From Strategy to Implementation: European Countries' Progress Toward the EUDI Wallet 2026 Deadline [Intermediate]

Thank you and welcome to this session named From Strategy to Implementation, when we will show you about how different European countries are moving toward the UDI wallet implementation and how they are in pattern to meet the 2026 deadline at the end of the year. So just a brief presentation of us, I'm Clarissa Falcone, Senior Researcher at the Digital Identity & Wallet Observatory of the School of Management of Politecnico University of Milano. I don't know if you... it's a pretty quite famous university in Italy. And together with me today Niccolò Cirri that is analyst on the same project.

Here you can find our email, so feel free to get in touch if you have questions or curiosities about our activity. So just a brief presentation of the observatory. This is a permanent research project that we started, I think, six years ago in 2020. So now we are at the sixth edition of the observatory. So we basically... our DNA is the research. So we develop empirical evidence and we will show you some of them just in a few minutes.

And our mission is to develop knowledge about digital identity systems but also about digital identity wallets and new future megatrends in this field that could be useful for development of the market. So that could be useful for stakeholders like many of you of private companies but also about institutional public administration and so on. The other pillars that you see in these slides are much more related to our community activities. So we have a community of companies that follow us, that join us during the research edition.

And together with them we collaborate in these different workshop and conference moments. Niccolò. Grazie. So hi everyone, good morning from me as well. Before going into the details of the presentation, let me briefly show you two introductory slides. This is how we as an observatory define a digital identity system and a digital identity wallet.

For us, a digital identity system is a solution which enables the collection of data which can be used to uniquely identify an entity. So both, for example, a customer or a business. This data can be used within an ecosystem of actors in order to allow the entity to access some value-added services. A digital identity wallet instead is a solution which enables the storage of documents which must be related to the identity of the entity. They must not be necessarily identity documents. The important thing is that they are somehow related to the identity.

These documents must enable some transactions, must be functional to the entity. And in particular, they can be used both in the physical and in the digital world. This is quite a slight difference with respect to digital identity systems which are traditionally used in the digital world.

Finally, the digital identity wallet allows autonomous management. So the entity is independent, is autonomous to request it, to delete and to share its data. From a methodological point of view, what we are going to show you is based on a census. So we have internal to the observatory which is made of 306 cases, both identity system and identity wallets.

And the census has been built starting from the analysis of the secondary sources such as the articles and the reports in order to map these solutions according to several variables and several dimensions which have allowed us to understand how these solutions work and what functionalities they allow. Starting from this, what we are currently seeing in Europe is a transition. We are starting on our left from an identity system-based landscape to an identity wallet-based system. As we know, the key driver which is pushing, which is moving this transition is EI-2.

So there is a strong regulatory requirement which is pushing this transition from identity system to identity wallet. In this map, you can see the starting point of this transition. Here we used some colors and some symbols in order to try to make it as clear as possible. You can see some light blue solutions and we are referring to the EIDAS notified solutions. So the solutions which are in line with the standards which are imposed by the EIDAS and other solutions which are represented with the blue diamond.

They refer to solutions which are based on a physical document, usually the electronic ID card. What you can see here is that there is a strong heterogeneity in the European landscape. We have several solutions and we have also several strategies that countries have adopted in order to introduce a digital identity solution. Here we represented three clusters. For example, at the center you can see some Nordic and Baltic countries which have a strong digital identity culture. They have usually more than one national solution and some solutions have been widely adopted for more than 10 years.

Some other countries instead, on our left, have been actively working to develop and to promote the diffusion of their solutions. For example, in Italy, there has been a strong institutional push, a strong institutional endorsement in order to promote the adoption of the digital identity solutions.

Other countries instead are showing a more immature, let's say, evolution, a more immature state of advancement with the digital identity solutions which have been introduced just recently and therefore they are looking at the digital identity wallet as a big opportunity for providing their citizens with an overarching solution. We will see how this heterogeneity that Niccolo showed you right now is also evolving into a heterogeneous landscape while coming to digital identity wallet solutions. Here in this slide you can see different colors.

