Managing Director Austria and Head of Sales & Presales Europe at Namirial

For over a decade has been supporting companies in the introduction and optimisation of applications for e-signatures and eKYC procedures, both in the DACH region and internationally. He brings in-depth expertise and experience to the design and implementation of technologically, legally and economically viable digital workflows.
His areas of expertise include, in particular, the opportunities offered by eIDAS 2.0 and the upcoming Anti-Money Laundering (AML) Regulation to regulated industries, whether in digital onboarding, contract conclusion, or document delivery and archiving.

As Managing Director of Namirial Austria, he heads the innovation centre in Ansfelden near Linz. In this role, he brings extensive experience in team leadership, sales and partner management, global key accounting, and strategic technology consulting for enterprise customers with business-critical end-customer processes, such as those prevalent in the financial industry.
Klaus Fellner holds a master’s degree in business informatics from Johannes Kepler University Linz. With his interdisciplinary expertise at the interface of law, technology and business administration, he is actively involved in the further development of digital identity solutions in Europe.

The boardroom guide to digital trust in banking

March 19, 2026

Trust

Digital Identity eIDAS 2 – EUDI Wallet

What to decide in 2026 for eIDAS 2.0, Wallet adoption, and the shift from Video Ident to Self-Ident

The conversation around the European Digital Identity Wallet (EUDI Wallet) is no longer about whether wallets will arrive. It is about deciding and executing. eIDAS 2.0 is moving from legislative intent to concrete implementation. In parallel, the EU anti-money laundering regime is becoming operational through the AMLR and related Regulatory Technical Standards (RTS), including the practical question of how remote identity verification must be performed. At the same time, PSR/PSD3 is setting the framework for payment execution and strong customer authentication (SCA), which remains central to digital onboarding, account servicing, and approval journeys.

Operationally, these frameworks now converge. eIDAS answers the question “who is this person?” AML/CFT rules answer “may we establish or continue this relationship?” and PSR/PSD3 governs “how do we securely approve and authenticate payments?”. In practice, identity, anti-money laundering controls, and payment security are becoming one trust and evidence chain rather than three separate compliance stacks.

What many leadership teams still underestimate is not the legal direction, but the operational physics of adoption.

Interoperability risk. There will not be one wallet. There will be multiple state-backed wallets and, depending on the country, private implementations, different credential formats, issuer policies, and registration regimes. Banks need a wallet-agnostic operating model rather than a single-wallet plan.
Liability and auditability. Accepting a wallet is not just adding another login option. It changes how identity is evidenced under Customer Due Diligence (CDD), and how robust that evidence will be under audit, supervision, or later disputes. Traditional KYC with physical ID documents will not disappear. But where remote proofing against physical documents is used, the strongest path is to close that journey with a qualified electronic signature (QES) and rely on ETSI-certified, eIDAS-2.0-aligned procedures so that the bank builds one end-to-end legally robust digital trust chain.
The last mile between compliance and conversion. A remote identification path that is compliant but too slow or too complex is not a strategic win. A high-assurance path with strong conversion is both risk reduction and growth enablement.

These issues are in focus in 2026 because onboarding and wallet roadmaps are increasingly discussed in public and across the market. The pressure does not come from regulation alone. It also comes from customer expectations: digital journeys must be fast, intuitive, and free of channel breaks, while still producing evidence that stands up in supervision, audit, and disputes.

The central shift for 2026: from video ident to self-ident

For many banks, the real operational turning point is not the wallet alone. It is the question of which remote identification method becomes the default from now on. The emerging AMLR RTS logic gives priority to eIDAS-defined methods: notified eID, the EUDI Wallet, and qualified electronic signatures (QES). Only where those routes are not available, or cannot reasonably be provided, does another form of remote verification against physical ID documents become relevant. That makes alternative methods a fallback with additional control, documentation, and justification requirements.

In practical terms, this means banks should stop designing future-state onboarding just around those remote IDV methods defined in today’s national AML laws such agent-assisted video calls because it has been done this way the last 10 years. Where customers do not yet use a digital identity, the recommended path under AMLR going into effect in July 2027 will be to structure remote proofing against the physical ID document in a way that remains eIDAS-2.0-aligned, protected by ETSI-based controls, and concluded with a QES. This creates one continuous legally valid path anchored high in the regulatory hierarchy rather than a lower-assurance process that later has to be justified case by case.

Whether the remote identification experience is accompanied by a human operator in a video session or performed by the user as an unaccompanied self-ident flow then becomes a secondary design choice. The primary question is no longer “agent or no agent?” but “how do we deliver the preferred assurance outcome with the best customer experience, the best conversion, and the strongest evidence chain?“.

Why this shift matters

Conversion and speed. Waiting times destroy conversion. Self-ident combined with immediate QES removes queue friction, starts instantly, and can be completed around the clock.
Scalability. Human operator capacity is finite, expensive, and in attended models often has to be multilingual. Self-ident scales more easily with demand spikes, campaigns, and seasonal peaks.
Operational resilience. The operating model shifts from queue management and staffing to quality control and fallback management: what happens in critical cases, where image quality is poor, where fraud signals appear, or where users simply get lost?
Regulatory fit. If eIDAS-compliant eID, wallet, and QES paths become the preferred methods, then every alternative route needs to be narrow, measurable, documented, and defensible before the financial supervisor. ETSI-certified remote identification procedures that support QES issuance can play this role even when they are fully unattended selfie-based journeys.

