Digital, Innovation, Payments
The EUDI Wallet is moving from concept to implementation
Published on 23 October 2026
The European Digital Identity Wallet is entering a decisive phase. For banks, the question is no longer whether the wallet will affect customer journeys, but how quickly they can prepare for its integration into onboarding, authentication and other key processes.
Summary
On 20 October, representatives from the Ministry of Digitalisation, Deloitte Luxembourg, ACA Luxembourg and the ABBL came together to discuss the implementation of eIDAS 2.0 and the European Digital Identity Wallet, and what it will mean in practice for banks and insurers.
Representing the ABBL, Amandine Laurent, Legal Adviser, AML/CFT, Compliance & Data Protection, and Arnaud Clément, Head of Payment & Innovation, explored the links between digital identity, AML/CFT, payments, fraud prevention and strong customer authentication.
A new identity layer for financial services
The EUDI Wallet is designed to provide a common European framework for digital identification, authentication, the sharing of verified attributes and qualified electronic signatures.
For financial institutions, this creates a range of potential use cases, including customer onboarding, access to online banking environments, transaction validation, electronic signatures and periodic KYC refreshes.
In Luxembourg, the national wallet is currently targeted for launch in early 2027, subject to the adoption of the relevant legislative framework.
For banks and insurers, preparation will need to cover several dimensions at the same time: legal and compliance requirements, customer journeys and technical integration.
From digital identity to customer due diligence
For AML/CFT purposes, the wallet could significantly simplify part of the customer identification and verification process.
However, verified identity does not in itself amount to full customer due diligence.
The information required under AML rules goes beyond the core attributes contained in the wallet. Elements such as the purpose of the business relationship, PEP screening, source of funds or wealth, risk assessment and ongoing due diligence will continue to form part of the wider KYC process.
One of the operational questions highlighted during the discussion concerns the scope of attributes available through the wallet. Address information, for example, is not part of the core Personal Identification Data currently foreseen, although Luxembourg is examining whether a certificate of residence could be made available as an additional attestation.
The interaction between digital identity and AML requirements will therefore require careful implementation, particularly around reliance, liability, data minimisation and supervisory expectations.
The wallet can make identification and verification more efficient, but it does not replace the full customer due diligence process. Banks will still need to collect and assess the information required under AML rules, and the key question will be how supervisors expect firms to rely on wallet data in practice.
Amandine Laurent
Legal Adviser, ABBL
A new tool for strong customer authentication
The wallet is also expected to become a new cross-border means of strong customer authentication.
At European level, the European Payments Council has been asked by DG CONNECT to support the development of a standardised approach for using the EUDI Wallet for SCA.
The EUDI Wallet is becoming a new cross-border means of strong customer authentication. For banks, the challenge now is to ensure that this can be integrated into existing payment and authentication journeys in a consistent and workable way across Europe.
Arnaud Clément
Head of Payments and Innovation, ABBL
A dedicated EPC task force has been launched, with work expected to proceed in phases and a first scheme targeted for summer 2027.
For payment service providers, this work will be important in ensuring that wallet-based authentication can be integrated consistently across borders.
Banks need to start preparing now
The implementation timeline is becoming increasingly concrete.
The AML Regulation will apply from July 2027, while banks and insurers are expected to be required to accept the EUDI Wallet for relevant use cases by the end of 2027.
This means institutions will need to assess now how the wallet fits into their existing identity and access management systems, e-signature solutions, onboarding processes and authentication journeys.
They will also need to decide whether they intend to use the wallet only as a relying party, or whether there is a business case for issuing their own attestations.
For banks, the opportunity goes beyond compliance. If implemented effectively, the wallet could help reduce friction in customer journeys, simplify access to trusted information and support more efficient cross-border financial services.
The challenge now is to move from regulatory preparation to operational readiness.
Arnaud Clément
Head of Payments and Innovation, ABBL
Published on 23 October 2026