EUDI Wallet: the actual country-by-country progress, 2 months before the deadline

In short: the deadline for the European digital identity wallet falls at the end of December 2026, in less than 2 months. And the most useful question is not which countries will be ready, but understanding what is being counted. France Identité, IT-Wallet, mObywatel and AltID are very real national apps, in production, with millions of users. They are not yet EUDI wallets within the meaning of the regulation: they are apps that are expected to become one. The distinction is not a legal detail, it is the heart of the matter, because the European certification scheme on which that status depends was still at draft stage in April 2026. For a company, the date that matters is in fact not December 2026 but December 2027, and it comes with two conditions that almost no one mentions.

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The deadline, and exactly where the date comes from

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The European digital identity wallet is created by Regulation (EU) 2024/1183 of 11 April 2024, published in the Official Journal on 30 April 2024 and in force since 20 May 2024. This text does not stand alone: it amends the 2014 eIDAS Regulation by inserting new articles into it, and it is those articles that carry the obligations.

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The time limit is set by Article 5 bis, paragraph 1: each Member State must provide at least one wallet within 24 months of the entry into force of the implementing acts referred to in Article 5 bis, paragraph 23, and Article 5 quater, paragraph 6. The starting point is therefore not the entry into force of the regulation, it is that of the technical acts.

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These acts were adopted on 28 November 2024, published in the Official Journal on 4 December 2024, and entered into force 20 days later, that is on 24 December 2024. The calculation gives 24 December 2026.

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One point of honesty is needed here, because it travels badly. No official Union document mentions 24 December 2026 in so many words. The Commission sticks to “end of 2026”. The precise date is a derivation, a solid and arithmetically verifiable one, but a derivation. If you cite it in a compliance document, cite how it is calculated as well.

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Incidentally, a second date circulates, “November 2026”. It comes from counting from the deadline for adopting the implementing acts and not from their entry into force. It is inaccurate.

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What is being counted, and why everyone gets it wrong

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This is the central confusion on the subject.

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Several countries today have national identity apps in production, used by millions of people. They make it possible to prove your identity, to carry a driving licence or a health insurance card, sometimes to sign. They work.

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But an EUDI wallet within the meaning of the regulation is something else: it is an app that is certified under a European scheme, notified, entered on the trusted lists, and able to interact with the wallets and relying parties of the other 26 Member States. Certification is not an option, it is a legal condition for providing a wallet.

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Yet ENISA, the European Union agency for cybersecurity tasked by the Commission with drawing up that certification scheme, only opened the public consultation on its draft scheme from 2 to 30 April 2026, on a version 0.4.6 accompanied by a security requirements document that was still preliminary. The finding set out in that work is unambiguous: in early 2026, no EUDI wallet had been deployed or certified.

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We have found no later institutional source contradicting that finding. Which does not mean it has not moved on, but that as at the date of this article, no one can publicly state that a certified EUDI wallet exists in a Member State. The dashboards that would settle the matter, in particular the list of wallet providers on the eIDAS dashboard, are the only source to consult to decide.

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The consequence is simple: when an article announces that a country “already has its European wallet”, it is almost always describing a national app.

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France: 5 million users, and still no date

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France Identité has been open to the general public since February 2024 and passed the 5 million user mark in early October 2026. In terms of real usage volume, it is one of the most advanced deployments in Europe.

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What works today, according to the figures published by the French government:

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• logging in to more than 1,800 services through FranceConnect, the French public identity federation service, without a username or password, for some 16 million logins;
• the single-use proof of identity, with more than 1 million documents generated;
• the fully online voting proxy, more than 80,000 proxies;
• proof of identity and of travel ticket on certain trains, more than 1 million users;
• the digital identity card at baggage check-in and at boarding in French airports, excluding border crossing, since June 2026;
• activation of the dematerialised health insurance card, more than 1 million;
• the digital driving licence, more than 1.7 million, and the digital vehicle registration document, more than 1 million.

