| Dokumendiregister | Justiitsministeerium |
| Viit | 7-1/9637 |
| Registreeritud | 28.11.2025 |
| Sünkroonitud | 01.12.2025 |
| Liik | Sissetulev kiri |
| Funktsioon | 7 EL otsustusprotsessis osalemine ja rahvusvaheline koostöö |
| Sari | 7-1 EL institutsioonide otsustusprotsessidega seotud dokumendid (eelnõud, töögruppide materjalid, õigustiku ülevõtmise tähtajad) (Arhiiviväärtuslik) |
| Toimik | 7-1/2025 |
| Juurdepääsupiirang | Avalik |
| Juurdepääsupiirang | |
| Adressaat | Riigikantselei |
| Saabumis/saatmisviis | Riigikantselei |
| Vastutaja | Kristiina Krause (Justiits- ja Digiministeerium, Kantsleri vastutusvaldkond, Üldosakond, Kommunikatsiooni ja väliskoostöö talitus) |
| Originaal | Ava uues aknas |
EN EN
EUROPEAN COMMISSION
Brussels, 19.11.2025
COM(2025) 838 final
2025/0358 (COD)
Proposal for a
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
on the establishment of European Business Wallets
{SWD(2025) 837 final}
EN 1 EN
EXPLANATORY MEMORANDUM
1. CONTEXT OF THE PROPOSAL
• Reasons for and objectives of the proposal
This explanatory memorandum accompanies the proposal for a Regulation on the
establishment of European Business Wallets. The legal instrument aims to provide a
harmonised, trusted, and user-friendly digital framework for economic operators and public
sector bodies to securely identify, authenticate and exchange data with full legal effect across
EU borders.
Recent technological and societal developments require a new harmonised and digital
approach to business-to-government and business-to-business interactions. AI, cloud
computing and secure digital identity are moving at an unprecedented pace, affecting the way
of doing business in Europe: processes have shifted from being document-based to automated
and data-driven. For instance, 91% of scaleups consider digital technologies critical to their
growth. These developments, combined with the EU’s strategic priorities for competitiveness,
digital sovereignty, simplification and digital-by-default public services, create the need for
agile solutions that can support trusted cross-border business transactions at scale.
The Draghi and Letta reports have warned that persistence of administrative burdens, and
fragmentation of the Single Market significantly weaken Europe’s competitiveness,
discourage EU firms from scaling up, and increase dependence on high-risk providers. Yet the
digital infrastructure available to public sector bodies and economic operators remains
fragmented and, compliance and reporting obligations complex: most stakeholders consulted,
highlighted the lack of cross-border interoperability as a major source for red tape. Across the
Union, public authorities still operate within heterogeneous digital environments that limit the
full realisation of cross-border public services: the eGovernment Benchmark 2024 shows that
while 88 % of public services are available online to national users, cross-border users can
access only 56 % of those services digitally and interoperability barriers remain among the
top obstacles to efficient e-government. For economic operators active in multiple Member
States ensuring smooth transaction, such as tax registration, licensing or procurement
applications, is key to remain competitive.
The practical consequences of the status quo are burdensome. Stakeholders reported for
example, employing two full-time staff solely for sustainability reporting obligations, or
incurring costs exceeding €100,000 for specialised consultancy in this area. Also, economic
operators estimate that around 20% of staff time is absorbed by compliance-related activities.
In cross-border contexts, this often requires manual or paper-based verification that delay
transactions and multiply administrative costs. These costs are disproportionate especially for
SMEs, where compliance obligations divert significant resources from strategic high-value
activities: the European Investment Bank estimates that regulatory compliance consumes
1.8% of turnover for firms overall and 2.5% for smaller companies. Know-Your-Customer
procedures in the financial sector alone can take 30 to 50 days per corporate client, with each
dossier requiring dozens of hours of manual processing.
For public sector bodies, structural barriers prevent the full transition to modern, digital, and
accessible services and the creation of a seamless EU administrative space. Although the
digitalisation of public services is showing signs of increased maturity, it will not, at current
rates, reach the target set in the Europe’s Digital Decade Report of having 100% of public
services online by 2030. This scenario limits scalability, raises administrative costs, and slows
EN 2 EN
down service delivery. Digitising interactions means more efficient administrative procedures,
better service delivery and opportunities for requalification of public resources to more
strategic tasks. Evidence shows that digitalisation in the public sector can make
administrations more effective, either by expanding services without additional budget or by
redeploying human resources towards higher-value activities.
The absence of a trusted, standardised channel for business-to-government and business-to-
business interaction allowing to exchange attributes undermines traceability and security.
Credentials are often shared via email or proprietary portals, which offer limited guarantees of
authenticity, increasing exposure to fraudulent practices, such as invoice scams, which
already generate over €26 million annually in illicit profits, according to Europol and EUIPO.
Thus, while privacy and minimal disclosure are essential for natural persons, businesses
require transparency and traceability of exchanges to support risk management, compliance
and fraud prevention. The EU has already achieved a major milestone in its simplification
agenda with the European Digital Identity Framework - a state-of-the-art, privacy-friendly
and interoperable system for digital identification empowering citizens and legal entities to
share data securely across borders. The European Business Wallets proposal aims at
complementing the European Digital Identity Wallets by introducing a market-driven digital
tool designed for the specific needs of business transactions.
The current drive for simplification and digitalisation is anchored in the Union’s political
agenda. The EU’s Strategic Agenda 2024–2029, the European Council conclusions and the
Commission’s Competitiveness Compass all underline the urgency of reducing administrative
burdens, with explicit targets of a 25% reduction in overall burdens and 35% for SMEs. The
Draghi and Letta reports identify fragmentation and administrative complexity as major
obstacles to Europe’s competitiveness, while President von der Leyen’s 2025 State of the
Union made clear that internal barriers continue to hinder economic operators more than
external ones. In March and June 2025, the European Council reaffirmed the need for
“simplicity by design,” and in early 2025 the Commission explicitly identified the
establishment of European Business Wallets as a cornerstone of a simpler and faster Europe.
Against this economic and political background, the European Business Wallets proposal
delivers on the simplification demand by achieving the following specific objectives:
– Reduce administrative burdens, streamline compliance processes, and improve
service delivery
– Ensure economic operators and public sector bodies have access to secure and
trusted digital identification across borders, meeting user needs and demand
• Consistency with existing policy provisions in the policy area
The European Business Wallets proposal builds on and extends the ecosystem established
under the European Digital Identity Framework (EUDI) - Regulation (EU) 910/2014 on
electronic identification and trust services for electronic transactions in the internal market, as
amended by Regulation (EU) 2024/1183. The European Business Wallets aim to complement
the EUDI Framework by offering functionalities tailored to the needs of public sector bodies
and economic operators, including the digital management of representation rights and
mandates, and a secure channel for exchanging official documents and attestations supported
by a common directory. Full interoperability with the European Digital Identity Wallets will
be guaranteed.
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The proposal is complementary to the EU company law acquis and uses the existing European
Unique Identifier which all limited liability companies and commercial partnerships (as well
as the future 28th regime companies) have in accordance with EU company law. In addition,
the proposal is compatible with the Business Registers Interconnection System (BRIS),
developed in accordance with the codified Company Law Directive (EU) 2017/1132. Finally,
the proposal is also in line with Beneficial Ownership Registers Interconnection System
(BORIS), developed in accordance with the Anti-Money Laundering Directive (EU)
2015/849. These interconnections use the European Unique Identifier (EUID) to uniquely
identify companies and other legal entities, and legal arrangements in the EU, but do not
cover all economic operators or public sector bodies, such as sole traders, self-employed or
public institutions. The European Business Wallets extend this ecosystem by offering a
trusted and interoperable mean for all these entities.
• Consistency with other Union policies
This proposal is embedded in the Union’s wider policy agenda to boost competitiveness,
reduce administrative burdens and deliver a digitally integrated Single Market. It contributes
directly to the goals set out in the Commission’s Single Market Strategy which calls for more
effective digitalisation in the EU to enable the optimal functioning of the Single Market as
well as to the EU Strategic Agenda 2024–2029, the Competitiveness Compass, the SME
Strategy for a sustainable and digital Europe, and the Digital Decade Policy Programme. All
of which highlight the need for simplification, interoperability and digital-by-default public
services. The European Business Wallets proposal deliver on these strategic priorities by
offering a concrete instrument to make compliance and cross-border interactions simpler,
faster and more reliable for economic operators and public sector bodies.
Furthermore, the proposal ensures complementarity with key legislative initiatives as follows:
– The Single Digital Gateway (SDG) and its Once-Only Technical System (OOTS)
implement the “once-only” principle, requiring authorities to reuse data already held
in another Member State without repeated submissions by businesses. The European
Business Wallets proposal will complement the SDG and OOTS by providing trusted
identification and authentication of economic operators and public administrations
and a secure exchange layer that enables businesses and public sector bodies to share
and reuse verified data and official attestations seamlessly across borders.
– The Digital Product Passport (DPP), central to the EU’s circular economy agenda,
depends on trusted access to conformity and sustainability data. The Business
Wallets proposal can prove legal identity and any granted access rights, allow
conformity declarations to be signed and sealed, and ensure product data is
exchanged securely and verifiably across borders.
– The Interoperable Europe Act (IEA) establishes the framework for cross-border
interoperability of public services. The Business Wallets proposal will complement
this by serving as a trusted infrastructure that administrations can integrate into
digital-by-default service delivery, reinforcing the removal of technical and
organisational barriers.
– The upcoming proposal on the 28th Regime corporate legal framework will provide
simple, flexible and fast procedures for companies to set up and operate and attract
investment in the EU through digital solutions. It will ensure that digital tools such
as the EU Company certificate and the EU digital Power of Attorney can be used in
the European Business Wallets.
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– The VAT in the Digital Age (ViDA) package modernises VAT reporting, introduces
mandatory e-invoicing across borders and strengthens fraud prevention. The
Business Wallets proposal will enable secure storage and verifiable exchange of
VAT attestations and transaction data, thereby supporting real-time reporting and
trusted invoicing.
2. LEGAL BASIS, SUBSIDIARITY AND PROPORTIONALITY
• Legal basis
The legal basis for the proposal is Article 114 of the Treaty on the Functioning of the
European Union (TFEU), which provides for the adoption of measures at EU level to ensure
the proper functioning of the internal market. Secure identification, trust services, and
seamless exchange of verifiable electronic attestations are essential for economic operators
and public sector bodies to participate effectively in the Single Market.
The functioning of the internal market relies on uniform and consistent rules applied across all
relevant public sectors bodies performing equivalent functions or providing comparable
services. European Union institutions, agencies, offices and bodies (Union entities) often
carry out similar activities to national public sector bodies and have key supervisory and
regulatory roles. Thus, their involvement in supporting the proper functioning of the Single
Market is necessary. Excluding them would create regulatory gaps, fragmentation and uneven
application of the rules, thereby undermining the Business Wallet’s objective of safeguarding
the integrity, stability and resilience of the internal market. In addition, simplification remains
a key driver of the EU’s commitment to building a bolder, simpler, and faster Union. A
competitive and well-functioning Single Market requires active participation from both
national and EU-level authorities, with the latter leading by example. Accordingly, Union
entities should adopt and use the European Business Wallet, extending simplification and
efficiency to their interactions with economic operators.
The current disparities in the way Member States identify economic operators, verify
mandates and exchange official data and documentation in digital form may pose risks of
obstacles to fundamental freedoms or cause significant distortions of competition. By
providing a harmonised solution for secure business identification and data exchange, the
European Business Wallets proposal aim to remove administrative barriers, prevent further
divergences, and ensure that all economic operators can compete on a level playing field
within the EU.
• Subsidiarity (for non-exclusive competence)
Economic operators and public sector bodies across the Union should be able to rely on
highly secure and trustworthy digital identity solutions, including the portability of electronic
attestations of attributes that can be used across the Single Market in a user-friendly and
efficient manner. These needs cannot be sufficiently met by Member States acting
individually, as national solutions remain fragmented in scope, effect and technical design.
