EU eIDAS wallet guideRelying party onboarding

EUDI Wallet Relying Party Onboarding Workflow

Use this workflow before a public or private service requests person identification data or electronic attestations of attributes from European Digital Identity Wallet users.

It focuses on the grounded onboarding record: relying-party role, registration information, intended use, requested data, presentation checks, user approval, validation evidence, and privacy controls.

Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
7

Cited legal and guidance references.

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

Under eIDAS Article 5b, an organisation that intends to rely on European Digital Identity Wallets for public or private digital services must onboard as a wallet relying party before requesting data from users. This page turns that requirement into a practical workflow for service providers and intermediaries without adding unsupported penalty, deadline, or certification claims.

Section 1

1. Confirm the relying-party role and service boundary

Start by documenting whether the organisation is the service provider that will request wallet attributes, or an intermediary acting for another relying party. eIDAS treats intermediaries acting on behalf of relying parties as relying parties, and the ARF describes a Relying Party Instance as the software and hardware used to interact with Wallet Units.

Keep the onboarding record at service level. A single organisation may have more than one intended use, and the ARF explains that separate intended uses may require separate presentation requests and registration information.

  • Actor record: legal name, Member State of establishment, registration number if applicable, contact details, and whether an intermediary is involved.
  • Service record: public or private service, user journey, online or proximity presentation, and the Relying Party Instance that will send requests to Wallet Units.
  • Boundary check: distinguish the relying-party service from wallet provider, PID provider, QEAA provider, Pub-EAA provider, and non-qualified EAA provider roles.
  • Intermediary check: if an intermediary requests attributes on behalf of a service provider, record the principal relying party and prohibit storage of transaction-content data by the intermediary.
Section 2

2. Prepare the registration and intended-use evidence

Before requesting wallet data, prepare the Article 5b registration package for the Member State where the relying party is established. The grounded minimum record is not a generic vendor questionnaire: it is the data needed to authenticate to wallets, contact the relying party, and explain the intended wallet use and requested data.

Use one intended-use entry for each materially different service purpose. The ARF states that a Wallet Unit can compare the requested attributes with the attributes registered for the relying party and warn the user if the request exceeds the registered set or if registration information cannot be retrieved.

  • Authentication information: Member State of establishment, relying-party name, and official registration number or official-record identifier where applicable.
  • Contact information: operational and compliance contacts that can handle registration changes, user complaints, data-erasure requests, and suspicious-request reports.
  • Intended use: concise service purpose, user journey, legal or business reason for wallet use, and whether identification is required or a pseudonym is sufficient.
  • Requested data: each PID or attestation attribute, source attestation type, whether selective disclosure is possible, and why the service needs that attribute.
  • Change control: owner and trigger for notifying the Member State without delay when registration information, intended use, contact details, or requested data changes.
Section 3

3. Design the wallet data request before building the integration

Translate each intended use into a wallet presentation request that a user can understand. The service should request only the attributes recorded for that intended use, use selective disclosure where available, and avoid identity disclosure when a pseudonym or narrower proof is sufficient under the applicable service rules.

The request design should also account for embedded disclosure policies. The ARF describes disclosure policies that may tell the Wallet Unit whether an authenticated relying party is allowed to receive an attestation, and the Wallet Unit presents the outcome to the user.

  • Attribute request matrix: intended-use identifier, requested attribute, attestation type such as PID, QEAA, Pub-EAA, or EAA, and the service decision the attribute supports.
  • Minimisation check: remove attributes that are not required for the service decision, and record why a pseudonym is or is not sufficient.
  • User-facing request text: relying-party identity, purpose, requested attributes, consequences of approval, and any disclosure-policy warning returned by the Wallet Unit.
  • Protocol evidence: whether the request uses a wallet-supported protocol or interface for requesting and validating PID or electronic attestations of attributes.
  • Exception handling: what the service does if the user rejects the request, if the wallet cannot retrieve registration information, or if an attestation policy warns against disclosure.
Section 4

4. Implement relying-party authentication, validation, and logging controls

The onboarding gate should not close until the technical team can prove the Relying Party Instance authenticates to Wallet Units and validates wallet evidence after the user approves the presentation. The ARF presentation flow includes access certificates, trust anchors, request signatures, certificate-chain validation, revocation checking, issuer signature validation, attestation revocation checks, and device-binding checks where relevant.