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The service is run by France Titres, the French agency for secure identity documents, formerly the Agence nationale des titres sécurisés, together with the Ministry of the Interior. France Identité was also notified in September 2024 as the French electronic identity scheme at the high level of assurance, certified by ANSSI, the French national cybersecurity agency. Beware the shortcut: this is an eIDAS notification of an electronic identity, not a wallet certification. These are two separate regimes.

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France also coordinates the POTENTIAL pilot consortium, closed in September 2025, and APTITUDE, launched in October 2025 and devoted to travel and payment.

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An important point: no public date has been found for the availability of the French EUDI wallet. Official communications speak of a “future wallet”, with no timetable.

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Germany: a law passed on 15 October, a launch on 2 January 2027

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Germany is the clearest case, because it has put a date forward and stands by it.

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The Bundestag adopted the Digitale-Identitäten-Gesetz on 15 October 2026. The German wallet, named d-you, is to start on 2 January 2027, that is after the European deadline. Asked in July 2026 about possible delays, the federal government maintained that date and stated that it did not expect any slippage.

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Governance is split between several players: the Federal Ministry for Digital Affairs decides how the wallet is made available, the Federal Network Agency supervises the wallet and its providers, and the SPRIND agency, the German federal agency for disruptive innovation, coordinates technical development. A sandbox has been open since the end of January 2026, with a regional pilot in Saxony.

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What deserves to be noted is what is postponed at launch: the qualified electronic signature, pseudonyms, wallet-to-wallet communication and zero-knowledge proofs, the last of these with no date. Security evaluations are expected in early January 2027, full certification later.

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Worth keeping in mind: passage through the Bundesrat and promulgation had not been verified as at the date of this article.

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Italy: 12 million activations, a national framework

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Italy has built its Sistema IT-Wallet on a national legal basis, inside the IO app, with an architecture shared between the Department for Digital Transformation, PagoPA for the app, the State Mint and Printing Office as the trust anchor, and AgID, the Agency for Digital Italy, for the terms of participation.

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The official figures concern document activations, not users: 12 million activations in July 2026, after 10.1 million activations and 17.3 million documents loaded in February 2026, of which around 8.5 million driving licences and as many health cards.

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A test environment was opened in May 2026, then extended to private companies. Italian institutional sources describe a trial phase intended to prepare for interaction with the European architecture. They do not claim compliance with the European regulation.

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Three figures circulate about Italy and they designate three different things: activations, documents loaded, and a monthly user count that comes from the press. Do not mix them up.

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Poland: 11 million users, a pilot in December

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mObywatel has more than 11 million users, a figure from March 2026, and is one of the most widely adopted public apps in Europe.

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The European function is due to arrive in December 2026, as a pilot version. Two practical conditions are worth flagging. Access to the wallet will require a one-off strong authentication with a chip identity card and its PIN: the digital identity document in the current app will not be enough. And according to the most recent source, during the pilot mObywatel Europa would be a separate app, linked to mObywatel by deep links, with full merging planned for early 2028. In March the ministry described direct integration. That contradiction has not been settled.

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The Polish transposition law was still at draft stage according to the latest information available.

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The others, briefly and with caution

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• Denmark: AltID has been live since 3 June 2026, open from the age of 13, with creation of an identity card and an age attestation, verification through the national identity then NFC reading of the passport chip, selective disclosure, online and offline use. It is to become the Danish EUDI wallet, with no date announced for that status.
• Netherlands: the NL Wallet is still under development and the delay is officially acknowledged, with the government page stating in October 2026 that the wallets will arrive later than planned and that the implementing law still has to go into consultation. No new official date.
• Sweden: Sverige-id was approved in April 2026 at the highest level of assurance in the national framework, for a launch planned in December 2026. The Swedish authority does not present it as an EUDI wallet.
• Belgium: MyGov.be has been in production since May 2024, but no official 2026 source on how it fits with the European wallet could be found.