Hence, action at EU level is necessary to ensure that all public authorities, both national and
European, recognise and apply the same interoperable solutions when interacting with
economic operators. This guarantees a coherent regulatory environment and avoids parallel
procedures or incompatible systems that would be contrary to the objectives of simplification
and optimal functioning of the internal market. Obstacles to the freedom of establishment and
EN 5 EN
the freedom to provide services arise because credentials issued digitally in one Member State
cannot always be reused or relied upon in another.
In addition, distortions of competition occur when operators face unequal conditions
depending only on their place of establishment. In Member States where procedures are fully
digitalised, companies can register for VAT or provide attestations within days at low cost,
while in less digitalised domestic environments, the same process may require courier
services, or lengthy manual checks, taking weeks and diverting staff from productive
activities. The eGovernment Benchmark 2024 reveals substantial differences across Member
States in the digital availability and usability of key public services: the average overall score
of the 10 top-performers within the EU27 is 87 points, compared to 64 points for the 10
bottom-performers - a gap that highlights persistent disparities in the digitalisation of EU
public services. These disparities translate into different compliance costs of digitalisation
disproportionately harm SMEs and micro-enterprises, weakening their ability to compete in
the Single Market and limiting their participation in economic opportunities such as public
procurement.
EU-level intervention is the most efficient way to restore a level playing field: a common,
harmonised framework ensures that all economic operators, regardless of size or location, can
rely on a single tool to interact with public authorities and partners across the Union. By
removing administrative barriers and creating uniform conditions, the European Business
Wallets proposal strengthens legal certainty, trust and competitiveness.
Regarding added value, the European Business Wallets will eliminate duplication and lower
compliance costs, enhance data quality and transparency, and provide public sector bodies
with more reliable information, thereby improving service delivery. For economic operators,
particularly SMEs, this means that the time and resources saved can be redirected to
innovation, growth and international expansion. At the same time, EU-level harmonisation
prevents dependency on high-risk providers, strengthens the resilience of critical
infrastructures, and consolidates the Union’s digital sovereignty. Beyond the internal market,
the initiative can also enhance the Union’s role as a global standard-setter for trusted digital
infrastructures, supporting European competitiveness in international trade.
• Proportionality
This initiative is proportionate to the objectives sought, as it limits obligations to what is
strictly necessary to ensure a secure, harmonised and interoperable framework for digital
interactions between economic operators and public sector bodies. The European Business
Wallets do not prescribe a single rigid business model or technical design but rather set a
framework that combines interoperability with flexibility, fostering competition and
innovation.
Furthermore, obligations for public sector bodies are balanced by transitional arrangements:
flexible implementation periods allow public sector bodies sufficient time to adapt their
administrative and IT systems and preventing disruption. The proposal does not create new
administrative procedures that must be completed by economic operators or public sector
bodies. It instead provides a common, trusted channel for fulfilling obligations that already
exist under Union law. Being sector-agnostic in nature, the initiative does not touch upon the
content of current obligations and simply provides a mean to simplify compliance with
European and national existing rules, while helping overcoming fragmentation and treatment
disparities across the Single Market.
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The costs of adoption and maintenance will be sustained by economic operators and public
sector bodies. In particular these relate to onboarding, training and IT adaptation. However,
these costs are outweighed by efficiency gains from simplified processes, reduced duplication,
and greater legal certainty. Moreover, training costs, that constitute the most substantial one-
off costs, could be partly supported by existing Union initiatives for digital transformation and
capacity-building, which can help alleviate training and adaptation costs.
The proposal is also proportionate in terms of its expected impact on economic operators. It
also uses the existing European Unique Identifier (EUID) which avoids extra costs for 18
million companies. SMEs and micro-enterprises, which face the greatest relative burden from
administrative complexity in terms of both costs and staff time, are expected to benefit the
most from the simplification and efficiency gains deriving from the use of European Business
Wallets. This is fully consistent with the EU’s political priorities, including the EU Start-up
and Scale-up Strategy, the upcoming 28th regime and the recommendations of the Draghi
Report, which emphasise the need to reduce red tape and administrative barriers as a
prerequisite for SMEs competitiveness and growth.
Notably, the proposal does not impose any obligation on economic operators. It requires
public sector bodies to enable the use of European Business Wallets for specified
functionalities, ensuring that economic operators like small and medium enterprises have the
choice to adopt the Business Wallets and to benefit from simplified procedures. This approach
aligns with the “Think Small First” principle by avoiding unnecessary regulatory pressure on
SMEs. Self-employed individuals and sole traders may also rely on their European Digital
Identity Wallets to access trust services offered for the European Business Wallets, including
the secure communication channel or e-signatures, without the need to acquire a fully-fledged
Business Wallet. This ensures proportionate treatment of smaller operators by preventing the
imposition of an undue burden.
Finally, the initiative is also proportionate in its regulatory design, as it relies on ex post
supervision by the specified supervisory bodies and a notification procedure rather than prior
authorisation. This approach ensures effective oversight and accountability of providers
without introducing unnecessary administrative delays or costs, while maintaining a high
level of trust and security.
Taken together, these elements show that the proposal respects the principle of
proportionality. By combining a clear common framework with flexibility for innovation, it
delivers in the most efficient way on addressing pressing needs of both economic operators
and public sector bodies.
• Choice of the instrument
The choice of a regulation as the legal instrument is justified by the need to ensure a uniform
framework of application for the secure identification, authentication and the exchange of
attestations by economic operators and public sector bodies across the Single Market. Only
directly applicable rules can guarantee that the European Business Wallets operate seamlessly
throughout the Single Market and that their legal effects are recognised and applied equally in
all Member States, which is essential to safeguard the fundamental freedoms of establishment
and the provision of services, currently weakened by divergent national solutions and
fragmented procedures.
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The direct applicability of a regulation, in accordance with Article 288 TFEU, will prevent
further legal fragmentation and ensure that economic operators and public sector bodies can
rely on a common instrument with the same legal certainty across the Union.
In addition, in order to guarantee the consistent application of all related instruments and
taking into consideration that the EUDI Framework is itself established by a Regulation, the
present proposal should likewise take the same legal form.
3. RESULTS OF EX-POST EVALUATIONS, STAKEHOLDER
CONSULTATIONS AND IMPACT ASSESSMENTS
• Stakeholder consultations
Targeted consultations were undertaken specifically for the European Business Wallets,
reflecting their distinct focus on B2G and B2B interactions. A Call for Evidence ran between
May and June 2025 and received nearly one hundred contributions from companies, business
associations, registries, public authorities and citizens across 17 Member States and several
third countries. The Commission also carried out surveys, in-depth interviews and a series of
dedicated workshops with Member States, registries, SMEs, industry representatives and trust
service providers. The feedback was complemented by input from conferences and ad hoc
dialogues with stakeholders throughout 2025.
The consultation strategy focused on specific issues relevant to economic operators and public
sector bodies, including operational requirements, technical integrations, workflow
optimisations, and integration of reporting obligations, tailored to capture the technical and
practical realities faced by professional users.
Stakeholders highlighted that existing digital tools and channels for administrative activities
are highly fragmented, particularly for cross-border exchanges, leading to repetitive data
submissions and administrative burdens. Several administrative activities were described as
burdensome, particularly those involving document exchange, compliance, and verification
across Member States. These activities are often time-consuming, repetitive, and prone to
human error.
Respondents anticipated that the European Business Wallets could significantly reduce the
cost and complexity of administrative tasks. Benefits cited included faster services, improved
data accuracy, and enhanced cross-border operations. Many stakeholders expressed openness
to adopting a cloud-based solution like the European Business Wallets, especially if it
streamlines processes and reduces costs. However, concerns were raised about integration
challenges and the need for clear guidance and support. In addition, stakeholders identified
various use cases and cost-saving opportunities, including automating identity verification,
streamlining compliance processes, and enabling secure cross-border transactions. The
potential benefits were quantified in terms of time saved on administrative tasks and the
reduction of manual processes.
The consultation results highlighted the need for a harmonised approach to business identity,
representation, and regulatory compliance. Recommendations included the need for
technological neutrality, ensuring the Wallets are technologically neutral, flexible, and future
proof, relying on harmonised standards and protocols. Interoperability is crucial, with the
Wallets integrated with existing frameworks, such as the EU Digital Identity Wallet, to ensure
seamless cross-border operations. The Wallets should be based on sustainable, market-driven
models, with clear guidelines and support for adoption. Special attention should be given to
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SMEs, considering their challenges in adopting digital tools and the need for clear, actionable
use cases.
The stakeholder consultation strategy provided valuable insights into the needs, challenges,
and expectations of economic operators and public sector bodies regarding the European
Business Wallets. The findings informed the development of the regulation, ensuring that it
addresses the specific needs of professional users by: being technological neutral and future-
proof; enabling the secure retrieval of data from business registries and other authentic
sources, guaranteeing traceable interaction; allowing for a market-driven model and finally,
making the acceptance of the Business Wallets mandatory for public sector bodies to ensure
consistent and effective uptake across the EU.
The initiative also builds on the extensive public consultation carried out in 2021 in the
context of the revision of the eIDAS Regulation, which gathered broad feedback on digital
identity and trust services. The results of that consultation remain valid for understanding user
expectations regarding interoperability, legal certainty, cross-border usability, and trust.
Therefore, no open public consultation was held.
• Collection and use of expertise
In preparing this initiative, the Commission drew on external expertise. Beyond regular
exchanges with Member State experts, business registries and industry representatives, the
Commission contracted specialised consultancy firms to support the collection and analysis of
evidence. These contractors conducted targeted interviews and surveys with stakeholders,
gathered qualitative and quantitative feedback, and carried out a cost/benefit analysis for the
Staff Working Document. Their work was complemented by the Commission’s in-house
expertise.
• Staff Working Document
For this proposal a derogation from an impact assessment was granted as the European
Business Wallets build directly on the policy choice already assessed in 2021 for the
European Digital Identity Framework and adapts it to the specific context and needs of
economic operators and public sector bodies. The proposal therefore follows the 2021
preferred option, namely the establishment of a harmonised wallet framework with Union-
wide legal effect, customising it to professional interactions. However, a Staff Working
Document analysing in detail the expected costs and benefits of the proposal was prepared.
The document provides the intervention logic (problems, drivers and objectives), describes
the policy option, and quantifies economic impacts for both public sector bodies and
economic operators on the basis of mixed-method research including quantitative and
qualitative analysis of public sources, survey data and interview data combined with
secondary sources (full details on the methodology are provided in the Staff Working
Document).
To meet the objectives of simplification, administrative burden reduction and secure cross-
border digital interactions, the initiative requires all public sector bodies in the EU to accept
the European Business Wallets in their interaction with economic operators for the purpose of
the core minimum functionalities (identification/authentication; signing/sealing; submission
and receipt of documents and official notifications), which have legal effect equivalent to
paper or in-person processes across the EU. The instrument is technology-neutral and market-
driven: it does not prescribe a single design, leaves room for innovative features beyond the
common layer, and ensures interoperability with eIDAS trust services and authentic sources.
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The impacts of the policy option are outlined in detail in Annex 3 of the Staff Working
Document. The costs benefits analysis indicates that there are annual direct costs both for
economic operators and public sector bodies. They are divided in one-off costs for training
and onboarding, activation and IT implementation, contracting/procurement costs, and in
recurring costs for licensing fees and maintenance. Overall, when the Business Wallets reach
their full potential and the adoption rate, for both public sector bodies and economic
operators, would reach 100%, the total estimated costs and benefits could reach the following
figures:
Stakeholder No. in the
EU
Year 1 (€bn) Year 2 (€bn)
Benefits Costs Net
benefits Benefits Costs
Net
benefits
Public
sector
bodies
95,825 19.13 7.32 11.81 19.13 1.15 17.98
Economic
operators 32,721,957 205.82 60.67 145.15 205.82 27.23 178.59
Total 224.95 67.99 156.96 224.95 28.38 196.57
Among micro-enterprises, self-employed individuals and sole traders could use their EU
Digital Identity Wallets to access the newly introduced communication channel to interact
with the Business Wallet ecosystem, without purchasing the full Business Wallet. Based on
current market prices across the EU, the estimated annual recurring cost for this service is
around €45, suggesting that these operators could connect to the ecosystem at a relatively low
cost.
