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Compliance CalendarEU

eIDAS 2 deadlines and compliance calendar

Track binding eIDAS 2 dates for EUDI Wallet delivery, annual reports, and trust-service transitions alongside implementing acts and non-binding programme milestones.

Use the legal trigger, affected actor, owner, and evidence for each date. A Commission publication, pilot, or Architecture and Reference Framework update is not automatically a compliance deadline.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 24, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
12

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 24, 2026
Overview

The main delivery date is 24 December 2026: Article 5a requires each Member State to provide at least one wallet within 24 months after the relevant implementing acts entered into force on 24 December 2024. The Commission describes this as delivery by the end of 2026. Other entries below have different legal effects, including annual reporting dates, Commission adoption dates, trust-service transition dates, and non-binding technical programme milestones.

Section 1

Milestones to put on an eIDAS compliance calendar

Use one calendar row per legal or programme milestone. Record the legal trigger, affected actor, internal owner, evidence to keep, and whether the date is fixed, recurring, transitional, or calculated from another act.

A date by which the Commission had to adopt an implementing act is not automatically a date by which a provider had to comply. Once an implementing regulation is adopted, read that act for its entry into force, application date, transitional rule, and referenced standards. Pilots, Architecture and Reference Framework publications, and reference implementation releases are readiness inputs rather than binding deadlines.

  • 3 June 2021: the Commission Recommendation started the toolbox workstream for the technical Architecture and Reference Framework, common standards, technical specifications, guidelines, and best practice.
  • 22 February 2022: the eIDAS expert group adopted and published the ARF outline for stakeholder feedback; the source states the outline was non-mandatory.
  • 10 February 2023: the Commission published ARF v1.0.0 as specifications for developing interoperable solutions.
  • April 2023 to 2025: four large-scale pilots tested technical specifications and use cases before Member State rollout.
  • 20 May 2024: the European Digital Identity Framework entered into force, amending eIDAS and adding the framework.
  • 21 November 2024: several provisions set this as the Commission's deadline to adopt implementing acts for wallet functions and electronic attestations of attributes. It was an EU rulemaking deadline, not a general provider compliance date.
  • 4 December 2024: five first-wave wallet implementing regulations were published. Four cover the Article 5a(23) subjects of protocols and interfaces, integrity and core functions, person identification data and attestations, and ecosystem notifications; the fifth covers wallet certification.
  • 24 December 2024: the relevant first-wave implementing regulations entered into force. This is the starting point for the 24-month wallet-availability calculation in Article 5a(1).
  • 2025: adopted acts replaced many earlier Commission adoption deadlines with operative rules. The May acts cover identity matching, wallet security breaches, relying-party registration, and certified-wallet lists; the July acts cover identity and attribute verification, remote qualified creation-device management, peer review, authentic-source attestations, device notifications, supervisory reports, and initiation of qualified services.
  • Late 2025: further acts cover qualified timestamps, signature and seal validation, qualified certificates, registered delivery, preservation, non-qualified-service risk management, conformity assessment, trusted lists, QWACs, qualified-provider requirements, electronic ledgers, and electronic archiving. Use the individual act, not its former adoption deadline, to set an operational date.
  • By 31 March each year: wallet supervisory bodies and trust-service supervisory bodies report their previous year's main activities to the Commission. Member States separately report the statistics collected under Article 48.
  • 21 May 2026: Article 49 set this as the date for the Commission's review report. Article 51 also ends specified transition measures for legacy qualified certificates and remote qualified signature or seal creation-device management, and requires QTSPs qualified before 20 May 2024 to have submitted conformity evidence for amended Article 24(1), (1a), and (1b).
  • 24 December 2026: each Member State must provide at least one under the 24-month formula in Article 5a(1). The Commission's public summary describes this as delivery by the end of 2026.
  • 21 May 2027: secure signature creation devices assessed under Directive 1999/93/EC continue to be considered qualified electronic signature creation devices only until this date.
Sources for this answer
Regulation (EU) 2024/1183 establishing the European Digital Identity Framework
Supports the eIDAS 2 legal trigger, wallet availability dependency, implementing-act dates, annual reporting dates, review date, and transitional trust-service dates.
European Commission - EUDI Wallet implementing regulations
Supports the 4 December 2024 publication milestone and the five implementing-regulation topic areas for the EUDI Wallet.
Commission Implementing Regulation (EU) 2024/2977 on person identification data and attestations
Identifies the four implementing regulations used for Article 5a(23), records Official Journal publication on 4 December 2024, and provides the entry-into-force rule used to calculate 24 December 2026.
European Commission - EUDI Wallet pilot implementation
Supports the April 2023 large-scale pilot launch, pilot continuation through 2025, and the role of the reference implementation and ARF in wallet readiness.
Section 2

What each calendar owner should evidence

The calendar is useful only if each row tells an owner what changed and what proof to keep. For eIDAS 2, the same date can affect different teams in different ways: a wallet provider tracks certification and core functions, an issuer tracks person identification data and attestations, a relying party tracks registration and data-request controls, and a QTSP tracks Article 24, remote QSCD, certificate, preservation, timestamp, and website-authentication standards.