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On Spain, Austria, Greece, Finland and the majority of the other Member States, we have found no recent and reliable government source. We prefer to write that rather than copy out a commercial tracking table.

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One figure circulates widely: 24 of the 27 Member States would miss the deadline. It is journalistic in origin, from September 2026, and is corroborated by no institutional document. It is plausible in view of everything above, but it is not an official finding, and the article carrying it does not name the 3 countries said to be on time.

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The real problem is not national, it is between countries

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The national figures are impressive. The interoperability tests, much less so.

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In December 2025 the Commission held its first multi-day testing event, the Launchpad. The published results are precise and instructive: 16 countries present including 11 Member States, 19 organisations, 671 test cases run. The success rate stands at 74% on the 570 wallet-to-wallet tests, and falls to 44% on the 101 tests against the reference implementation. The report identifies three priorities, including stronger regulatory alignment to obtain a consistent interpretation of the requirements, and notes the absence of a unified trust signal allowing citizens to tell an official wallet from another app.

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The structural difficulties, set out at an international technical workshop in spring 2026 by a manager of the Italian programme, are of three kinds.

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Trusted lists duplicate one another. A single entity can hold several roles and appear on several lists, with revocation consistency to be maintained everywhere. Wallets and relying parties have to resolve identities across those lists, and Member States keep the freedom to take different approaches for some of them.

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Relying party registers remain national. A relying party can depend on 5 distinct trust sources: the access certificate chain, its revocation, the registration certificates, the status lists and the discovery interface. Above all, the policies of the registration bodies are not harmonised: compliance obtained with the register of one Member State is not automatically recognised in another. For a company present in several countries, this is the most expensive point.

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Existing sector infrastructures are not integrated. The invoicing, customs, data sharing and banking ecosystems already have their own trust chains. Without explicit articulation, validation is duplicated, and the question raised remains open: which list prevails?

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On top of that comes a certification difficulty that is rarely explained. The “high” level of the eIDAS Regulation and the “high” level of the cybersecurity regulation, under which the certification scheme is being drawn up, are two different notions. Assessment bodies also report overlaps with other European texts and a lack of clarity on timescales.

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What companies should really take away from this

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If you are a bank, an insurer, a telecoms operator, an energy, transport or healthcare player, three things matter, and the December 2026 date is not one of them.

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Your deadline is at 36 months, not 24. The obligation for private players to accept the wallet runs until 36 months after the entry into force of the implementing acts, that is 24 December 2027 on the same calculation as above. It targets service providers required, by law or by contract, to use strong authentication, in sectors that the text lists: transport, energy, banking, financial services, social security, health, drinking water, postal services, digital infrastructure, education and telecommunications.

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That obligation has two limits that almost no one mentions. It applies only at the voluntary request of the user: it is not an obligation of use imposed on your customers, it is an obligation to accept if a customer asks. And it excludes micro and small enterprises within the meaning of the 2003 European recommendation.

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Being a relying party involves an administrative step. You have to register with the registration body of your Member State and obtain an access certificate. Given the lack of harmonisation mentioned above, a multi-country company will in all likelihood have to deal with several registers.

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And one framing point, because it will avoid disappointments: the wallet supplies verified attributes, it does not do the rest of the work. It will prove that the person really is who they say they are, with a high level of assurance, which is considerable and will simplify the identification step. It will say nothing about whether a file makes economic sense, it will not screen sanctions or politically exposed persons, it will not check the authenticity of a proof of income, and it will not detect a manipulated customer acting of their own free will. Identification is only one building block of onboarding.

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What to watch in the coming months

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Four signals are worth more than the announcements:

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• publication of the final certification scheme by ENISA, a legal condition for any compliant wallet;
• the official list of wallet providers on the eIDAS dashboard, the only source that will settle who has actually delivered;
• the amending implementing acts adopted in 2026, which have already led to a new version of the architecture and reference framework in July 2026;
• the Commission's reaction after the end of December 2026: to date, no information exists on a possible infringement procedure or on any tolerance.