Importantly, the magnitude of the net benefits depends on the rate of usage of the European
Business Wallets by economic operators, and SMEs in particular - which represent the largest
share of economic operators. The higher the usage, the higher the resulting efficiency,
simplification and cost savings across the internal market. Several scenarios are considered in
the Staff Working Document: at lower adoption levels, the initiative already generates
measurable efficiency gains for economic operators, with public authorities reaching positive
returns shortly thereafter. As usage expands, both categories of stakeholders experience clear
net benefits, particularly SMEs and micro-enterprises, as network effects begin to take hold.
At higher rates of use, the European Business Wallets become a de facto standard for
business-to-government exchanges, with growing spill-over effects in business-to-business
contexts. (for a more detailed analysis, see Chapter 6 and, Annex 3 and 4 of the Staff Working
Document).
In addition, beyond direct savings, the initiative generates substantial indirect benefits for the
wider EU economy and society, articulated into three areas. The first area is economic
opportunities and market competitiveness. Reduced time spent on compliance frees resources
that can be redirected into innovation, and cross-border service expansion. By improving data
quality and transparency, the initiative also facilitates fraud reduction and optimisation of
internal processes. A second area is trust and resilience, where the European Business Wallets
are expected to increase trust in digital transactions, and to strengthen the EU’s cyber-
resilience and operational continuity, including during crises. A third area is environmental
sustainability, where gains are expected from the reduction of paper-based processes and the
facilitation of more efficient sustainability reporting.
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For public sector bodies, the European Business Wallets are expected to bring structural and
lasting improvements in administrative efficiency and service quality. By automating
verification, document handling and data exchange, the initiative reduces manual processing
and the risk of human error, accelerating decision-making and enhancing the reliability of
outcomes for citizens and companies. The consolidation of authentication and communication
systems into a harmonised EU framework strengthens cybersecurity and digital sovereignty,
allowing coordinated risk management and secure data flows. In parallel, the availability of a
traceable, standardised channel for information exchange streamlines regulatory supervision,
allowing authorities to rely on accurate, auditable data and to deploy innovative RegTech
solutions that improve oversight and compliance monitoring.
Together, these indirect benefits reinforce the EU’s competitiveness, strengthen trust in digital
infrastructures, and support broader policy objectives such as the Green Deal and the Digital
Decade.
• Regulatory fitness and simplification
This proposal establishes the European Business Wallets as a single, harmonised tool for
economic operators to identify, sign, store, submit and receive documents in their interactions
with public authorities. It will allow to replace fragmented national procedures with a secure
and interoperable solution, thereby removing administrative complexity and reducing
compliance costs.
For public sector bodies, it streamlines reporting and verification processes, enabling more
efficient supervision and record-keeping. For economic operators, in particular SMEs, it
eliminates duplicative procedures and disproportionate burdens. The latter stand to gain the
most, as they are disproportionately burdened by fragmented and duplicative administrative
procedures. Direct benefits are estimated at €4,000 per year at individual level for
microenterprises and €42,250 per year for larger SMEs, but the impact goes beyond cost
savings: simplified cross-border procedures will enable faster establishment abroad, easier
access to finance, and stronger participation in procurement markets. By ensuring legal
certainty and uniform application, the proposal promotes the free movement of goods and
services, while at the same time fosters innovation, allowing market-driven features
flourishing.
• Fundamental rights
While this legislative proposal primarily addresses legal persons, it indirectly supports the
protection of several fundamental rights enshrined in the Charter of Fundamental Rights of
the European Union. By providing a harmonised and trusted instrument for cross-border
business interactions, the initiative strengthens the freedom to conduct a business (Article 16)
by removing unnecessary barriers in the Single Market. It also facilitates the exercise of the
freedom to choose an occupation and right to engage in work (Article 15), as businesses and
professionals can expand their activities across borders more easily and at lower cost.
In their role as “gatekeepers” of administrative procedures within the Single Market, public
sector bodies will be enabled to offer more transparent and efficient procedures, thereby
indirectly reinforcing the right to good administration (Article 41). The European Business
Wallets also contribute to ensuring a high level of protection of personal data (Article 8) in
line with existing EU laws, in particular Regulation (EU) 2016/67. For example, the selective
disclosure feature, inspired by the European Digital Identity Framework, also serves as a
measure for the protection of personal data as users of the European Business Wallets are able
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to control the type and amount of data communicated to other European Business Wallets
owners and relying parties. In addition, when preparing the implementation of the European
Digital Directory, the relevant data protection principles and obligations, such as data
minimisation and data protection by design and by default, should be considered.
Finally, by increasing the accuracy and reliability of business credentials, the proposal
indirectly strengthens consumer protection (Article 38) and contributes to overall trust and
confidence in the Single Market dynamics.
4. BUDGETARY IMPLICATIONS
The inclusion of Union entities will have financial implications, which will be predominantly
covered by the EU budget under the Multiannual Financial Framework (MFF) 2028-2034.
These costs are mainly associated with the implementation and use of the European Business
Wallets by Union entities and the establishment and maintenance of the European Digital
Directory within the Commission.
A detailed overview of the costs involved is provided in the ‘financial statement’ linked to
this proposal.
5. OTHER ELEMENTS
• Implementation plans and monitoring, evaluation and reporting arrangements
The impact of the proposed Regulation will be monitored and evaluated in accordance with
the Better Regulation Guidelines, covering its implementation and application. The
monitoring arrangement constitutes an important part of the proposal. The Commission will
monitor its implementation with a view to generating the necessary and relevant information
that will feed into a future evaluation and to provide solid evidence for policymaking. In
particular the following aspects will be evaluated and monitored: 1) reduction of
administrative burden of regulatory compliance and reporting requirements on businesses
through demonstrable economic benefits; 2) improvement of public service delivery and 3)
enhancement of competitiveness thanks to the Business Wallets’ introduction.
Given the horizontal reach of this regulation and considering the extensive uses-cases that the
Business Wallets could support across various economic sectors, it will be important to ensure
the efficient and collaborative coordination of its implementation. To this end, a cross-
Commission interservice group chaired by DG CONNECT will be established.
On the application of the proposed instrument, the European Commission and the National
Competent Authorities will assess also: 1) development of a market for secure digital
identification and trust services between economic operators and public sector bodies; 3)
trustability and security of available solutions and their compliance with all requirements to
provide European Business Wallets and 3) adoption of the Business Wallets among different
sectors.
Four years following the adoption of the Regulation, the Commission will carry out an
evaluation to assess how effectively the European Business Wallets have met their objectives.
The evaluation will look in particular at the usability of the wallets’ minimum core
functionalities, the compliance level of wallets’ providers, the functioning of national
supervision and penalties, performance of the qualified electronic registered delivery services
and the use of Business Wallets and the qualified registered delivery service. Member States
EN 12 EN
will provide the Commission with the necessary data and evidence for this assessment (for an
in-depth analysis of the monitoring and evaluation aspect, see Chapter 9 of Staff Working
Document).
• Detailed explanation of the specific provisions of the proposal
Chapter I sets out the subject matter and scope of the proposal that applies to the provision
and acceptance of European Business Wallets. It also sets out the definitions used throughout
the instrument. The definition of the European Business Wallets is deliberately broad and
technologically neutral to allow flexibility for varying market-driven solutions and future
technological developments, a digital wallet that allows owners to store, manage, and share
verified identification data and electronic attestations of attributes, as well as to issue and
delegate mandates in a legally recognised manner.
Chapter II establishes the key components for the European Business Wallets framework. It
sets out the principle of legal equivalence, serving as a provision which equates actions
performed through a European Business Wallet to those carried out in person, on paper, or via
any other means or processes: an essential element to remove administrative frictions in
concerned exchanges. The principle of equivalence also applies to the use of the qualified
electronic registered delivery service by self-employed persons and sole traders. In the same
chapter, a minimum, interoperable set of core functionalities, together with qualified
electronic registered delivery service as a standalone service to users of European Digital
Identity Wallets, is defined alongside with technical requirements, further expanded in the
Annex and envisioned to be complemented by implementing acts. Provisions of this chapter
also address who can provide European Business Wallets, the relevant requirements that must
be met by such legal persons and the process that an eligible entity must undergo at national
level in order to be included in the trusted list of providers. To guarantee consistent cross-
border recognition, the proposal relies on European Business Wallets’ owners' identification
data issued as electronic attestations of attributes by qualified trust service providers, national
public sector bodies, or by the Commission for Union entities. Using these attestations
ensures that every Business Wallet owner can be reliably identified on the basis of official and
verifiable information. In addition, a unique identifier is attributed to each Business Wallet
owner. Where a European Unique Identifier is assigned under Company Law Directive (EU)
2017/1132 or the Anti-Money Laundering Directive, the Business Wallets will use the
European Unique Identifier as the unique identifier. In other cases, Member States designate
existing national registers and corresponding registration numbers as the authentic source for
generating an equivalent identifier. The structure and technical specifications of this identifier,
ensuring Union-wide uniqueness and interoperability, will be defined by implementing acts.
To enable a straightforward communication through the Business Wallets, the proposal also
establishes a European Digital Directory, which will be created and maintained by the
Commission, will enable economic operators and public sector bodies to be easily contacted,
while implementing adequate measures for the protection personal data. In this regard, the
Commission will establish standards, technical specifications and the categories of
information to be communicated to the Commission for the Directory through implementing
acts.
Chapter II also establishes the governance and supervision mechanism. To minimise
fragmentation and leverage existing expertise, the proposal names the existing eIDAS
supervisory bodies to act as the supervisory authorities in each Member State for Business
Wallets’ providers established in the respective territories. These authorities also assist
providers of Business Wallets in accessing the information needed for the issuance of owner
EN 13 EN
identification data by issuers of owner identification data based on information available from
authentic sources, cooperate closely with the competent authorities for qualified trust service
providers, and notify the Commission of the national registries holding data on economic
operators and public sector bodies. In this regard, the Regulation provides for the role and
tasks of such authorities. Given the Treaties’ institutional balance, EU institutions, bodies and
agencies (Union entity) are not subject to Member State supervision. The proposal rather
provides a Union-level supervisory arrangement under the Commission.
In Chapter III the obligations placed on public sector bodies are set out. These provisions
ensure that public sector bodies enable economic operators to use the European Business
Wallets for the purposes of identifying, authenticating, signing or sealing, submitting
documents, and sending or receiving notifications in administrative or reporting procedures.
For the exchange of documents and notifications, public sector bodies must themselves hold a
European Business Wallet and use the secure communication channel. The obligations have
to be met by set time frames. Public sector bodies may also recognise the use of European
Business Wallets and the communication channel (for sole traders and self-employed) as the
sole means for submitting electronic documents and attestations when required under Union
law. The Commission will review these obligations and their scope over time.
Chapter IV sets out the international dimension of the European Business Wallet framework,
establishing the possibility for the recognition of systems developed in third countries that
offer functionalities equivalent to the proposal where relevant conditions guarantee a
comparable level of trust, security, and interoperability. This approach allows the EU to
facilitate trusted global exchanges with non-EU partners while maintaining the Union’s high
standards for digital identity, authentication, and data integrity.
Chapter V contains the horizontal and closing provisions. It provides for the evaluation and
review of the proposed regulation to assess the effectiveness of its implementation and the
functioning of the supervisory framework.
