middle band rather than at the bottom of the table.

The launch will be real, but it will not be symmetrical

This is the point many market participants still understate. The end of 2026 is unlikely to deliver one homogeneous European wallet moment. It is much more likely to produce a first wave of compliant or near-compliant national launches with very different levels of functional breadth. Some wallets will arrive first with core identification and authentication capabilities. A few may already have capabilities for qualified e-signing. Some will remain more government-centric for a period before broader issuer and verifier ecosystems emerge. Some countries will be technically interoperable earlier than they are operationally convenient. Others will have a solid domestic app but still need time to convert it into an open EUDI-ready service model. “Available” and “mature” will not mean the same thing in every Member State on the same day.

The Netherlands shows the opposite problem

The Dutch case is a different, but equally useful, signal. The Netherlands is not inactive. It has public testing, technical work and a visible national programme. But when public information indicates that an initial release may not satisfy the full requirement set, that warning should be taken seriously. It is better to be precise about this now than to create a false sense of uniform market readiness. 24 December 2026 is the delivery date, however Durch versions of EUDI Wallets might become available sometimes later in 2027 which may not necessarily mean in first or second quarter.

What organizations should do now

For banks, insurers, qualified trust service providers, telecom operators and large relying parties, the implication is straightforward. Do not plan for one uniform pan-European go-live.

Plan for a phased market reality. Prioritize the countries with the strongest installed base and clearest institutional ownership. Build a wallet-agnostic acceptance model rather than a single-wallet integration plan. Prepare for a period in which domestic identity apps, wallet pilots and EUDI-conformant services coexist. And treat evidence, fallback logic and operational governance as first-class design requirements, not as paperwork to add later.

The strategic takeaway

Nine months before the legal obligation takes effect, Europe looks readier than many feared but not ready enough to assume a smooth and uniform launch. The leaders are increasingly visible. The middle band is real, but fragile. The laggards are still running against time. That is precisely why the next months matter so much. The market is moving from legislative certainty to execution reality. By the end of 2026, the EUDI Wallet era will have started. The more important question for every participant in the ecosystem is where it will be usable first, where it will be trusted first, and who will already be prepared when fragmented readiness becomes real market structure.