The countries with the green one are countries that have already a solution and may be distributed to citizens. The yellow one signals countries that are still developing their solutions, so they are in trial or under development solution. And the red ones are those countries that are still at the beginning of their journey towards the UDI deadline at the end of 2026.

So, let's evolve a little bit our analysis. Here you can see one of the different maps we will show you today. In dark blue, I think, or maybe you can see black, in dark blue color, you can see countries that are working in integrating existing solution and existing assets in digital identity system in their transition towards the wallet. In this cluster you can see Italy, but also France, Spain, Portugal, UK and many others in Europe. On the other hand, you can see in light blue the countries that are developing wallet solution ex novo.

So, they are starting quite from scratch. They are building a different timeline, different design choices, different constraints within the environment. And here you can see like Germany, Switzerland, Greece and all the West and East Europe and some Nordics and Baltic countries. But an important variable here is who is building these assets for countries and who is managing, who held the governance of this solution.

And as observatory, we defined five different strategies in the provision of digital identity wallet, ranging from the fairly public one, so the solution is developed internal to the government, like Portugal has done with the gov.pt wallet, all the way to a fully private solution. Think, for example, the big tech wallet that we all have in our pocket.

So, solutions that are developed and owned and managed by private companies. In the middle you can see different approaches that combine different strategies, the publicly baked solution, like the Italian one, where the government gives the mandate to a public company to develop the first IT wallet for Italy. The public procurement in the middle, where you can see countries that give a mandate to private companies to develop the solution and the certified private solution that is developed by private companies that could be later certified and notified within a shared regulatory framework.

Please note that in this case there is no right answer, so all those approaches are viable, all those approaches are valid, and we will see spread all around Europe and each one comes with its compromise between public governance and private speed of innovation, for example. And we will see in a few minutes. So this is another map. The important thing is that when we color the different European countries with this legend, with these approaches about the provision of digital identity wallet solutions, we found that almost all countries in Europe are working starting from a public solution.

So the dark blue countries you can see are developing a fairly public or public baked solution. Here you can find Italy, Spain, Portugal, the Nordic countries and so on. The light blue countries on the other end are relying on public procurement, so they are giving mandate to private companies to develop solution within the regulatory framework. And here you can find France, Germany, for example, with the Sprint consortium, the Sprint initiative. Let's complicate a little bit, because this is the backbone.

What we show you here is the backbone of the public solution, but many countries are also open this market to private solution. So here you can see red in this pattern, countries that are opening this UDI wallet ecosystem also to private companies that want to develop assets in this market. And here you can see some Nordic countries, but also Italy, because the ET wallet ecosystem would be also a comprehensive one, talking also to private companies, but also Germany. As you can see, the Sprint initiative is always going in this direction. Let's complicate a little bit more.

This is an original clusterization that the observatory did in the last few months. So we collected some information publicly available from secondary sources, as Niccolo told you before.

So please, if you have some updated information, please come to us so we will update our research. So the variables that we considered in this classification are basically those two. From one end, ecosystem development, asking how thriving, how different are the use cases that the member state is developing, starting with only the PID issuance. The level two, integrating also at least three attestation of a sandbox to develop them. And level three, that also add the active involvement of reliant parties. So those are three different steps in the ecosystem development stage.

And on the other end, the solution development from a technical point of view. So how far is the member state in developing and also distributing those solutions to citizens? Ranging from no app available for citizens to a different number of functionalities according to the implementing act of OBI-2.

Like, as you can see in this slide, the proximity, representation proximity, pseudonym, transaction logs, and so on. So here, this is the solution. And now we will build these step by step. The matrix you see here and different clusters of countries results from them. Starting with the first one that you will not see because it is white as all the others. So we will see them, you will find listed here in the slide, but we will see them at the end when we will have colored all the others. So a little bit of suspense before lunch.

And like Albania, Bosnia, Denmark, Estonia, Lithuania, Kosovo, and so on. Starting with the second cluster. So the first cluster was yet to begin. So those countries were solutions to develop, not so ready, not available, and an ecosystem that is still to begin involvement. The second cluster is the behind cluster. So here you can find those countries that have either a solution under development, but an ecosystem to build, or an emergent ecosystem. They are already trying to work about use case and attestation, but a solution to develop technically.