EN 14 EN
2025/0358 (COD)
Proposal for a
REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL
on the establishment of European Business Wallets
THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,
Having regard to the Treaty on the Functioning of the European Union, and in particular
Article 114 thereof,
Having regard to the proposal from the European Commission,
After transmission of the draft legislative act to the national parliaments,
Having regard to the opinion of the European Economic and Social Committee(1) ,
Acting in accordance with the ordinary legislative procedure,
Whereas:
(1) In its Communication of 29 January 2025 ‘A Competitiveness Compass for the EU’(2)
the Commission announced that European Business Wallets, building on the European
Digital Identity Framework, will constitute the cornerstone for conducting business in
a simple and digital manner within the Union, providing companies with a seamless
environment in which to interact with public administrations.
(2) Regulation (EU) No 910/2014 of the European Parliament and of the Council(3)
establishes the European Digital Identity Framework and introduces the European
Digital Identity Wallets, enabling users to securely store and manage their digital
identity and electronic attestations of attributes, and to access a wide range of online
services. The European Digital Identity Framework features new trust services,
including the issuance of electronic attestations of attributes, thereby enhancing the
security and reliability of online transactions and interactions.
(3) In order to foster a competitive and digital European economy, and to facilitate cross-
border business, it is necessary to establish a seamless and secure environment for
digital interaction between economic operators and public sector bodies in different
configurations.
(4) In order to ensure the interoperability and security of European Business Wallets, the
technical specifications established in Regulation (EU) No 910/2014 and subsequent
implementing regulations established pursuant to that Regulation as well as the
technology and standards developments and the work carried out on the basis of
1 OJ C 365, 23.9.2022, p. 18.
2 Communication from the Commission to the European Parliament, the European Council, the Council, the European Economic
and Social Committee and the Committee of the Regions ‘A Competitiveness Compass for the EU’, COM(2025) 30 final.
3 Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and
trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC (OJ L 257, 28.8.2014, p. 73, ELI:
http://data.europa.eu/eli/reg/2014/910/oj).
EN 15 EN
Recommendation (EU) 2021/946, and in particular the Architecture and Reference
Framework, should apply, with the specifications laid down in this Regulation taking
precedence in the event of any inconsistency.
(5) In order to enhance the functioning of the digital single market, ensure interoperability
and reduce administrative burdens, it is essential to ensure compatibility between and
European Business Wallets and existing systems and solutions at both Union and
national level. As prescribed by the Interoperable Europe Act and to enhance secure
and efficient data exchanges across the Union, the implementation of the European
Business Wallets should, to the extent possible, where appropriate and following
technical analysis, make use of existing EU digital infrastructures and building blocks,
including those developed under the Once Only Technical System, the Business
Registers Interconnection System and the European Digital Identity Wallet, thereby
ensuring complementarity, interoperability, and efficient use of public resources.
(6) The European Business Wallets are a digital tool for economic operators to interact
with public sector bodies in the context of meeting reporting obligations and fulfilling
administrative procedures. The use of the core functionalities of the European
Business Wallets to identify and authenticate, sign or seal, submit documents and send
or receive notifications should be without prejudice to procedural requirements that
might be part of an administrative procedure and that cannot be fulfilled by the core
functionalities of the European Business Wallets. These procedural requirements may
include any additional safeguards or verifications, such as checks to ensure the
awareness or understanding of the contents of a document or the implications of the
signature of a contract, or specific actions that are required as part of an administrative
procedure and are not supported by the core functionalities of the European Business
Wallets. Public sector bodies should therefore ensure that all relevant procedural
requirements are met, including any specific actions or processes which need to be
fulfilled as part of an administrative procedure and which cannot be performed
through the European Business Wallets.
(7) Public sector bodies have the flexibility to decide how to ensure that they can accept
European Business Wallets considering the diversity of their IT infrastructure and
their needs for interoperability. This approach allows public sector bodies to maintain
their existing operational frameworks, while benefiting from the advantages of the
European Business Wallets.
(8) This Regulation is without prejudice to the procedural autonomy, the constitutional
requirements and the judicial independence that govern the organisation and
functioning of national justice systems of the Member States, as well as to the
framework, integrity and procedural safeguards of judicial proceedings.
(9) This Regulation is without prejudice to the Member States’ responsibility for
safeguarding national security and their power to safeguard other essential State
functions, including ensuring the territorial integrity of the State and maintaining law
and order.
(10) This Regulation should be without prejudice to the right of legal persons to submit
only once information to public sector bodies as well as to the right of Member States
to continue using other systems for the submission of documents and data between
competent authorities as established under Union law, such as in Regulation
EN 16 EN
2018/1724(4) and Directive (EU) 2017/1132 establishing the Business Registers
Interconnection System
(11) In order to reduce administrative burden and improve competitiveness, all entities
conducting economic activities, including companies, organisations, self-employed
persons, sole traders and any other type of business, regardless of size, sector or legal
form, should be able to use European Business Wallets. To ensure that legally valid
notifications, and documents can be exchanged, and reporting obligations fulfilled by
means of European Business Wallets, it is necessary to establish a reliable and secure
communication channel that can be used by European Business Wallet owners across
the Union. A qualified electronic registered delivery service (‘QERDS’) should
therefore be integrated as a secure communication channel in the European Business
Wallets, and should enable the secure and legally valid exchange of information
between parties, as provided for in Article 43 of Regulation (EU) No 910/2014.
(12) In order to provide a tailored solution for self-employed persons and sole traders, it is
essential to ensure the seamless integration of European Digital Identity Wallets with
European Business Wallets. That integration should enable those persons to
authenticate using their European Digital Identity Wallet and access trust services
offered for the European Business Wallets, including the QERDS established as a
secure communication channel in this Regulation, using those Wallets, without the
need to create a separate business identity. Providers of European Business Wallets
should therefore be allowed to offer the secure communication channel as a standalone
service to self-employed persons and sole traders that use European Digital Identity
Wallets in a business capacity, with ensured interoperability to facilitate app
switching, as well as trust services such as electronic signatures and qualified and non-
qualified time stamping services. Such access to the secure communication channel for
self-employed persons and sole traders, should be promoted by ensuring an offer, at
reasonable and affordable prices, that reflects the usage needs and is accompanied by
terms of use that do not impose an undue burden on those persons.
(13) The European Business Wallets, in combination with Regulation (EU) 2018/1724,
should support the forthcoming 28th Regime(5) by providing the digital infrastructure
for fully digital procedures, enabling start-ups and scale-ups to conduct EU-wide
operations in a rapid and efficient manner. The Business Wallets should provide the
digital infrastructure for the 28th Regime's digital-first strategy, streamlining cross-
border interactions and reducing administrative burden, such as facilitating the secure
storing and signature of contracts and certificates or submitting, receiving and sharing
electronic applications and documents. By providing this infrastructure, the Business
Wallets should help make the "digital by default" principle a reality, facilitating the
growth and development of EU companies and enhancing their competitiveness.
(14) Given the objective of creating a unified digital ecosystem for electronic identification,
authentication, and the exchange of electronic documents, notifications, and
attestations of attributes, the inclusion of Union entities among public sector bodies
covered this Regulation, is necessary. Such an inclusion should create a coherent
4 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018 establishing a single digital
gateway to provide access to information, to procedures and to assistance and problem-solving services and amending Regulation
(EU) No 1024/2012 (OJ L 295, 21.11.2018, pp. 1, ELI: https://eur-lex.europa.eu/eli/reg/2018/1724/oj/eng) 5 European Commission, Call for Evidence: 28th regime – a single harmonized set of rules for innovative companies throughout
the EU, 8th of July, available at https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14674-28th-regime-a-single-
harmonized-set-of-rules-for-innovative-companies-throughout-the-EU_en
EN 17 EN
framework for owners of European Business Wallets to engage with all levels of
public administration thereby reducing administrative complexities and driving uptake
of the European Business Wallets.
(15) In order to ensure the proper issuance and integration of European Business Wallets
throughout the operations and systems of Union entities, this Regulation should have
due regard to the specific nature and structure of such institutions, bodies, offices and
agencies. To ensure the respect of administrative autonomy and security of Union
entities. They should be allowed to acquire European Business Wallets from already
established providers of European Business Wallets, or develop their own European
Business Wallets or act themselves as provider for Union entities. Where Union
entities act as providers of European Business Wallets, they should also be subject to a
supervisory framework. In such cases, the Commission should be tasked to the
supervise the provision of European Business Wallets by Union entities.
(16) Regulation (EU) No 910/2014 established a framework for electronic identification
and trust services in the internal market. Building on the ecosystem established by
Regulation (EU) No 910/2014, the European Business Wallets should offer economic
operators and public sector bodies a secure and reliable solution for digital
identification and authentication, data sharing, and the delivery of legally valid
notifications. The trust framework for European Business Wallets, including the use of
trusted lists, should build upon the structures established under Regulation (EU) No
910/2014.
(17) The European Business Wallets should allow individuals granted the power to act on
behalf of an entity in legal, financial, and administrative matters to exercise their
functions by signing any attestations, declarations, or documents executed through a
legally valid electronic signature within the meaning of Regulation (EU) 910/2014,
which establishes that electronic signatures shall have the equivalent legal effect of a
handwritten signature.
(18) To support the delegation of powers and mandates within a professional context, the
European Business Wallets should incorporate a mandate and role-based authorisation
system that governs access to services and transactions within the European Business
Wallet in such a way as to preserve the integrity of the identity of the owner of that
Wallet. That system should enable economic operators and public sector bodies to
assign rights to authorised representatives through clearly defined technical mandates
allowing the owner of a specific European Business Wallet to grant full rights to
generally use the solution and act on its behalf, and an administrative mandate,
allowing the owner of a Business Wallet to assign roles and responsibilities to various
users of the solution within their organisation. This authorisation system should ensure
compatibility with the EU digital power of attorney, as established by Directive (EU)
2025/25 of the European Parliament and of the Council6. This authorisation system
should be robust and scalable, to ensure that economic operators and public sector
bodies, as the owners of European Business Wallets, can delegate authority to multiple
users, including employees or other authorised natural or legal persons, thereby
facilitating the efficient and secure management of internal activities and ensuring that
access to European Business Wallets and their functions is controlled and auditable.
6 Directive (EU) 2025/25 of the European Parliament and of the Council of 19 December 2024 amending Directives 2009/102/EC
and (EU) 2017/1132 as regards further expanding and upgrading the use of digital tools and processes in company law (OJ L, 2025/25,
10.1.2025, ELI: http://data.europa.eu/eli/dir/2025/25/oj).
EN 18 EN
This system should govern access to services and transactions within the European
Business Wallet, preserving the integrity of the owners' identities.
(19) In order to facilitate the conduct of cross-border business transactions, reduce
administrative burdens, and promote economic growth, it is necessary to establish a
clear and predictable legal framework that recognises the legal equivalence between
the use of the European Business Wallets, or their core functionalities and the secure
communication channel where the latter is used by self-employed persons and sole
traders, and other accepted methods for economic operators to identify, authenticate,
submit documents and receive notifications when interacting with public sector bodies
in the Union. To that end, the use of the core functionalities of a European Business
Wallet, or the secure communication channel where the latter is used by self-employed
persons and sole traders, should have the same legal effect as if lawfully carried out in
person, in paper form, or via any other means or process that would otherwise be
deemed compliant with applicable legal, administrative, or procedural requirements.
(20) To ensure a consistent user experience and to guarantee the utility, reliability, and
interoperability of European Business Wallets across the Union, providers of
European Business Wallets should implement a core set of functionalities. They
should retain the freedom to offer additional features as part of their commercial
offering, fostering innovation and responding to market needs. In order to ensure
uniform conditions for the development and use of the core functionalities,
implementing powers should be conferred on the Commission to set out requirements
and technical specifications necessary to ensure interoperability and seamless
functioning across the Union. Those powers should be exercised in accordance with
Regulation (EU) No 182/2011 of the European Parliament and the Council(7) and
should include the powers to define the necessary standards and protocols for the
secure communication channel, taking into account the latest technological
developments.
