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Dock Labs maps where the EUDI Wallet market begins

Understanding the boundary between government identity and private services is key to entering the EUDI Wallet market
Dock Labs maps where the EUDI Wallet market begins
 

It’s going to change the world. That’s the verdict of Dock Lab’s Richard Esplin, as he and colleague Agne Caunt looked at “what actually matters” when it comes to the EU Digital Identity Wallet.

In a webinar focused on practical steps, the two acknowledged the growing need for guidance on mobile driver’s licenses (mDLs) and the European Digital ID (EUDI) framework. It will change the lives of EU citizens and residents for one.

From 2027 every member state will offer a free digital wallet that’s interoperable across all 27 member states. These must be accepted in regulated sectors like banks and telecoms. This has significant implications for non-EU member UK if UK businesses are operating or trading in the EU, for example, as Signicat has drawn attention to.

What interested parties don’t need to worry about, or that which is currently outside the EUDI governance framework, are unregulated Electronic Attestation of Attributes (EAA). These could be credential exchange, monetization of credentials, selective disclosure and Zero Knowledge sharing with private ecosystem entities. Private wallets can be built by anyone, for instance, using the same standards, but cannot carry a personal identity document (PID).

Caunt highlighted the Truvera platform and Truvera Wallets which can do Qualified Electronic Attestation of Attributes (QEAA). A question came up during the webinar: Why would you want a private wallet? To be able to issue additional credentials, that was one reason given, while another is to be able to offer a different user experience, as EU-state wallets will have much narrower user experiences.

The EU has by no means figured everything out yet. A list of things still being worked on includes the wallet certification scheme, with the ENISA draft in public review; the relying party registration process, which varies by member state; cross-border interoperability, for issue keys and revocation; and the role of intermediaries, which may vary by member state. The first set of technical specifications for the EUDI Wallet have been completed.

Clarifying wallet developer participation

In terms of practicalities, vendors can maintain clarity by knowing where the state stops and where the market starts. Governments are in control of legal identity, PID, and only notified, certified wallets can hold it. But all else is open to the market, to different degrees. Any organization that becomes, or partners with, a qualified trust service provider (QTSP) can do QEAAs, although it’s heavily regulated. Non-qualified EAAs are open to any organization as are private wallets.

Organizations have three ways to participate: relying party, issuer, wallet provider. They could do just one or more. Each of these have their own pathways. For relying parties, registration or using an intermediary to do so is crucial, and there will be tests against a pilot or sandbox wallet among the steps.

Issuer pathways split into two, with non-qualified EAA, or QEAA or partnership with a QTSP. There is a trade off here related to regulatory burdens. Official state wallet providers have the heaviest regulatory burden but private wallets far less so since they cannot carry PID. But different states can have different rules. For example, private wallet providers have specific legal considerations in Italy. Member states vary in their development status of the EUDI Wallet with eIDeasy providing a handy snapshot of where they are.

Later in the webinar, Dock Labs went into payment models, which Caunt said they receive a lot of questions on. A standardized monetization model does not exist in the regulation itself but commercial models are under development across sectors. As 2027 draws ever nearer, much is yet to crystallize but having a clearer idea of where the boundaries are should be useful, as the webinar affirmed.

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