And here you can find Germany or Spain and Czech Republic in different combination of the matrix. The third cluster is the on track cluster. And here you can find Austria, Italy, Belgium, Slovakia, Slovenia, Iceland. So those are countries kind of in the middle. They have either a solution ready and an ancient ecosystem, or they have a solution under development and an ecosystem in the initial phase of development, an emergent ecosystem. So this flourishing ecosystem and solution to develop is not feasible right now. The other cluster is the ahead cluster.

So those countries that are already closer to the deadline of December 2026. And here you can find France, Ukraine, Greece, Moldova. So those countries have a solution ready, either a solution ready and an emergent ecosystem. They are trying to develop attestation and to involve relying parties, and a solution under development and a flourishing ecosystem. So they have already worked on the relying party side and they are building the technical part. Last cluster, the exclusive club. We found Poland and Portugal. They are the best of the class, we can say. They are ready in this classification.

So please note that ready does not mean already certified UDI wallet. The journey in the certification of the wallet is still complicated. But from these two variables point of view, those countries are ready in this matrix. So the question is, in the next month, who will be joining this club? And we will see with the updates of this research.

So the key message that we can take home from this presentation, with the revision of EI-2 and the deadlines of December 2026, European governments and member states have begun a transition from the traditional existing digital identity system toward a solution of digital identity wallet. And we have seen different strategies because member states are developing them and capitalizing past investments and assets that are already being used by the population in those countries. Others are creating ex-novo solutions, ex-novo wallets almost from scratch.

Countries are adopting different approaches in the provision. So who is involved in developing the wallet? Some countries are favoring a prominent governmental role, so maintaining this project in public hands. And others are involving private sectors. And in some cases, those solutions, those approaches are overlapping together. And last but not least, while some countries are focusing on the ecosystem side, involving online parties, developing attestation and so on, some others are prioritizing the development from a technical point of view.

So the heterogeneity that Niccolo showed you before about digital identity system is also reflecting in these days, right now, even if this is an always evolving landscape day to day in meeting the EI-2 timeline. So just to conclude, as I mentioned before, one of the mission of the observatory is to share knowledge. So this QR code, you can find the page with all our reports, international reports available for free. Some of them are related to this research that we presented you today, but some others are relating to the census of digital identity wallets, EI-2 compliance or not.

Some others to the user perspective. So how different clusters of users are all around Europe, comparison between different member states. So please feel free to download them, but also to come back to us to share your impression or suggestion. And Niccolo, for the last but not least, communication. Before concluding, since we are running out of time, as Clarissa was mentioning before, what we have seen today is just a snapshot of the current situation. We don't know yet how the map we have seen will evolve in the next months.

So for the first year, we as observatory will have an international conference. It will be the 3rd of February in 2027, both hybrid, so both in presence and online. During the event, you'll be able to listen to international speakers and also to see which countries actually managed to respect the EI-2 deadline. So if you are interested in attending, please scan the QR code. It's a really quick form where we ask you to leave your email so that we can contact you. Thank you so much. So one quick question before we wrap it up and go get lunch. I can see that some of you are hungry.

So the question is, it's an online question. From your point of view, what are the advantages and disadvantages of having so many nation-specific solutions?

Yeah, that's an interesting point because our research about the user side highlights some cultural substrate where this solution, this digital culture, because we must not forget that digital identity is part of a broader digital culture of the countries, of the governments, but also of the society. So we should not mention that this solution should be adopted and should be aligned to the expectation of different countries. And having a fragmented landscape, yeah, it is a compromise. It is a compromise.

Some countries can have solutions that better align with user needs, maybe integrating some systems with which the users are already familiar in the previous year. And some others could also develop some sector-specific wallets, some sector-specific solutions. So the price of fragmentation is balanced by different benefits about fostering user adoption in this case, in our opinion. Thank you very much. Thank you. Thank you.