(21) European Business Wallets should simplify the complex interactions between
economic operators and public sector bodies, and could also facilitate interactions
among economic operators themselves, reducing administrative burden on economic
operators in a broad range of economic sectors. In order to foster innovation and
competitiveness, the European Business Wallets should enable sector-specific use
cases and enhance operational efficiencies, while ensuring flexibility and adaptability
to support the unique requirements of different sectors, including, but not limited to,
agriculture, energy, environment, social security coordination.
(22) The use of the European Business Wallets in such contexts can aid in the reduction of
costs and promote a wide range of applications and use cases across the Union, such as
the submission of declarations, applications for public funding, access to public
services and facilitating secure data sharing and access within data spaces, such as the
submission of A1 certificates concerning posted workers provided for under
Regulation (EU) 883/2004.
(23) The establishment of the European Business Wallets alongside the Once Only
Technical System is expected to create powerful synergies that maximise efficiency
and operational ease. In particular, economic operators should be able to use the
7 Regulation (EU) No 182/2011 of the European Parliament and of the Council of 16 February 2011 laying down the rules and
general principles concerning mechanisms for control by the Member States of the Commission's exercise of implementing powers (OJ L 55,
28.2.2011, p. 13, ELI: http://data.europa.eu/eli/reg/2011/182/oj).
EN 19 EN
European Business Wallet to hold and transmit evidence retrieved from competent
public authorities through the Once-Only Technical System. Where appropriate,
economic operators should also be able to combine evidence held in the European
Business Wallet with evidence retrieved via the Once Only Technical System in the
context of public procedures. Consequently, by providing a secure digital platform for
storing and exchanging business documents, the European Business Wallets should
facilitate the exchange of such documents between public sector bodies through the
mechanisms established under Once-Only Technical System.
(24) In order to ensure coordination between the Union’s ongoing digitalisation of judicial
cooperation, the modernisation of secure cross-border information exchange, and the
need to provide economic operators with efficient digital tools to interact with
authorities, it is necessary to establish a coherent framework that enables smooth
interaction between such relevant systems. Enhancing such coordination will reduce
administrative burden, improve legal certainty, and strengthen the effectiveness of
cross-border cooperation, by ensuring that communication channels used by economic
operators function seamlessly within the European digital market. In that context,
European Business Wallets should complement the systems set out in Regulation (EU)
2023/2844 and Regulation (EU) 2023/969, where a seamless interaction between
these systems and the Business Wallets should be maintained through the Business
Wallets gateway, enabling relevant authorities to maintain these systems whilst
promoting simplification for European companies.
(25) To facilitate a flexible and efficient exchange of information and services when using
European Business Wallets, and to ensure seamless integration of European Business
Wallets with existing digital identity solutions, it should be possible to use European
Digital Identity Wallets and electronic attestations of attributes for onboarding to and
access management of the European Business Wallets. This should enable users to
leverage existing digital identities and electronic attestations of attributes to access
European Business Wallets, thereby streamlining the onboarding process and
enhancing the overall user experience. The use of electronic attestations of attributes in
the context of the European Business Wallets should cater to the diverse needs of
European Business Wallet owners and may be used to issue and enable the secure and
trustworthy verification of key attributes, such as an owner's current address, VAT
registration number, tax reference number, Legal Entity Identifier (LEI), Economic
Operator Registration and Identification (EORI) number and excise number. European
Business Wallets should support a wide range of use cases, from simple authentication
and identification to more complex transactions and interactions.
(26) In order to ensure the secure and trustworthy operation of European Business Wallets,
providers of European Business Wallets should ensure that each European Business
Wallet they provide is pre-configured to interact with certain trust services, which are
required to enable the core functionalities of European Business Wallets, including the
creation of qualified electronic signatures, the creation of qualified electronic seals,
and the issuance and validation of qualified and non-qualified electronic attestations of
attributes. To support these functionalities, European Business Wallets should allow
for the sharing and storage of specific information and documents relating to the
owner, such as messages and documents for the secure communication channel,
signed and sealed documents, and sets of attributes for attestation-related services.
(27) To allow for the legal recognition of electronic attestations of attributes presented via
European Business Wallets, it is necessary to allow for the creation and validation of
linked attestations, whereby one attestation is cryptographically linked to another in a
EN 20 EN
manner that allows the verification of the authenticity and integrity of each individual
attestation, and of all linked attestations collectively. To that end, the European
Business Wallet infrastructure should, through the use of the chain of attestations,
enable the submission of a single instance of an attestation and facilitate its subsequent
reuse across relevant procedures. Such functionality should allow European Business
Wallet owners to transmit a reference to a document where appropriate with a
cryptographic element, such as a hash key to a sealed attestation issued by a European
Business Wallet, thereby attesting to the integrity and authenticity of the original
submission.
(28) In order to ensure that the standards and technical specifications for European
Business Wallets ensure harmonisation across various solutions, it is necessary to
define the standards and protocols for the core functionalities and technical
requirements for European Business Wallets in an Annex to this Regulation. The
Annex should set out the requirements for the implementation of European Business
Wallets. To ensure the long-term viability and effectiveness of the European Business
Wallets, implementing powers should be conferred on the Commission to establish
and update the procedures and technical specifications on the implementation of core
functionalities, thereby allowing for the integration of additional features and new
technologies that would enable new use cases, such as agentic AI or the provision of a
digital identity to an owner’s asset, and enabling the European Business Wallets to
continue to support the evolving needs of economic operators in a secure and
trustworthy manner. Those powers should be exercised in accordance with Regulation
(EU) No 182/2011 of the European Parliament and the Council. To the extent
possible, the standards and technical specifications of the European Business Wallet
should take into account relevant technical solutions and standards used by existing
ICT systems by economic operators, facilitating the alignment of these systems to be
aligned to and made interoperable with the European Business Wallet.
(29) To support the timely development of the market for European Business Wallets, the
adoption of the implementing acts on core functionalities and the accompanying
technical specifications should be prioritised. Where appropriate, these should build on
the existing standards including those out in the Architecture and Reference
Framework provided for in the context of Regulation (EU) No 910/2014, to support
the re-use of familiar technical standards and uptake of the European Business
Wallets.
(30) To ensure the high level of trust, functionality, and security of European Business
Wallets necessary to the cross-border provision of their services, and in particular to
mitigate the risk of fraud, providers of European Business Wallets should be subject to
clear and proportionate requirements and obligations without being subject to
additional national requirements.
(31) To ensure proper supervision in line with this Regulation, entities that would like to
become providers of European Business Wallets should be required to notify their
intention to provide such European Business Wallets to the supervisory bodies prior to
offering their services. In order to safeguard the integrity and accountability of
European Business Wallet providers and to ensure the security of data stored or
exchanged in the European Business Wallets ecosystem, providers should be
established within the Union. This should ensure that such providers fall under the
jurisdiction and supervision of a competent body in a Member State, allowing for
effective enforcement of this Regulation and the protection of users' rights and data.
EN 21 EN
Furthermore, providers of European Business Wallets should not present a risk to the
security of the Union, namely by not being subject to control by a third country or by a
third-country entity, to ensure that the Union's critical digital infrastructure remains
secure and resilient. In line with the requirements set out in this Regulation, the
Commission may adopt implementing acts to ensure cooperation and interoperability
with solutions established or endorsed by like-minded partners of the Union.
(32) The Union must protect its security interest against providers which could represent a
persistent security risk due to the potential interference from third countries. To that
end, it is necessary to reduce the risk of persisting dependency on high-risk suppliers
in the internal market, including in the ICT supply chain, as they could have
potentially serious negative impacts on the security of economic operators and public
sector bodies across the Union and the Union’s critical infrastructure, especially with
regards to the integrity, confidentiality and availability of data and services. Any
restrictions should be based on a proportionate risk assessment and corresponding
mitigation measures as defined in Union policies and laws. Such limitations may
apply, for example, to high-risk suppliers, as identified under Union law.
(33) In order to establish the identity of economic operators in a secure and reliable
manner, this Regulation should allow for the use of qualified electronic attestations of
attributes to issue European Business Wallet owner identification data. Qualified
electronic attestations of attributes can be easily updated or revoked. The use of
qualified electronic attestations of attributes for establishing the identity of economic
operators provides an efficient, and secure solution that is suited to the needs of the
digital economy. Qualified trust service providers issuing these attestations are
regulated under Regulation (EU) No 910/2014 and are subject to strict requirements
and scrutiny, ensuring a high level of security and trust in the issuance process. The
authentic sources used to verify the data contained in the qualified electronic
attestations of attributes are business registers and other registers, and the use of the
Business Registers Interconnection System (‘BRIS’) and the Beneficial Ownership
Registers Interconnection System (‘BORIS’) should be promoted to facilitate the
verification of this data, thereby ensuring the accuracy and reliability of the
identification data.
(34) This Regulation should not affect the functioning or the role of business registers as
authentic sources and should not alter the way they operate or the data filed therein but
rather build upon and complement the existing infrastructure. In this regard, where
electronic attestations of attributes are issued by or on behalf of an authentic source,
such as a business register, the register could directly issue the relevant data, further
enhancing the security and reliability of the identification process.
(35) Regulation (EU) No 910/2014 requires Member States to ensure that measures are
taken to allow qualified trust service providers to verify by electronic means, at the
request of the user, the authenticity of the attributes listed in Annex VI of Regulation
(EU) No 910/2014, such as educational and professional qualifications, titles and
licenses, powers and mandates to represent natural or legal persons, public permits and
licenses and financial and company data. The European Business Wallets framework
should build on this existing requirement that should cover all official data that is
relevant for economic operators in the context of the European Business Wallets and
enable the electronic verification of attributes to facilitate the issuance of European
Business Wallet owner identification data and other electronic attestations of
attributes.
EN 22 EN
(36) As all economic operators and entities conducting economic activities should be able
to use European Business Wallets, including self-employed persons and sole traders,
European Business Wallet owner identification data should be provided in a manner
that is specifically designed to verify their identity and attested attributes within a
business context. To ensure consistency with existing Union frameworks and facilitate
cross-border interoperability, the European Business Wallet framework should use the
European Unique Identifier (EUID) provided by the codified Company Law Directive
(EU) 2017/1132(8) and Commission Implementing Regulation (EU)2021/369(9) as
well as Regulation (EU) 2024/1624(10) and Commission Implementing Regulation
(EU) 2021/369(11). Companies and other legal entities as well as arrangements such as
trusts are assigned a European Unique Identifier to enable their unequivocal
identification in cross-border situations. The European Unique Identifier is currently
made publicly accessible through BRIS and used by BORIS. Accordingly, the
European Business Wallet framework should rely on the issuance and recording
process of European Unique Identifiers as the means of verifying the identity of
economic operators to which European Unique Identifiers are provided in accordance
with Directive (EU) 2017/1132. The European Business Wallet framework should rely
on the issuance and recording process of European Unique Identifiers for other
economic operators falling under Directive (EU) 2015/849.
(37) To ensure that all European Business Wallet owners can be reliably identified and
their electronic attestation of attributes are associated with a unique entity, it is also
necessary to assign a unique identifier to other economic operators and public sector
bodies. To ensure uniform conditions for the implementation of unique identifiers, in
particular their effectiveness and consistency, implementing powers should be
conferred on the Commission to specify the detailed requirements for the unique
identifiers. Those powers should be exercised in accordance with Regulation (EU) No
182/2011. Given the diverse approaches among Member States regarding the
registration of some economic operators and public sector bodies, it is important to
ensure transparency and accessibility for providers of European Business Wallet
owner identification data. To this end, Member States should notify to the
Commission the authentic sources that are relevant for the issuance of European
Business Wallet owner identification data.