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The European wallet will arrive. The national investments are real, the apps work, and several tens of millions of Europeans already use a national version of one. But between a national app in production and a certified, interoperable cross-border ecosystem lies the hardest part of the journey, and that is precisely the part that is not finished. To see what, in your onboarding journeys, will depend on the wallet and what will remain your responsibility, schedule a demo.

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FAQ

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What is the deadline for the European identity wallet?

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The end of December 2026. Article 5 bis of the amended eIDAS Regulation requires Member States to provide at least one wallet within 24 months of the entry into force of the implementing acts, which entered into force on 24 December 2024. The calculation gives 24 December 2026, but the European Commission communicates only on “end of 2026” and does not mention that precise date in its documents.

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Is France Identité the European wallet?

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Not yet. France Identité is a national app in production, with more than 5 million users, notified in September 2024 as an electronic identity scheme at the high level of assurance and certified by ANSSI. That is an electronic identity notification, not a wallet certification within the meaning of the regulation. Official communications present it as the future French wallet, with no date announced.

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Which countries already have a certified EUDI wallet?

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No institutional source makes it possible to state this for any given country. The European certification scheme, which is mandatory for a wallet to be compliant, was still out for public consultation at draft stage in April 2026, and the finding set out at that time was that no wallet had been deployed or certified. The national apps in production, in France, Italy, Poland or Denmark, are expected to become EUDI wallets.

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From when will my company have to accept the wallet?

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From 36 months after the entry into force of the implementing acts, that is 24 December 2027 on the same calculation. The obligation targets private players required to use strong authentication, in particular in transport, energy, banking, financial services, social security, health, drinking water, postal services, digital infrastructure, education and telecommunications. It applies only at the voluntary request of the user and excludes micro and small enterprises.

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Will the wallet replace KYC?

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No. It will supply verified identity attributes with a high level of assurance, which will simplify identification and identity verification. It covers neither the screening of sanctions and politically exposed persons, nor the risk assessment of a business relationship, nor checking the authenticity of economic supporting documents, nor detecting a manipulated customer. Risk-based due diligence obligations remain in full.

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Why are the interoperability tests a cause for concern?

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Because the results published by the Commission after its first testing event, in December 2025, show a success rate of 74% on wallet-to-wallet tests and 44% on tests against the reference implementation, with only 11 Member States taking part. The difficulties lie less with the apps themselves than with the trust infrastructure: duplication of lists, relying party registers not harmonised between Member States, and no articulation with existing sector infrastructures.

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Sources: Regulation (EU) 2024/1183 of 11 April 2024 amending Regulation (EU) No 910/2014, Official Journal of 30 April 2024, in particular Articles 5 bis and 5 septies; Implementing Regulations (EU) 2024/2977, 2024/2979, 2024/2980, 2024/2981 and 2024/2982 of 28 November 2024, published on 4 December 2024; Implementing Regulations (EU) 2025/846 to 2025/849 and 2026 amending acts; Architecture and Reference Framework version 3.0.0 of 23 July 2026; European Commission, EU Digital Identity Wallet pages and Launchpad 2025 report; ENISA, public consultation on the draft wallet certification scheme, April 2026; France Identité and France Titres, October 2026 press releases; French interministerial digital directorate, October 2026; Bundestag, Digitale-Identitäten-Gesetz adopted on 15 October 2026 and federal government reply of 21 July 2026; Dipartimento per la trasformazione digitale, February and July 2026 press releases; Polish Ministry of Digital Affairs, March 2026; digitaleoverheid.nl, October 2026; Digg, April 2026; ITU workshop “Trustable and Interoperable Digital Identities”, Geneva, March 2026.