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FAQEU

EUDI Wallet relying parties under eIDAS

A relying party is the public or private service provider that asks a user to present identity data or attestations from a European Digital Identity Wallet.

Register in the Member State of establishment, declare the purpose and data list, identify the service to users, validate wallet data, and retain evidence that requests stayed within the registered scope.

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Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
4 sections5 primary sources
Overview

Under the amended eIDAS framework, an intends to rely on European Digital Identity Wallets for a public or private service delivered through digital interaction. Article 5b sets the role's registration, data-request, identification, validation, and change-notification duties. Commission Implementing Regulation (EU) 2025/848, as amended by Commission Implementing Regulation (EU) 2026/1730, supplies the harmonised registration mechanics, but they do not apply until 24 December 2026.

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4 of 4 questions
Question 1

Who is an EUDI Wallet relying party under eIDAS?

A relying party is the service provider side of a wallet interaction: a public or private organisation that requests data from a user's EU Digital Identity Wallet before granting access to a service, verifying a customer, enrolling a student, checking a professional mandate, or receiving a digital document.

For Article 5b, the trigger is the intention to rely on the wallet for public or private services by means of digital interaction. Once that trigger is present, the relying party must register in the Member State where it is established. Because the harmonised national-register rules apply from 24 December 2026, a team preparing earlier must verify whether its Member State has already opened a registration route instead of assuming that an EU-wide registration portal exists.

  • Treat the role as triggered by wallet reliance, not by the organisation's sector label.
  • Map each wallet use case to the service being provided, the establishment Member State, and the specific wallet data needed.
  • Distinguish a relying party from wallet providers, PID providers, and attestation providers; the relying party is the service side requesting and receiving presented data.
  • If an intermediary acts on behalf of the relying party, Article 5b treats the intermediary as a relying party and restricts it from storing transaction-content data.

What is an under the EU eIDAS Regulation?

It is the public or private service provider that intends to rely on a European Digital Identity Wallet for a digital service interaction. In practice, that means the party asks the user to present , an , or other wallet-held data so the service can authenticate the user, verify an attribute, or process a digital document.

Question 2

What must be registered before requesting wallet data?

Article 5b requires the relying party to register in the Member State where it is established. The registration must include information needed for the party to authenticate to EUDI Wallets, contact details, and the intended wallet use, including the data the relying party will request from users.

From 24 December 2026, Commission Implementing Regulation (EU) 2025/848 harmonises the registration process. It requires national registers and policies, accurate registration data, prompt updates, verification against supporting documents or authentic sources, and cancellation when the relying party stops relying on wallets under that registration.

Article 5b limits the live request: relying parties must not ask users for data beyond what they indicated during registration. The registered purpose and attribute list therefore form a control boundary for product, legal, privacy, and engineering teams.

  • Registration jurisdiction: the Member State where the relying party is established.
  • Identity material: information needed to authenticate the relying party to wallets, including name and official registration details where applicable.
  • Contact details: the public contact record associated with the wallet relying-party registration.
  • Purpose and data list: the intended use of the wallet and the user data or attributes to be requested.
  • Change control: notify the Member State without delay when registration information changes.

Does an need authorisation before requesting wallet data?

The cited rule is registration, not a general EU-level pre-authorisation approval. Article 5b requires registration in the Member State of establishment and says the process must be cost-effective and proportionate to risk. Recital 17 adds that registration should not entail a pre-authorisation process, while leaving other Union or national service-specific laws unaffected.

Can an ask for attributes that were not listed during registration?

No. Article 5b says relying parties must not request user data other than the data indicated in the registered intended-use information. A new attribute, new purpose, or changed service should therefore reopen the registration and privacy review before it appears in the wallet request.

When do the harmonised EUDI Wallet relying-party registration rules apply?

Commission Implementing Regulation (EU) 2025/848 applies from 24 December 2026. Article 5b already establishes the registration duty, but before the harmonised rules apply, a relying party should verify the relevant Member State's register, policy, availability, and onboarding route rather than assume that the same process is live across the EU.