(38) In order to ensure the efficient, secure, and transparent functioning of the European
Business Wallet framework, it is necessary to establish a European Digital Directory,
that includes personal data of economic operators. The Commission should be
8 Directive (EU) 2017/1132 of the European Parliament and of the Council of 14 June 2017 relating to certain
aspects of company law (codification) (OJ L 169, 30.6.2017, pp. 46–127, ELI:
http://data.europa.eu/eli/dir/2017/1132/oj
9 Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 on the prevention of the use of the financial
system for the purposes of money laundering or terrorist financing (OJ L, 2024/1624, 19.6.2024, ELI:
http://data.europa.eu/eli/reg/2024/1624/oj)
10 Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 on the prevention
of the use of the financial system for the purposes of money-laundering or terrorist financing, and
amending Regulations (EU) No 1093/2010, (EU) No 1094/2010 and (EU) No 1095/2010 (OJ L …,
19.6.2024, ELI: http://data.europa.eu/eli/reg/2024/1624/oj 11 Commission Implementing Regulation (EU) 2021/369 of 1 March 2021 establishing the technical
specifications and procedures required for the system of interconnection of central registers referred to
in Directive (EU) 2015/849 of the European Parliament and of the Council (OJ L 71, 2.3.2021, pp. 11–
17, ELI: http://data.europa.eu/eli/reg_impl/2021/369/oj
EN 23 EN
empowered to set up and maintain this Directory, as a trusted source of information on
economic operators and public sector bodies using European Business Wallets. The
Directory should enable European Business Wallet owners to be easily contacted to
promote legal certainty in relation to dealings between businesses and in relation to
interactions with public sector bodies, particularly in the view of promoting trade
between Member States. European Business Wallet Providers, liaising with the
Commission, should submit the necessary information to support the functioning of
the European Digital Directory and collaborate with the relevant qqualified trust
service providers to ensure that the data submitted remains accurate. Such actions shall
not indirectly create a requirement for economic operators to update such information.
In this regard the Digital Directory will rely on the information made available by
business registers also through BRIS while ensuring that such information will not be
duplicated.
(39) Regulation (EU) 2016/679 of the European Parliament and of the Council applies to
all personal data processing activities under this Regulation. Where the European
Digital Directory includes the processing of personal data this will be carried out in
accordance with the relevant data protection principles, such as the data minimisation
and purpose limitation principle, obligations, such as data protection by design and by
default, and include, where appropriate, features of pseudonymisation.
(40) To avoid excessive regulatory burdens, ex post supervision of providers of European
Business Wallets and monitoring of their activities should be provided for, rather than
requiring prior compliance verification for every aspect of their operations. This
approach should allow for a more flexible and efficient regulatory environment, while
maintaining the necessary safeguards to protect users and ensure compliance with the
requirements of the European Business Wallets framework. The notification process
for providers of European Business Wallets should be streamlined and efficient, with
clear requirements and timelines for applicants. Qualified trust service providers,
which are already subject to a robust regulatory framework under Regulation (EU) No
910/2014, should benefit from a particularly light process to be able to provide
European Business Wallets.
(41) In order to ensure transparency and accountability in the European Business Wallet
ecosystem, a publicly available list of notified providers of European Business Wallets
should be established and maintained by the Commission. That list should include
information transmitted by the national supervisory bodies concerning providers,
including qualified trust service providers, that have completed the notification
process. Making that information publicly available should enable users to verify the
authenticity and trustworthiness of providers, thereby promoting a high level of
security and trust in the European Business Wallet ecosystem.
(42) Effective oversight by supervisory bodies, vested with sufficient powers and provided
with adequate resources, is essential to ensure that European Business Wallets made
available in the Union comply with the requirements laid down in this Regulation. To
best ensure such oversight and relevant expertise, Member States should designate the
same supervisory body or bodies as designated pursuant to Article 46a(1) and Article
46b(1) of Regulation (EU) No 910/2014.
(43) Due consideration should be given to ensuring effective cooperation between
supervisory bodies designated under this Regulation, Article 46b of Regulation (EU)
No 910/2014 and the competent authorities designated or established pursuant to
Article 8(1) of Directive (EU) 2022/2555 of the European Parliament and of the
EN 24 EN
Council(12)Since the competent authorities are distinct entities, they should cooperate
closely and in a timely manner, including by exchanging relevant information to
ensure effective supervision and compliance of European Business Wallet providers
with the applicable obligations under Regulation (EU) No 910/2014 and Directive
(EU) 2022/2555.
(44) To harmonise the enforcement of this Regulation, national supervisory bodies should
be empowered to impose administrative fines. It is necessary to specify the upper limit
of administrative fines and the criteria for their determination in order to promote
equal treatment of providers of European Business Wallets across the Union
regardless of their Member State of establishment. The competent supervisory
authority should assess each case individually, taking into account all relevant
circumstances, including the nature, gravity and duration of the infringement, its
consequences and any measures taken to ensure compliance and mitigate harm. In this
regard, Member States should notify the Commission of the rules laid down in
national law allowing the supervisory body to impose penalties by [Publications
Office, insert the date 12 months after the entry into force of this Regulation] and
should notify the Commission without delay of any subsequent amendments to those
rules.
(45) In order to ensure the proper functioning of the internal market and to protect the
rights of economic operators, it is necessary to establish a mechanism for the
Commission to intervene in cases where a provider of European Business Wallets is
found to be non-compliant with the requirements of this Regulation and no effective
measures have been taken by the competent supervisory authority to remedy the
situation. This mechanism should allow for the Commission to carry out an evaluation
of compliance, consult with the Member States concerned and the provider, and adopt
implementing acts to provide for corrective or restrictive measures. This should enable
the Commission to take swift and effective action to address any non-compliance and
to ensure that the European Business Wallets are used in a secure and trustworthy
manner.
(46) The Cooperation Group established pursuant to Regulation (EU) No 910/2014 should
be given the additional responsibility for the coordination of national practices and
policies related to this Regulation and facilitate discussions between competent
authorities regarding the Regulation's application and enforcement, thereby delivering
on the objectives of the Cooperations Group’s establishment and retaining expertise
for the benefit of implementing the European Business Wallet framework.
(47) In order to support effective take-up and interoperability, all public sector bodies
should be required to enable the use of the European Business Wallet in all relevant
administrative procedures for the purposes of identification and authentication, signing
or sealing documents, submitting documents and sending or receiving notifications. In
this regard, public sector bodies should by [Publications Office, please insert the date
24 months after the entry into force of this Regulation] ensure that the use of European
Business Wallets by economic operators is possible and that, where the receipt or
communication of documents or notifications is concerned, they are able to access the
12 Directive (EU) 2022/2555 of the European Parliament and of the Council of 14 December 2022 on measures
for a high common level of cybersecurity across the Union, amending Regulation (EU) No 910/2014
and Directive (EU) 2018/1972, and repealing Directive (EU) 2016/1148 (OJ L 333, 27.12.2022, pp. 80–
152, ELI: http://data.europa.eu/eli/dir/2022/2555/oj)
EN 25 EN
Business Wallets’ secure communication channel. To ensure seamless and
interoperable application of this Regulation in this regard, public sector bodies should
own a European Business Wallet for the purposes of receiving or sending documents
and notifications. The obligation for public sector bodies to accept European Business
Wallets by economic operators should not affect systems used for the exchange or
submission of documents or data between competent authorities.
(48) In order to avoid disrupting existing interactions between economic operators and
public sector bodies, it is necessary to enable a transition period until [Publications
Office, please insert the date 36 months after the entry into force of this Regulation].
During such period public sector bodies may choose not to offer the European
Business Wallets' secure communication channel and instead support alternative
solutions already in place which enable economic operators to communicate with
public sector bodies prior to offering the European Business Wallets’ secure
communication channel. In order to ensure an adequate level of security and
interoperability, any alternative solution used during this transition period should
comply with the requirements for Qualified Electronic Registered Delivery Services
set out in Regulation (EU) No 910/2014 and offer a gateway to European Business
Wallets. The gateway should enable users of European Business Wallets to access the
alternative solutions used during the transition period. After this period, public sector
bodies should support the secure communication channel of the European Business
Wallets to ensure a harmonised and efficient means of communication across the
Union, to the benefits of European businesses.
(49) European Business Wallets contribute to the provision of a cross-border digital public
service within the meaning of the Interoperable Europe Act (EU) 2024/903. The
assessment required under that Regulation has been carried out, and the resulting
report will be published on the Interoperable Europe Portal.
(50) To ensure that the European Business Wallets ecosystem continues to meet the needs
of economic operators and public sector bodies, it is necessary to assess its
implementation and impact in light of the purpose of this Regulation. The evaluation
should, in particular, take into account the risk of legal fragmentation within the
internal market regarding the electronic submission of documents and attestations of
attributes as well as the technological developments and progression of the market for
European Business Wallets and associated trust services.
(51) To avoid duplication and reduce administrative burden, public sector bodies should
not require the same information or documents to be submitted again through physical
or alternative digital means, or in the inverse, once these have been validly transmitted
via the European Business Wallet in accordance with this Regulation. Accordingly,
Member States should not adopt or maintain additional national requirements
regarding matters falling within the scope of this Regulation, unless explicitly
provided for herein, since this would affect its direct and uniform application.
(52) In order to enable effective access to Union procedures and markets and facilitate the
participation of economic operators established outside the Union in the European
Business Wallet framework, it is necessary to enable providers of European Business
Wallets to issue European Business Wallets to such operators, provided that their
identity can be verified with a high level of certainty. To prevent duplicate
registrations and safeguard the integrity of the internal market, such operators should
not be allowed to obtain more than one set of European Business Wallet owner
identification data and one unique identifier. Member States’ should cooperate to
EN 26 EN
mitigate the risk of duplicate registrations and ensure the uniqueness of registrations of
economic operators established outside of the Union.
(53) The implementing act concerning the requirements and procedures for the unique
identifier should encompass the conditions for their issuance to third country
economic operators. In particular, it should set the conditions that promote
coordination between providers of European Business Wallet owner identification
data, ensuring that each third country economic operator is attributed only one unique
identifier for the purpose of the European Business Wallet owner identification data.
Prior to the provision of a European Business Wallet to an economic operator
established outside the Union the relevant provider should confirm that the conditions
for verifying the identity of the economic operator have been met. That should allow
economic operators from third countries to use European Business Wallets, while
preserving the security and trustworthiness of the ecosystem.
(54) In order to ensure uniform conditions for the implementation of the recognition and
interoperability of business wallets or similar systems and framework from third
countries to support and promote partnerships and cooperation, implementing powers
should be conferred on the Commission to set the conditions under which such similar
systems or framework benefit from the provisions of this Regulation. Those powers
should be exercised in accordance with Regulation (EU) No 182/2011 of the European
Parliament and of the Council.
(55) Regulation (EU) No 910/2014 offers a secure and convenient means for natural
persons, such as citizens and residents, to identify themselves and access online
services. It requires Member States to ensure that European Digital Identity Wallets
are provided to legal persons, despite a lack of clarity on the specific technical
implementation of European Digital Identity Wallets for legal persons. This
uncertainty about the purpose and functioning of the European Digital Identity Wallets
for legal persons increases legal and technical complexity for Member States. It is
therefore necessary to amendment Article 5a of Regulation (EU) No 910/2014 to
ensure that the mandatory issuance of European Digital Identity Wallets relates only to
natural persons.
(56) The framework established by this Regulation should provide a secure, Union-wide
digital infrastructure and should therefore constitute the principal instrument for such
purposes. To fully realise the benefits of the European Business Wallet framework for
both economic operators and public sector bodies, it is necessary to promote its use as
the default tool for secure digital identification, authentication, and the exchange of
electronic documents and attestations of attributes.
(57) To ensure a coherent and horizontal application across sectors of Union legislation,
reduce administrative cost on economic operators and to improve budgetary
efficiency, Union law concerning electronic identification, authentication, or the
exchange of electronic documents, notifications, or attestations of attributes,
particularly where specific technical requirements, systems, or protocols are
established, should be applied in a manner consistent with this Regulation.