Smart onboarding now means fewer steps, better orchestration, and above all: no waiting for an agent unless a truly exceptional case requires it.

Expectation hardens: eIDAS becomes standard, fallback must be justified

If assisted video identification is still the mainstream element of your AML/KYC stack today, 2026 is the year to stop treating migration as optional. The direction of travel is clear: eIDAS-aligned electronic identification becomes the standard for remote identification, while alternative methods remain possible only if they are justified, safeguarded, documented, and aligned with the institution’s risk profile.

This affects more than retail onboarding. It also touches re-identification, account recovery, suspicious activity handling, high-risk products, and signature journeys where proof quality may later be challenged in court or in supervisory review.

Strategically, the question is not just “How do we integrate wallet usage?” It is “What is our default KYC path, and how do we design fallback paths that are both customer-centric and audit-ready?”.

In practice, eID and the EUDI Wallet are the preferred path for customers who already have and use those means. For everyone else, the strongest default is a QES-enabled journey based on an eIDAS-2.0-aligned remote identification process against the user’s physical identity document.

A downscaled onboarding flow without QES may still be possible in certain cases, but it is the path that demands far more supervisory comfort and justification. In any case, the chosen identification service should be able to demonstrate ETSI certification for the relevant remote identification process.

Consultations and RTS: influence now instead of reworking later

AMLA is working on technical standards during 2026, while consultation activity on Customer Due Diligence remains highly relevant for banks that want to shape practical implementation. This is a real opportunity to reduce future risk. Institutions that contribute operational experience on data sources, verification methods, proportionality, and fallback logic now can reduce later rework in controls, audit narratives, and supervisor discussions. That matters especially for cross-border business models.

What boards need to decide in 2026: three decision blocks

A. Target journeys: where wallet and digital identity become the default control plane

One common mistake is to treat wallet adoption as a single project with a single go-live. A more practical approach is to define a portfolio of journeys, each with explicit assurance, evidence, and channel requirements.

For most banks, three core processes should be fixed in 2026 for 2027 execution:

Retail onboarding (aka intial KYC), including cross-border variants and flows for non-citizens.
Re-identification journeys such as account recovery, device change, suspicious activity, and transaction-limit reviews.
Signature journeys with high economic value, such as credit agreements, wealth onboarding, and corporate signing authority.

For banks with a stronger corporate focus, add a fourth anchor journey: corporate onboarding (KYB) and signing-authority verification, where digital verifications of attestations already today can significantly reduce manual review and reconciliation work, while in near future the upcoming European Business Wallet (EBW) promises also here much simpler processes on the horizon.

For each journey, the board should decide:

Digital-first posture. Use eID or the EUDI Wallet whenever possible. For users who already have these means, it is typically the simplest customer path and the lowest-cost path for the relying party.
Fallback design. For customers who still rely on physical ID documents, use QES-capable remote identification procedures. Unattended self-ident models are likely to outperform attended models on scalability and cost, although both may coexist for some time.
Channel coverage. Define how the journey works in app, mobile web, desktop, assisted channels, and cross-device scenarios.

**B. Evidence strategy: “Prove it in 2027 and beyond” is the real requirement**

Evidence is more than log storage. For supervision, disputes, cross-border proceedings, and security incidents, each customer journey needs a defined evidence package.

Boards should require clear decisions on what is collected, how integrity and timing are protected, how auditors can review the material, and how retention, minimisation, and purpose limitation are operationalised.

That evidence package should include the captured proofing artefacts, verification outcomes, risk assessments, decisions, customer consents, and the reasons for any special-case or fallback treatment.

This point becomes even more important if a bank still wants to use video-ident flows without QES in some exceptional cases. The evidence package for those exceptions must still be strong, reviewable, and defensible, not only when the journey works perfectly, but especially when it does not.

C. Operating model and governance: wallet introduction is not a one-off project

Wallet readiness cuts across compliance, digital channels, fraud prevention, IT security, legal, and operations. Boards should therefore define a durable operating model with one accountable executive sponsor, one end-to-end product owner for identity and trust journeys, and explicit responsibilities for certification and registration where relevant, incident handling, service-provider oversight, governance of automated checks and risk models, and the implementation of changes driven by new standards and rules.

The strategic question is not ‘wallet yes or no?’. It is ‘which operating model gets us safely to 2027 and keeps us scalable after that?’.

What the best 2026 decisions look like

Fund core journeys end to end: user experience, controls, evidence, and operations together.
Define one coherent identity-assurance policy and reduce the number of parallel methods in day-to-day use.
Make wallet and eID the preferred default path where available, but do not expect to be able to get all required attestations from there.
Offer self-ident as the scalable standard alternative for users without wallet or eID.
Keep attended procedures as a fallback rather than the mainstream model.
Treat interoperability as a first-class risk across multiple wallets, credential formats, and national variants.
Define auditability as a product requirement so journeys remain reconstructable years later.

That is how the 2026–2027 window becomes a durable digital trust advantage: cross-border, wallet-agnostic, and more customer-friendly because customers no longer have to wait for an agent to continue the journey.

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