For a calculated date, keep the formula and the calculation. For wallet availability, record Article 5a(1), the 24 December 2024 entry into force of the relevant acts, the resulting 24 December 2026 date, and the Commission's end-of-2026 summary.

Do not use the amended Regulation's 2025 Commission adoption deadlines as the current status. The Commission-maintained Architecture and Reference Framework lists the implementing regulations adopted during 2025. For a particular product or trust service, open the regulation itself and record its entry into force, application date, transition, and referenced-standard provisions.

  • Wallet provider: keep the Article 5a requirement mapping, certification status, core functionality evidence, notification record, breach and incident escalation procedure, validation mechanism, and accessibility evidence.
  • Issuer or authentic-source owner: keep the person identification data and attribute model, the electronic attestation interface evidence, source authority proof, revocation process, and wallet issuance test records.
  • Relying party: keep registration status, lawful data-request purpose, authentication mechanism, selective-disclosure requirements, wallet validation checks, and records for erasure or suspicious-request handling.
  • Qualified trust service provider: keep amended Article 24 conformity evidence, supervisory-body notices for service changes or cessation, security-breach notification procedures, termination plan, certificate or service standard mapping, and annual reporting support.
  • Supervisory or public-sector owner: keep the annual 31 March report pack, cooperation and mutual-assistance records, notified body or public-sector-body evidence, and machine-readable publication evidence where required.
  • Programme owner: keep ARF version evidence, technical-specification decisions, pilot feedback, reference implementation dependencies, test coverage, and a clear line between non-mandatory toolbox material and binding implementing or delegated acts.
Sources for this answer
Regulation (EU) No 910/2014 consolidated with eIDAS 2 amendments
Supports the amended eIDAS obligations for wallet providers, relying parties, trust services, supervision, annual reporting, and transitional QTSP compliance evidence.
European Commission - EUDI Regulation overview
Supports the policy summary that Member States must provide EUDI Wallets by the end of 2026 and that wallets extend the eIDAS framework to public and private services.
European Commission - EUDI Wallet home
Supports practical ecosystem roles, wallet use cases, implementing-act navigation, and Commission wallet readiness material for issuers and service providers.
EUDI Wallet Architecture and Reference Framework - adopted implementing regulations
Commission-maintained technical framework whose legal-context register identifies the 2024 and 2025 implementing regulations. The ARF is implementation material; the linked regulations, not the ARF itself, are the binding legal sources.
Section 3

Fixed dates and dependent triggers to track separately

Keep separate fields for fixed dates, recurring dates, and calculated dates. Fixed dates include the 21 May 2026 review and transition date and the 21 May 2027 device-transition expiry. The 31 March reports recur annually. Wallet availability and authentic-source verification are calculated from the entry into force of specified implementing acts.

For the wallet rollout, the legal formula and the Commission summary now converge: the relevant acts entered into force on 24 December 2024, producing 24 December 2026, which falls within the Commission's end-of-2026 description. Retain the formula because later amendments or a different dependent provision may use another trigger.

  • Fixed legal date: 21 November 2024 for specified and electronic attestation implementing acts in Articles 5a, 5c, 45d, 45e, and 45f.
  • Fixed publication milestone: 4 December 2024 for the Commission library page announcing five adopted implementing regulations.
  • Recurring fixed date: 31 March each year for wallet and trust-service supervisory-body annual reports and Member State Article 48 statistics reports.
  • Historical adoption deadline: 21 May 2025 for Commission formats and procedures for wallet supervisory reports, procedural cooperation, and multiple trust-service standard lists or guidance items; use the adopted 2025 implementing regulations for current requirements.
  • Fixed legal date: 21 May 2026 for submission of the Commission eIDAS review report and for several transitional measures affecting qualified certificates, remote qualified signature or seal creation-device management, and QTSP conformity evidence.
  • Calculated legal date: Article 5a requires at least one European Digital Identity Wallet within 24 months of the relevant acts' entry into force. The acts entered into force on 24 December 2024, producing 24 December 2026.
  • Calculated legal date: Article 45e uses the same 24-month trigger for measures that let qualified trust service providers of electronic attestations of attributes verify specified public-sector authentic-source attributes electronically, producing 24 December 2026.
  • Fixed transition end: 21 May 2027 for secure signature creation devices previously assessed under Directive 1999/93/EC.
Sources for this answer
Regulation (EU) 2024/1183 establishing the European Digital Identity Framework
Supports the fixed dates and dependent legal triggers that should be separated in an eIDAS calendar.
European Commission - EUDI Wallet implementing regulations
Supports the 4 December 2024 publication date and implementing-regulation categories used as programme evidence.
Commission Implementing Regulation (EU) 2024/2979 on wallet integrity and core functions
One of the Article 5a(23) acts; its 4 December 2024 publication and twentieth-day entry-into-force clause support the 24 December 2024 trigger date.
Section 4

