eIDAS 2.0 for businesses: changes and implications

eIDAS 2.0 expands the European legal framework to include the European Digital Identity Wallet (EUDI-Wallet). It is intended to facilitate cross-border digital identification. Germany plans to launch a government-issued wallet in early 2027; its range of functions will be expanded gradually. In future, certain businesses will be required to accept a wallet for identification purposes if the conditions set out in Article 5f are met. The three signature levels – EES, FES and QES – will remain in place. signotec plans to integrate wallets into existing workflows as a means of identification and signing in future.

Regulation (EU) 2024/1183 was published in the Official Journal on 30 April 2024 and entered into force on 20 May 2024. It amends the eIDAS Regulation (EU) No 910/2014. The focus is on a European framework for digital identities. The rules governing simple, advanced and qualified electronic signatures remain in place.

For businesses, this distinction is important: identification via the wallet and the electronic signature are two separate steps. An obligation to accept the wallet does not imply a general obligation to accept wallet signatures. The Regulation in the Official Journal of the EU sets out the legal details.

An EUDI wallet is intended to enable people across Europe to identify themselves digitally and provide evidence. Its use is voluntary for citizens. Member States must provide at least one wallet. For Germany, the Federal Ministry for Digital and State Modernisation has announced that the first phase will begin in early 2027.

Qualified electronic signatures via the wallet are also planned. Which functions will be available at launch and how they will fit into business processes will depend on the specific implementation. Companies should therefore keep track of the roll-out and technical specifications.

Article 5f of the eIDAS Regulation concerns certain private services that already require strong user authentication for online identification. At the user’s request, these services must accept an EUDI wallet as a means of identification. Exemptions apply to micro-enterprises and small enterprises. The deadline begins 36 months after the entry into force of the relevant implementing acts; therefore, a blanket statement such as ‘for all businesses from 2027’ is too imprecise.

Whether a business is affected depends on the specific identification requirement and the service offered. The sectors mentioned, such as financial services or healthcare, are examples and do not constitute an exhaustive list of sectors. A legal assessment should be carried out for each specific process.

Existing signatures are not invalidated by eIDAS 2.0. The simple electronic signature (EES), the advanced electronic signature (FES) and the qualified electronic signature (QES) remain distinct levels. The level required depends on the document and the statutory formal requirements. A biometric FES using a signature pad can still be used for suitable processes; where the statutory written form is to be replaced by an electronic form, the QES is generally required, provided that the law permits the electronic form.

With signoSign/Universal, companies can already implement advanced and qualified signature processes within a browser. The wallet is a potential addition for future identification methods.

First, check which signature level is required for each document type. Then, clarify whether your online services are subject to a requirement for strong user authentication and whether Article 5f may be relevant. Document existing FES and QES processes and monitor the roll-out of the wallet in your target markets.

signotec plans to integrate the EUDI wallet into existing workflows in future as a further option for identification and signing. This is a planned feature; it is not yet available, and no specific launch date has been confirmed. For current browser-based signing processes, signoSign/Universal already supports FES and QES.

Do all businesses have to accept a wallet?

No. The obligation to accept the wallet is subject to the conditions set out in Article 5f and relates to identification at the user’s request. Exceptions and implementation deadlines must be taken into account.

When will the German digital wallet be launched?

The relevant federal ministry is planning the first phase for early 2027, followed by a phased roll-out. Dates and functions should be reviewed again prior to publication.

Will the signature levels change?

No. EES, FES and QES will continue to apply.

Conclusion

eIDAS 2.0 introduces a new approach to digital identification with the EUDI wallet. Organisations should assess their potential obligations regarding acceptance and monitor the practical roll-out. Existing signature processes can continue as normal; signotec plans to integrate the wallet into these workflows at a later stage.