Accordingly, any future legislative or non-legislative initiatives in these fields should
adhere to the Business-Wallet-by-Default principle and should be designed and
developed to build upon and enable the use of European Business Wallets. Where such
alignment is not possible, the Commission should provide a written justification
through an Impact Assessment, accompanying the relevant initiative, setting out the
reasons for not enabling the use of European Business Wallets. The Commission
EN 27 EN
should evaluate and review this Regulation by [Publications Office, please insert the
date 3 years post adoption] and every four years thereafter and report to the European
Parliament and the Council. This review is essential for assessing the continued
relevance of the prescribed core functions and technical specifications, especially
those associated with the QERDS as a secure communication channel, in the context
of the latest technological advancements. Furthermore, the Commission should
evaluate the notification procedures for providers of European Business Wallet, as
well as the implementation and effectiveness of the rules on penalties established by
Member States, to evaluate market developments and compliance levels.
(58) The European Data Protection Supervisor was consulted in accordance with Article
42(1) of Regulation (EU) 2018/1725 of the European Parliament and of the
Council(13), and delivered an opinion on [insert date].
HAVE ADOPTED THIS REGULATION:
Chapter I - Subject matter, scope and definitions
Article 1
Subject matter
This Regulation enables secure digital identification and authentication, data sharing and
legally valid notifications, reduces administrative burdens and compliance costs, and supports
cross-border business and competitiveness. In particular, it:
(1) establishes a framework for the provision of European Business Wallets;
(2) establishes the principle of equivalence, giving equivalent legal effect to actions and
transactions carried out through a European Business Wallet as to actions and
transactions lawfully carried out in person, in paper form, or via any other means or
processes that would be deemed compliant with applicable legal, administrative, or
procedural requirements;
(3) establishes rules for the issuance of European Business Wallet owner identification
data for the identification of economic operators and public sector bodies;
(4) establishes the European Digital Directory;
(5) designates the European unique identifier (EUID), as established and governed by
Directive (EU) 2017/1132, as the unique identifier for European Business Wallet
owners, and establishes a similar unique identifier for European Business Wallets
owners to whom the European Unique Identifier is not available;
(6) lays down the notification mechanism under which providers of European Business
Wallets shall be established;
(7) lays down obligations for public sector bodies concerning European Business
Wallets;
(8) provides a framework for the supervision of Union entities, where such public sector
bodies provide European Business Wallets;
13
Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural
persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC (OJ L 295, 21.11.2018, p. 39, ELI: http://data.
europa.eu/eli/reg/2018/1725/oj).
EN 28 EN
(9) provides a framework for the recognition of third-country systems similar to the
European Business Wallets and the issuance of European Business Wallets to third
country economic operators.
Article 2
Scope
1. This Regulation applies to the provision and acceptance of European Business
Wallets and the issuance and acceptance of European Business Wallet owner
identification data, and to the use of European Business Wallets by economic
operators and public sector bodies.
2. This Regulation is without prejudice to the existing systems and procedures
mandated by Union law governing the exchange of documents and data between
competent authorities.
Article 3
Definitions
For the purposes of this Regulation, the following definitions apply:
(1) ‘European Business Wallet’ means a digital solution that allows European
Business Wallet owners to securely store, manage, and present European
Business Wallet owner identification data and electronic attestations of
attributes to Business Wallet-relying parties and other entities using European
Business Wallets and European Digital Identity Wallets for the following
purposes:
(a) to authenticate and provide the verified proofs required by a relying
party;
(b) to access and use electronic attestations of attributes, electronic
signatures, electronic seals, electronic registered delivery services, and
electronic time stamps;
(c) to enable the creation, management and delegation of mandates to
authorised representatives;
and that may support additional functionalities in accordance with this
Regulation;
(2) ‘European Business Wallet owner identification data’ means a set of data that
enables the establishment of the identity of a European Business Wallet owner
and that is issued by a provider of European Business Wallet owner
identification data;
(3) ‘provider of European Business Wallet owner identification data’ means a
qualified trust service provider or public sector body or the Commission
issuing European Business Wallet owner identification data;
(4) ‘economic operator’ means any natural or legal person, or a group of such
persons, including temporary associations of undertakings, acting in a
commercial or professional capacity for purposes related to their trade,
business, craft or profession;
EN 29 EN
(5) ‘public sector body’ means a Union entity, a national, state, regional or local
authority, a body governed by public law or an association formed by one or
several such entities or bodies , or a private entity mandated by at least one
such entities, authorities, bodies or associations to provide public services,
when acting under such a mandate;
(6) ‘Union entity’ means a Union institution, body, office and agency set up by or
pursuant to the Treaty on European Union, the Treaty on the Functioning of
European Union or the Treaty establishing the European Atomic Energy
Community;
(7) ‘European Business Wallet owner’ means an economic operator or public
sector body that owns or has a right of use of a European Business Wallet;
(8) ‘trust service’ means trust service as defined in Article 3, point (16) of
Regulation (EU) 910/2014;
(9) ‘attribute’ means attribute as defined in Article 3, point (43) of Regulation
(EU) 910/2014;
(10) ‘electronic attestations of attributes’ means electronic attestations of attributes
as defined in Article 3, point (44) of Regulation (EU) No 910/2014;
(11) ‘qualified attestation of attributes’ means qualified attestation of attributes as
defined in Article 3, point (45) of Regulation (EU) No 910/2014;
(12) ‘European Digital Identity Wallet’ means European Digital Identity Wallet as
defined in Article 3, point (42) of Regulation (EU) No 910/2014;
(13) ‘electronic signature’ means an electronic signature as defined in Article 3,
point (10) of Regulation (EU) No 910/2014;
(14) ‘qualified electronic signature’ means a qualified electronic signature as
defined in Article 3, point (12) of Regulation (EU) No 910/2014;
(15) ‘electronic seal’ means an electronic seal as defined in Article 3, point (25) of
Regulation (EU) No 910/2014;
(16) ‘qualified electronic seal’ means qualified electronic seal as defined in Article
3, point (27) of Regulation (EU) No 910/2014;
(17) ‘qualified electronic stamp’ means a qualified electronic stamp as defined in
Article 3, point (34) of Regulation (EU) No 910/2014;
(18) ‘authorised representative’ means a natural or legal person acting on behalf of
the European Business Wallet owner in executing and operating functions of a
designated European Business Wallet on the basis of an authorisation granted
by a European Business Wallet owner;
(19) ‘mandate’ means the authorisation granted by a European Business Wallet
owner to an authorised representative, enabling that representative to act on
behalf of the owner in executing and operating functions of a designated
European Business Wallet;
(20) ‘electronic document’ means an electronic document as defined in Article 3,
point (35) of Regulation (EU) No 910/2014;
(21) ‘qualified electronic registered delivery service’ means a qualified electronic
registered delivery service as defined in Article 3, point (37) of Regulation
(EU) No 910/2014;
EN 30 EN
(22) ‘user’ means a natural or legal person, or a natural person representing another
natural person or a legal person, that uses European Business Wallets or
European Business Wallet electronic identification means provided in
accordance with this Regulation;
(23) ‘European Business Wallet-relying party’ means a natural person, an economic
operator or public sector body that relies upon European Business Wallets;
(24) ‘wallet unit attestation’ means a data object that describes the components of
the European Business Wallet unit or allows authentication and validation of
those components;
(25) ‘European Business Wallet unit’ means a unique configuration of a European
Business Wallet solution that includes European Business Wallet front-end and
European Business Wallet back-end, wallet secure cryptographic applications
and wallet secure cryptographic devices provided by a provider to a European
Business Wallet to a specific European Business Wallet owner;
(26) ‘European Business Wallet solution’ means a combination of software,
hardware, services, settings, and configurations, including European Business
Wallet front-end and back-end, one or more wallet secure cryptographic
applications and one or more wallet secure cryptographic devices;
(27) ‘critical assets’ means assets within or in relation to a European Business
Wallet unit of such extraordinary importance that where their availability,
confidentiality or integrity are compromised, that would have a very serious,
debilitating effect on the ability to rely on the European Business Wallet unit;
(28) ‘wallet secure cryptographic application’ means an application that manages
critical assets by being linked to and using the cryptographic and non-
cryptographic functions provided by the wallet secure cryptographic device;
(29) ‘wallet secure cryptographic device’ means a tamper-resistant device that
provides an environment that is linked to and used by the wallet secure
cryptographic application to protect critical assets and provide cryptographic
functions for the secure execution of critical operations;
(30) ‘trust service provider’ means a trust service provider as defined in Article 3,
point (19) of Regulation (EU) No 910/2014;
(31) ‘qualified trust service provider’ means qualified trust service provider as
defined in Article 3, point (20) of Regulation (EU) No 910/2014;
(32) ‘electronic attestation of attributes issued by or on behalf of a public sector
body responsible for an authentic source’; means a electronic attestation of
attributes issued by or on behalf of a public sector body responsible for an
authentic source as defined in Article 3, point (46) of Regulation (EU) No
910/2014;
(33) ‘authentic source’ means authentic source as defined in Article 3, point (47) of
Regulation (EU) No 910/2014;
(34) ‘attestation scheme’ means a set of rules applicable to one or more types of
electronic attestation of attributes;
(35) ‘catalogue of schemes means a digital repository listing schemes for the
attestation of attributes registered in accordance with this Regulation and that is
maintained and published online by the Commission;
EN 31 EN
(36) ‘European unique identifier’ means the European Unique Identifier referred to
in Directive (EU) 2017/1132;
(37) ‘national register’ means an official database or system established and
maintained by or on behalf of a national government or its designated
authority, which records, stores, and manages information pertaining to legal
entities, including but not limited to companies, partnerships, foundations,
associations as well as businesses as natural persons such as sole-traders and
self-employed persons or other registrable persons or organisations;
(38) ‘API’ or ‘Application Programming Interface’ means a set of definitions and
protocols for building and integrating application software to share data;
(39) ‘submission’ or ‘submit 'means any transmission of structured or unstructured
data, files, forms, or records by between a public sector body and an economic
operator or between economic operators or between public sector bodies,
where such transmission is required, requested, or permitted under Union or
national law, and is intended to support a legal, administrative, or procedural
purpose;
(40) ‘notification’ means any transmission of information, decisions, requests, or
acknowledgements between a public sector body and an economic operator or
between economic operators or between public sector bodies, which is
required, requested, or permitted under Union or national law, and which is
intended to produce legal effects or inform the recipient of rights, obligations,
or procedural developments;
(41) ‘administrative procedure’ means a sequence of actions, defined by Union or
national law, that must be taken by economic operators or public sector bodies
to comply with obligations, provide information, or obtain a decision,
authorisation, or benefit from a public sector body in the exercise of
administrative functions;
(42) 'European Business Wallet front-end' means the user interface component,
regardless of platform or form factor, that interacts with users acting on behalf
of the owner, and is part of the European Business Wallet unit;
(43) 'European Business Wallet back-end' means the server-side components,
including software, services, and infrastructure, that provide the necessary
functionality and support for the European Business Wallet Frontend, and form
part of the European Business Wallet unit.
Chapter II – European Business Wallets
Article 4
Principle of equivalence
Where a European Business Wallet owner makes use of any of the core functionalities of a
European Business Wallet referred to in Article 5(1), the resulting action shall have the same
legal effect as if the action had been lawfully carried out in person, in paper form, or via any
other means or processes that would be deemed compliant with applicable legal,
administrative, or procedural requirements.
Where a self-employed person or a sole trader makes use of the qualified electronic registered
delivery service in the circumstances set out in Article 5(3), the resulting action shall have the
EN 32 EN
same legal effect as if the action had been lawfully carried out in person, in paper form, or via
any other means or processes that would be deemed compliant with applicable legal,
administrative, or procedural requirements.