Question 3

How should the wallet interaction work for users?

The relying party should authenticate and identify itself to the user, request only the registered data needed for the service, and let the wallet present the specific requested data before the user confirms. Article 5b also makes the relying party responsible for authenticating and validating the and electronic attestations of attributes it requests from wallets.

The ARF adds a useful technical control point: the wallet can use relying-party registration information or certificates to help verify whether a request fits the registered attributes and warn the user if it does not. That technical model supports the legal purpose, data-minimisation, and transparency checks, but the binding obligation remains in eIDAS and applicable data-protection law.

  • Show the relying-party identity before requesting wallet data.
  • Display the specific PID fields, attestations, or attributes being requested for the transaction.
  • Allow the user to confirm or refuse the presentation through the wallet flow.
  • Validate the authenticity and validity of received PID or EAA data before relying on it.
  • Accept pseudonyms where Union or national law does not require identification of the user.

What should an show the user before receiving wallet data?

The relying party should identify itself and request only the specific data needed for the registered purpose. The Commission service-provider flow describes the wallet displaying the requested data to the user before confirmation, and Article 5b requires relying parties intending to rely on wallets to identify themselves to the user.

Who validates and electronic attestations received from an EUDI Wallet?

Article 5b places that responsibility on the relying party. The relying party must carry out the procedure for authenticating and validating the PID and electronic attestations of attributes it requested from the wallet, rather than treating the wallet presentation alone as a complete business approval.

Question 4

What evidence should a relying party keep?

A useful relying-party evidence record should prove that the live wallet request matches the registered purpose and data list. It should also show that the user saw who was requesting the data, what data was requested, and which validation procedure the service applied to the wallet response.

Avoid storing more wallet transaction content than the service needs. The ARF highlights relying-party linkability risks from unique fixed attestation elements, and Article 5b specifically says intermediaries acting for relying parties must not store data about transaction content.

  • Member State registration record, relying-party name, official registration details where applicable, and contact details.
  • Registered intended use, requested PID fields or attestation attributes, and the product/service feature that uses each item.
  • Wallet request configuration, relying-party authentication material, and, under the harmonised rules applying from 24 December 2026, wallet-relying-party access and registration certificates.
  • Validation procedure for PID and electronic attestations of attributes, including what is checked before granting service access.
  • Change log showing when a new service, purpose, data field, intermediary, or establishment fact triggered registration review.
  • Data-retention note explaining which transaction elements are discarded when no longer needed to reduce linkability and over-collection risk.
  • Do not misstate the harmonised registrar's 10-year recordkeeping duty as a blanket relying-party retention period. Commission Implementing Regulation (EU) 2025/848 requires registrars to keep registration, certificate-issuance, and change records for 10 years; the relying party still needs a separate legal and operational basis for retaining transaction content.

What evidence should an keep under eIDAS?

Keep the registration record, declared wallet purpose, requested data list, contact details, wallet request configuration, user-facing identification evidence, validation procedure for PID and electronic attestations, and change notifications. From 24 December 2026, also retain the access certificates and automatically issued registration certificates produced by the applicable national process. The record should let a reviewer compare the registered scope with the actual wallet request.

What records help prove a wallet request stayed within the registered scope?

Keep the registration record, the data list declared for the wallet use case, the user-facing request details, and the change log for any later scope updates. That combination shows whether the live request matched the registered intended use and helps explain any later review or update.

What happens if an EUDI Wallet relying-party registration is suspended or cancelled?

Under the harmonised rules applying from 24 December 2026, the registrar may suspend or cancel a registration for specified non-compliance, security, legality, fraud, or cessation grounds. The registrar must notify the affected relying party and relevant certificate providers without undue delay and no later than 24 hours after the action; the providers must then revoke the related access and registration certificates without undue delay where applicable. The service should stop making wallet requests under the affected registration until the status and any required remediation are resolved.

