The revised eIDAS Regulation: What banks need to know now

The revised eIDAS Regulation expands the existing European legal framework for electronic identification and trust services. At its core is the EUDI wallet. Member States must provide at least one wallet. This will allow users to digitally manage their identity and other evidence and selectively transmit it to third parties. [1]

For banks, it is particularly important that the wallet does not remain a mere technical option. Article 5f(2) of eIDAS obliges private trusted parties in certain sectors, including banking and financial services, to accept EUDI wallets at the user's voluntary request if strong user authentication is required by law or contract for online identification. The deadline is generally 36 months after the entry into force of the relevant implementing acts, and thus, according to the current status, until December 24, 2027. [2]

Two dates that banks should keep an eye on

The AMLR will in principle apply directly in the Member States from 10 July 2027. [3]

What can the EUDI wallet do in the KYC process?

Today, many onboarding processes still involve document uploads, manual data entry, and multiple verification steps. A digital wallet can provide structured and technically verifiable data in this context. Instead of repeatedly entering information from an ID document...

Instead of typing, identity data can be directly transferred and the origin and integrity of a document can be technically verified.

The AMLR also explicitly addresses electronic identification. Article 22(6)(b) permits the use of electronic identification means with eIDAS security levels of "substantial" or "high," as well as relevant qualified trust services, for identity verification. EUDI wallets are provided under a notified electronic identification system with a "high" security level. [4]

This makes wallet data interesting for KYC processes. However, the bank must still, among other things, identify beneficial owners, understand ownership and control structures, determine the business purpose, conduct PEP and sanctions checks, assess customer risk, and continuously monitor the business relationship.

In short: The wallet can serve as a reliable data source and identification channel. The professional KYC decision remains with the institution.

Electronic attributes: particularly interesting for corporate banking

In addition to identity data, eIDAS 2.0 introduces electronic attribute certificates more strongly into the European trust framework. Such certificates can, for example, contain statements about a company function, authorization to represent a company, registration, or professional qualification. Qualified electronic attribute certificates are issued by qualified trust service providers and are subject to specific legal requirements. [5]

For banks, the main benefit lies in the fact that certain information can now be transmitted in a structured manner with verifiable origins. This can reduce the effort required for document verification and manual data entry. However, a single attribute does not automatically answer all legal questions. For example, the information "managing director" does not necessarily indicate whether a person is solely authorized to represent the company in a specific transaction.

For business applications, the planned European Business Wallet is also relevant. The European Commission presented its own regulatory proposal for this at the end of 2025. The Council adopted its negotiating position on 9 June 2026; however, the legislative process is not yet complete. [6]

What does this mean for banks in practical terms?

The most important task now is not to integrate as many wallet functions as possible. It makes more sense to examine existing identification and KYC processes to determine where structured digital evidence offers genuine added value.

• Plan for wallet acceptance: Check which online processes fall under the acceptance obligation of Article 5f paragraph 2 eIDAS and how the wallet can be technically integrated into existing routes.
• Clearly define KYC requirements: Determine which obligations can be supported by wallet data and which checks are still required regardless.
• Validate issuers and certificates: Ensure, both technically and professionally, that the origin, validity, and status of the submitted evidence can be verified.
• Do not prematurely shut down existing procedures: Using a digital wallet is voluntary for users. Therefore, institutions will continue to need alternative methods of identification.

Conclusion

eIDAS 2.0 won't change digital onboarding overnight, but it will create a new European standard for identity and verified credentials. For banks, this development coincides directly with the implementation of the AMLR (Adult Payment Services Directive).

The EUDI wallet can simplify identification, reduce media breaks, and integrate structured data into KYC processes. However, it does not replace anti-money laundering assessments or other due diligence obligations. Therefore, the ability to meaningfully integrate wallet data and electronic attributes into existing KYC processes, rather than creating a separate, parallel process, is particularly relevant.