eIDAS 2 and the European Digital Identity Wallet: what changes on December 24, 2026

Regulation (EU) 2024/1183, known as eIDAS 2, amends the 2014 eIDAS Regulation. It entered into force in May 2024. Its Article 5a requires each Member State to provide at least one European Digital Identity Wallet within twenty-four months of the entry into force of its implementing acts.

The text therefore does not state a date. It follows from the first implementing acts, published in the Official Journal of the European Union on December 4, 2024 and in force twenty days later. The period thus runs until December 24, 2026.

The wallet is a means of digital identification for natural and legal persons. It must allow access to public and private services across the Union while keeping control of one’s data. It can be provided directly by a State, under a mandate from a State, or independently with that State’s recognition.

Its use is voluntary. Article 5a specifies that people who do not use it must be neither restricted nor disadvantaged in accessing services. A company therefore cannot treat it as the only identification path to offer.

The obligation applies to certain private relying parties, under Article 5f. It requires that Union law, national law or a contractual obligation impose on them strong user authentication or identification for online identification. The text cites in particular these areas:

• transport and energy
• banking and financial services
• social security and health
• drinking water and postal services
• digital infrastructure, education and telecommunications

These companies must accept the wallet no later than thirty-six months after the entry into force of the implementing acts, that is, by December 24, 2027, and only at the user’s voluntary request. Micro and small enterprises are excluded. Very large online platforms have a separate obligation when they require authentication.

The first question to ask is therefore simple: does your company currently require strong authentication from its customers or users because a law or a contract obliges it to? If so, this topic concerns your online journeys, and it deserves a place on your 2027 roadmap.

The wallet can be used to sign. It must allow its users to sign with a qualified electronic signature. This use is free of charge for natural persons for non-professional purposes, and Member States may provide for proportionate measures to limit this free use to those purposes. A company should therefore not conclude that signing its contracts will become free.

The substantive rules are not overturned. eIDAS 2 deletes paragraph 3 of Article 25 of the 2014 Regulation, and a new Article 24a addresses the recognition of qualified signatures in all Member States. The first two paragraphs of Article 25 remain: an electronic signature cannot be denied legal effect solely because it is in electronic form, and a qualified signature has the legal effect of a handwritten signature.

No general obligation to use qualified signatures. Nothing in this timeline requires all contracts to be signed at this level. The choice still depends on the contract, the risk, the requirements of a specific law and the evidence you want to be able to produce.

The wallet will arrive gradually, and market practices will take time to settle. A few checks remain useful today, without waiting for its rollout:

• Map your signatures. Which contracts are signed, by whom, at what signature level, and with which provider?
• Set a rule per contract type. A written policy avoids deciding the signature level case by case, just before sending.
• Review your evidence agreements. Check that your contracts correctly describe the signature method used.
• Check retention. The signed contract and its evidence must be retrievable on the day they are needed.
• Ask your providers. Ask your e-signature provider whether it plans to support the wallet, and by when.

The December 24, 2026 date sets an obligation, not actual availability in each country. The timeline and real-world use will depend on the wallet each State makes available. Before changing a signature journey, check the status of the French scheme with official sources.

For a company, the most useful step remains knowing where its own contracts stand. A signature only has practical value if the signed contract, its version and its evidence can be found quickly.

Docform offers an e-signature compliant with the eIDAS framework: invited signers authenticate with a one-time code sent by email, an evidence file is compiled, and a Certigna electronic seal can be applied to the final PDF. Docform does not provide qualified signatures. The signed PDF and its evidence file are stored in the contract repository, with the contract.