Recommended next step

Turn relying-party registration duties into wallet request evidence

Sorena can help map EUDI Wallet use cases to registered purposes, requested attributes, user-facing disclosures, validation checks, and change-control evidence.

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Primary sources

References and citations

Regulation (EU) 2024/1183 establishing the European Digital Identity Framework
eur-lex.europa.eu5 citations
Referenced sections
  • Primary legal source for EUDI Wallet relying-party registration, registered data limits, user identification, validation duties, pseudonym acceptance, intermediaries, and change notification.
  • Recital 17 and Article 5b ground the relying-party registration trigger and the distinction between registration and pre-authorisation.
  • Article 5b lists the registration fields and prohibits requests for data beyond the registered indication.
Show 2 more
  • Article 5b assigns user identification, PID/EAA validation, and pseudonym acceptance duties to relying parties.
  • Article 5b supports the evidence fields for registration, change notification, relying-party identification, validation, pseudonym acceptance, and intermediary limits.
"European Digital Identity Wallet-Relying Parties"
More quoted passages
"Registration should apply exclusively to relying parties providing services by means of digital interaction."
"Relying parties shall not request users to provide any data other than that indicated"
"they shall identify themselves to the user"
"inform Member States without delay about any changes"
Commission Implementing Regulation (EU) 2025/848 on wallet-relying-party registration
eur-lex.europa.eu4 citations
Referenced sections
  • Current implementing act for national registration processes, applying from 24 December 2026.
  • Defines national registers, registration policies, verification, access certificates, suspension and cancellation, and applies from 24 December 2026.
  • Sets the harmonised registration data, national policy, verification, update, cancellation, and certificate rules that apply from 24 December 2026.
Show 1 more
  • Supports the registrar's 10-year recordkeeping period and the suspension, cancellation, notification, and certificate-revocation consequences that apply from 24 December 2026.
EUDI Wallet Architecture and Reference Framework
eu-digital-identity-wallet.github.io4 citations
Referenced sections
  • Technical reference for relying-party role boundaries, registration certificates, registered attribute checks, user approval, and linkability controls.
  • The ARF explains the technical relying-party role as a service provider requesting wallet attributes subject to user approval.
  • The ARF explains technical request controls, including registered attributes, user approval, and wallet warnings for requests outside registered scope.
Show 1 more
  • The ARF grounds evidence for registered attributes, user approval, and retention controls that reduce relying-party linkability risk.
"Relying Parties, Relying Party Instances, and intermediaries"
More quoted passages
"A Relying Party is a service provider requesting attributes"
"the User retains control over their data"
"Relying Parties will discard the unique fixed elements"
European Commission - Wallet for service providers
ec.europa.eu4 citations
Referenced sections
  • Commission service-provider guidance explaining practical wallet data-request flows and operational obligations for organisations requesting wallet data.
  • Commission service-provider guidance describes service providers as organisations requesting data from a wallet before granting service access.
  • Commission guidance restates the practical registration, intended-use, requested-data, no-extra-data, and change-notification obligations for service providers.
Show 1 more
  • The Commission service-provider flow describes wallet display of requested data and user confirmation before service access or document presentation.
"Learn how organisations can request data from wallet users."
More quoted passages
"Service providers are public or private sector organisations that request data from an EU Digital Identity Wallet"
"Detail how you intend to use EU Digital Identity Wallets"
"wallet displays the specific data requested"
Commission Implementing Regulation (EU) 2026/1730 amending Implementing Regulation (EU) 2025/848 as regards applicable standards and specifications
eur-lex.europa.eu3 citations
Referenced sections
  • Amending act, entering into force on 11 August 2026, that requires automatic registration-certificate issuance without undue delay when the harmonised rules apply.
  • Amends the registration-certificate rules before their application date to require automatic issuance without undue delay after registration.
  • Requires automatic registration-certificate issuance without undue delay when the harmonised rules apply.
"automatically and without undue delay"

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