Source-check rules for maintaining this calendar

Before adding a new eIDAS calendar row, classify the source. EUR-Lex legal text supports binding dates and obligations. Commission wallet pages support programme milestones, ARF releases, pilots, technical specification navigation, and policy summaries. ENISA and ETSI material can support security, supervision, and standards context, but should not be used to invent statutory deadlines.

Do not add penalties, thresholds, fines, or national supervision dates unless the source directly states them. For this page, the official source calendar focuses on EU-level eIDAS and eIDAS 2 dates; Member State wallet launch dates, national supervisory enforcement deadlines, and sector-specific acceptance dates need separate source support before publication.

  • Use EUR-Lex for binding eIDAS and eIDAS 2 articles, review dates, reporting dates, transitional measures, and implementing-act deadlines.
  • Use Commission pages for ARF publication dates, large-scale pilot milestones, reference implementation status, and the public end-2026 wallet readiness summary.
  • Use ENISA only for security and supervision context unless a specific ENISA source gives a calendar date relevant to the page.
  • Use ETSI standards for trust-service control and standards context, not as a substitute for legal application dates.
  • Store the source title, URL, source type, legal provision, date claim, calculation, affected actor, internal owner, dependency, and evidence artifact in every internal calendar row.
Sources for this answer
European Commission - EUDI Wallet Architecture and Reference Framework
Supports the 10 February 2023 ARF v1.0.0 publication milestone and the role of ARF material as technical implementation evidence.
European Commission - EUDI Wallet ARF outline
Supports the 3 June 2021 toolbox recommendation, 22 February 2022 ARF outline milestone, and the distinction between non-mandatory outline material and binding legal acts.
ENISA - Guidelines on supervision of qualified trust service providers
Supports using ENISA material as supervision context for QTSP oversight rather than as a source of new statutory calendar dates.
Recommended next step

Build an evidence-backed eIDAS calendar for wallets, QTSPs, issuers, and relying parties

Use the cited sources listed here to verify obligations and the supporting evidence requirements.

Research workflow
Open Research Copilot for eIDAS

Check eIDAS 2 dates, wallet implementation dependencies, and QTSP transitions against the cited Commission and EUR-Lex sources.

Explore next step
Talk to Sorena
Review your eIDAS calendar

Check whether your wallet, issuer, relying-party, or trust-service calendar separates legal deadlines from programme milestones and has evidence for each row.

Explore next step
Primary sources

References and citations

EUDI Wallet Architecture and Reference Framework - adopted implementing regulations
eu-digital-identity-wallet.github.io
Referenced sections
  • Commission-maintained technical framework whose legal-context register identifies the 2024 and 2025 implementing regulations. The ARF is implementation material; the linked regulations, not the ARF itself, are the binding legal sources.
"adopted Commission Implementing Regulations"
European Commission - EUDI Regulation overview
digital-strategy.ec.europa.eu
Referenced sections
  • Supports the policy summary that Member States must provide EUDI Wallets by the end of 2026 and that wallets extend the eIDAS framework to public and private services.
"by the end of 2026"
European Commission - EUDI Wallet ARF outline
digital-strategy.ec.europa.eu
Referenced sections
  • Supports the 3 June 2021 toolbox recommendation, 22 February 2022 ARF outline milestone, and the distinction between non-mandatory outline material and binding legal acts.
"non-mandatory"
European Commission - EUDI Wallet home
ec.europa.eu
Referenced sections
  • Supports practical ecosystem roles, wallet use cases, implementing-act navigation, and Commission wallet readiness material for issuers and service providers.
"same common specifications"
European Commission - EUDI Wallet pilot implementation
digital-strategy.ec.europa.eu
Referenced sections
  • Supports the April 2023 large-scale pilot launch, pilot continuation through 2025, and the role of the reference implementation and ARF in wallet readiness.
"four large-scale pilot projects"
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