Diia architect warns against treating EUDI Wallet as another infrastructure project

The European Digital Identity (EUDI) Wallet promises to transform how EU citizens interact with both the state and private companies. But long before a pan-European digital identity was on the table, forward-thinking projects like Ukraine’s Diia were already leading the way.

Used by 23 million Ukrainians, Diia has achieved what many believe the EUDI Wallet should aspire to: becoming completely invisible.

“Nobody actually wakes up in the morning dreaming about digital identity and how to quickly receive this digital identity,” says Liudmyla Rabchynska, Ukraine’s former deputy minister for Digital Transformation. “That’s why all of these state services had to be super invisible and super quick.”

Rabchynska spent three years at the heart of Diia’s development and rollout as part of President Volodymyr Zelensky’s cabinet. The digital trust expert has since brought her decade of experience to German firm IDnow, which she joined as Director of Global Regulatory & Government Affairs in February.

Speaking to Biometric Update, Rabchynska warned that European countries developing the EUDI Wallet are taking a far less streamlined approach than Ukraine did.

“I see the risk that governments of member states continue to treat it like another infrastructural product and not see it as an instrument that should relieve the lives of citizens,” says Rabchynska.

Assuming users will simply flock to a digital ID wallet because it appears in app stores would be a “big mistake,” she adds. Governments must first build trust — and make the service convenient enough that people actually want to use it.

Amazon as inspiration

Rabchynska credits Diia’s success to a rethink of how citizens relate to the state. Its architects drew inspiration from e-commerce giant Amazon and the idea of users receiving a service in one click.

“We were not trying to digitize bureaucracy,”  says Rabchynska. “We were trying to make bureaucracy invisible, disappear from the user’s life, which is much harder.”

​Rather than imposing a single top-down law on electronic services, Ukraine took a horizontal approach to the country’s entire regulation. The state faced the formidable task of digitizing more than 700 public services and 300 state registries, and coordinating across multiple state-level authorities. Simultaneously, it had to navigate an administrative reform that reduced its 2,000 municipalities to around 490.

​Today, many young Ukrainians do not even remember that accessing public services required submitting paperwork and visiting public administration offices, notes Rabchynska.

The app has continued to play an outsized role in the country even during its darkest times: The Brookings Institute notes that Diia has made a major contribution to the country’s resilience amid the war in Ukraine, with economic and anti-corruption impact valued in millions.

Private sector needs to be proactive

The success of the EUDI Wallet project will also depend on how closely the private sector collaborates with governments. Rabchynska offered recommendations for navigating that relationship — and for keeping up with the sweeping regulatory changes currently reshaping the EU landscape.

Companies will need to monitor developments such as eIDAS 2.0, the Anti-Money Laundering framework, the Cyber Resilience Act, the AI Act, Cloud and AI Development Act (CADA), and more. Technology developers also need to build go-to-market strategies that anticipate future requirements, such as sovereign cloud mandates and country-specific regulations, rather than scrambling to adapt after the fact.

​“Monitoring is very important,” says Rabchynska. “A lot of different changes are coming, and the bad news is that we are not expecting that in the near future it will stop.”

​Although governments are driven by different interests than private companies, including the protection of citizen data, the private sector has a role in proposing more effective mechanisms in the domain. IDNow has been collaborating with government bodies across member states, as well as EU agencies and standardization bodies.

“Companies should be more proactive to articulate their interests […] and build this trust relationship with public sector bodies like a reliable expert that has very important domain expertise,” says Rabchynska.

Article Topics

digital ID infrastructure  |  digital wallets  |  Diia  |  EU Digital Identity Wallet  |  Ukraine