Keep evidence that explains both sides of the interaction: what the wallet can verify about the relying party before asking the user, and what the relying party verifies about the received PID or attestation before relying on it.

  • Access-certificate evidence: issuing authority, certificate chain, relying-party identity fields, intended-use linkage, expiry and revocation-check method.
  • Request-signing evidence: signed request payload, requested attributes, intended-use reference, nonce or replay-protection mechanism where applicable, and protocol version.
  • Wallet-side evidence: test showing that the Wallet Unit can authenticate the relying party and warn when requested attributes exceed registered attributes.
  • Relying-party validation evidence: issuer signature validation, attestation or PID revocation status check, wallet authenticity check, and device-binding or user-binding check where the use case requires it.
  • Operational logs: user approval result, attributes actually received, validation result, rejection reason, erasure-request handling path, and suspicious-request escalation path.
Section 5

5. Add privacy, security, and review gates before launch

The final onboarding review should be a privacy and security gate, not a marketing launch checklist. eIDAS requires wallet users to have control over wallet data and Article 5b limits relying parties to the registered data indication; the ARF identifies over-collection, impersonation, message interception, message tampering, and linkability as risks to address in the wallet ecosystem.

Close the workflow only when the service can show that it requests no more than registered attributes, identifies itself to the user, validates received evidence, accepts pseudonyms where identification is not legally required, and has a change process for registration updates.

  • Data minimisation: the production request exactly matches the registered intended use and requested attributes.
  • User control: the wallet interaction supports user approval or rejection and does not treat wallet approval as a standalone GDPR lawful basis.
  • Pseudonym handling: the service accepts pseudonyms where user identification is not required by Union or national law, and records any reason identity is required.
  • Security controls: mutual authentication, encrypted communication, signed requests or responses, certificate-chain validation, revocation checks, and replay-protection evidence are tested.
  • Linkability controls: discard unique fixed attestation elements when no longer needed, avoid cross-service correlation, and limit logs to the service evidence needed for audit, fraud, support, erasure, and dispute handling.
  • Reopen triggers: new intended use, new requested attribute, new Relying Party Instance, intermediary change, registration-data change, protocol or certificate change, suspicious-request report, or failed validation control.
Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • The ARF ties embedded disclosure-policy support for electronic attestations of attributes to the wallet integrity and core-functionality implementing rules.
"rules for the integrity and core functionalities"
eur-lex.europa.eu
Referenced sections
  • Commission implementing rules identify protocols and interfaces for wallet solutions, including relying-party request and validation interfaces referenced by the Commission implementing-regulation page.
"protocols and interfaces of eID Wallets solutions"
data.europa.eu
Referenced sections
  • The ARF cites this implementing regulation for registration of wallet-relying parties; use it as the implementing-act anchor for registration work where the local Member State process points to it.
"registration of wallet-relying parties"
eu-digital-identity-wallet.github.io
Referenced sections
  • The ARF risk discussion supports the security and privacy controls for relying-party requests, including selective disclosure, registered requested attributes, disclosure policies, and linkability mitigation.
"Relying Party linkability"
ec.europa.eu
Referenced sections
  • Commission service-provider guidance lists operational obligations such as not requesting extra data, identifying to users, validating PID and EAA data, accepting pseudonyms where appropriate, and notifying Member States about registration changes.
"Not request any extra user data"
eur-lex.europa.eu
Referenced sections
  • Article 5a and Article 5b ground the wallet user-control, privacy, registration, data-request, pseudonym, validation, and change-notification controls used in this launch gate.
"Users shall have full control"
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