Article 5
Core functionalities of European Business Wallets
1. Providers of European Business Wallets shall ensure that the European Business
Wallets they provide enable European Business Wallet owners to make use of the
following core functionalities:
(a) securely issue, request, obtain, select, combine, store, delete, share and present
electronic attestations of attributes;
(b) selectively disclose European Business Wallet owner identification data and
attributes contained in electronic attestations of attributes, in the context of the
functionalities listed in point a;
(c) request and share European Business Wallet owner identification data and
electronic attestations of attributes in a secured way between European
Business Wallets and European Digital Identity Wallets and with European
Business Wallet-relying parties;
(d) sign by means of qualified electronic signatures and seal by means of qualified
electronic seals, as applicable;
(e) bind data in electronic form to a particular time by means of qualified
electronic time stamps;
(f) issue electronic attestations of attributes to European Business Wallets and
European Digital Identity Wallets;
(g) issue electronic attestations of attributes through the European Business Wallet
of the owner, allowing the issued attestation to be linked to other relevant
attestations forming part of a chain;
(h) enable the use of qualified and non-qualified electronic attestations of attributes
to allow European Business Wallet owners and their authorised representatives
to authenticate themselves;
(i) transmit and receive electronic documents and data by means of a qualified
electronic registered delivery service capable of supporting confidentiality and
integrity;
(j) authorise multiple users to access and operate the European Business Wallet of
the owner, and for the European Business Wallet owner to manage and revoke
such authorisations;
(k) authorise European Business Wallet-relying parties to request electronic
attestations of attributes issued to the European Business Wallet owner, and for
the European Business Wallet owner to manage and revoke such
authorisations;
(l) export their data, including issued European Business Wallet owner
identification data, electronic attestations of attributes, communication logs,
and interaction records, in a structured, commonly used and machine-readable
EN 33 EN
format, at the request of the owner or in the event of termination of service or
revocation of the notification of the provider of the European Business Wallet;
(m) access a log of all transactions;
(n) access a common dashboard for accessing, storing and verifying
communications exchanged through the qualified electronic registered delivery
service referred to in point (i).
2. Providers of European Business Wallets may offer additional functionalities beyond
those listed in paragraph 1 provided that such functionalities do not interfere with or
compromise the confidentiality, availability, or integrity of the minimum core
functionalities, and the reliability and interoperability of the European Business
Wallets they provide.
3. Providers of European Business Wallets shall enable the provision of the qualified
electronic registered delivery service referred to in paragraph 1, point (i) as a
standalone service to users of European Digital Identity Wallets.
4. Providers of European Business Wallets shall implement the functionalities referred
to in paragraph 1 in accordance with requirements set out in the Annex.
5. The Commission shall, by means of implementing acts, establish a list of reference
standards and where necessary, establish specifications and procedures for the core
functionalities of European Business Wallets referred to in paragraph 1 of this
Article. Those implementing acts shall be adopted in accordance with the
examination procedure referred to in Article 19.
Article 6
Technical features for European Business Wallets
1. Providers of European Business Wallets shall ensure that the European Business
Wallets they provide support common protocols and interfaces:
(a) for the issuance of European Business Wallet owner identification data,
qualified and non-qualified electronic attestations of attributes and qualified
and non-qualified certificates to European Business Wallets;
(b) for European Business Wallet-relying parties to request and validate European
Business Wallet owner identification data and electronic attestations of
attributes;
(c) for the sharing and presenting to European Business Wallet-relying parties of
European Business Wallet owner identification data, electronic attestation of
attributes and of selectively disclosed data;
(d) to allow interaction with the European Business Wallets automatically without
manual intervention or through direct user action;
(e) to securely onboard the European Business Wallet owner remotely via an
authorised representative with an electronic identification means of that
authorised representative which meets the requirements of Regulation (EU) No
910/2014 with regard to the assurance levels ‘substantial’ or ‘high’;
(f) for interaction between European Business Wallets, and between European
Business Wallets and European Digital Identity Wallets for the purpose of
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receiving, validating and sharing European Business Wallet owner
identification data and electronic attestations of attributes in a secure manner;
(g) for authenticating European Business Wallet-relying parties by implementing
authentication mechanisms, where authentication is required;
(h) for European Business Wallet-relying parties to verify the authenticity and
validity of European Business Wallets, where the verification of the
authenticity and validity is required;
(i) for the provision of the qualified electronic registered delivery service referred
to in Article 5(1), point (i), including an interface to the European Digital
Directory established pursuant to Article 10;
(j) for the assigning to each European Business Wallet owner, for the purposes of
the qualified electronic registered delivery service referred to in Article 5(1),
point (i) and the European Digital Directory referred to in Article 10, at least
one unique digital address;
(k) for the provision of wallet unit attestations to all European Business Wallet
units, containing public keys and corresponding private keys protected by a
wallet secure cryptographic device;
(l) for the management of critical assets, for the use of at least one wallet secure
cryptographic application and wallet secure cryptographic device and, where
critical assets relate to performing electronic identification at assurance level
substantial, for ensuring that such cryptographic operators or other operations
processing critical assets are performed in accordance with the requirements
for the characteristics and design of electronic identification means at
assurance level substantial as set out in Commission Implementing Regulation
(EU) 2015/1502.
2. Providers of European Business Wallets shall also:
(a) ensure that the European Business Wallet owner identification data is digitally
associated with the European Business Wallet of the owner;
(b) ensure that, for the purposes of the functionality referred to in Article 5(1),
point (j):
– mappings between roles and attributes are verifiable, auditable, revocable
and traceable to their legitimate issuers;
– conflicts of roles, over-delegation, or expired authorisations are
automatically detected and prevented in real time;
– all authorisation logic is interoperable across Member States.
(c) ensure security-by-design;
(d) provide validation mechanisms, in order to ensure that the authenticity and
validity of European Business Wallets can be verified;
(e) provide a mechanism enabling European Business Wallet owners to easily
request technical support and report technical problems or any other incidents
having a negative impact on the use of European Business Wallets;
(f) ensure that the validity of the European Business Wallets can be revoked in the
following circumstances:
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– upon the explicit request of the European Business Wallet owner;
– where the security of the European Business Wallet has been
compromised;
– upon the permanent or temporary cessation of activity of the European
Business Wallet owner;
– where the provider of the European Business Wallet is not included in
the list referred to in Article 12(5).
(g) without undue delay, notify to the Commission:
– the mechanism allowing for the validation of the European Business
Wallet owner identification data;
– the mechanism by which to validate the authenticity and validity of
European Business Wallets.
3. The Commission shall make available the information notified pursuant to paragraph
2, point (g) of this Article to the public through a secure channel, in electronically
signed or sealed form suitable for automated processing.
4. Providers of European Business Wallets shall implement the technical features
provided for in paragraphs 1 and 2 in accordance with the requirements set out in the
Annex.
5. The Commission shall, by means of implementing acts, establish a list of reference
standards and where necessary, establish specifications and procedures for the
technical features of European Business Wallets provided for in paragraphs 1, 2 and
3 of this Article. Those implementing acts shall be adopted in accordance with the
examination procedure referred to in Article 19.
Article 7
Requirements and obligations for providers of European Business Wallets
1. European Business Wallets shall be provided by providers of European Business
Wallets that are included in the list established pursuant to Article 12(5).
2. Given the role of European Business Wallets in the Unions digital infrastructure,
providers of European Business Wallets shall be established in the Union, have their
principal place of business and main operations in the Union and not present a risk to
the security of the Union. In particular they shall not be subject to control by a third
country or by a third-country entity.
3. Providers of European Business Wallets shall comply with the requirements set out
in Article 19a of Regulation (EU) 910/2014. That obligation shall not apply to
providers of European Business Wallets that are qualified trust service providers.
4. Providers of European Business Wallets shall comply with the requirements set out
in Directive (EU) 2022/2555 of the European Parliament and of the Council on
measures for a high common level of cybersecurity across the Union.
5. Providers of European Business Wallets shall comply with applicable cybersecurity
requirements laid down in Union and national law, including those relating to the
identification of high-risk suppliers. Providers shall also ensure that their suppliers of
software and security solutions comply with these requirements and conform to the
relevant security standards and requirements.
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6. Providers of European Business Wallets shall:
(a) implement appropriate technical and organisational measures to ensure the
confidentiality, integrity, authenticity, interoperability, and availability of the
European Business Wallets they provide with other European Business Wallets
and European Digital Identity Wallets;
(b) ensure that European Business Wallet owners are clearly informed, in a user-
friendly, concise and accessible manner, about the terms and conditions of use
of the European Business Wallet, including the scope and limitations of core
and additional functionalities, cybersecurity standards, and the European
Business Wallet owner’s rights with regard to data portability, redress, and
termination of service;
(c) ensure that authorised representatives of European Business Wallet owners are
clearly informed, in a user-friendly, concise and accessible manner, about their
rights and obligations in relation to their European Business Wallet unit, in
particular, the right to request revocation of their wallet unit attestation, using
the authentication mechanism provided in point 1 of the Annex;
(d) cooperate with the competent supervisory bodies referred to in Article 13(1), or
with the Commission in the cases referred to in Article 13(10) and 14(1) and
respond without undue delay to any request for information or documentation
necessary to verify compliance with this Regulation;
(e) notify the relevant national supervisory bodies, or the Commission in the cases
referred to in Article 14(1), of any substantive changes to their services or
overall structure which may impact the compliance of the provider with this
Regulation;
(f) notify European Business Wallet owners in the event of suspension, revocation
or voluntary termination of the providers of European Business Wallet`s
services and of the removal of the provider of European Business Wallet from
the list established pursuant to Article 12(5) and ensure the transfer or deletion
of the European Business Wallet owner data in accordance with the European
Business Wallet owners instructions, including European Business Wallet
owner identification data;
(g) ensure that the information on European Business Wallet owners, pursuant to
Article 10(2), is notified to the Commission and that the information initially
submitted to the Commission is kept up to date and corroborated using the
providers of the European Business Wallet owner identification data issuing
the unique identifiers referred to in Article 8(5), point (b).
Article 8
European Business Wallet owner identification data
1. Providers of European Business Wallet owner identification data shall issue
European Business Wallet owner identification data to European Business Wallets of
European Business Wallet owners. Where European Business Wallet owners are
Union entities, the Commission shall issue European Business Wallet owner
identification data to the European Business Wallets of those Union entities.
2. Member States shall notify to the Commission the relevant authentic sources for the
verification of the required attributes for the issuance of the European Business
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Wallet owner identification data. On the basis of the information received pursuant to
this paragraph, the Commission shall make available on the Commission’s website,
in a machine-readable format, a list of the notified relevant authentic sources.
3. European Business Wallet owner identification data shall be issued in a format
compliant with one of the standards listed in Annex II of Commission Implementing
Regulation (EU) 2024/2979 and as:
(a) qualified electronic attestations of attributes, when provided by qualified trust
service providers;
(b) electronic attestations of attributes issued by or on behalf of a public sector
body responsible for an authentic source, when provided by a public sector
body so responsible;
(c) electronic attestations of attributes, when provided by the Commission.
4. European Business Wallet owner identification data issued by the Commission shall
have the same legal effect as qualified electronic attestations of attributes and
attestations of attributes issued by, or on behalf of, a public sector body responsible
for an authentic source.
5. European Business Wallet owner identification data shall contain at least the
following attributes:
(a) the official name of the economic operator or public sector body, as recorded in
the relevant register or official record;
(b) the relevant unique identifier attributed in accordance with Article 9.
6. The Commission shall establish and maintain an attestation scheme for European
Business Wallet owner identification data. That scheme shall be listed in the
catalogue of schemes for the attestation of attributes referred to in Article 8 of
Implementing Regulation (EU) 2025/1569.
7. The Commission may, by means of implementing acts, set out requirements for
European Business Wallet owner identification data issued pursuant to this Article,
including procedures for Member States to notify to the Commission the relevant
authentic sources. Those implementing acts shall be adopted in accordance with the
examination procedure referred to in Article 19.
Article 9
Unique identifiers
1. Where an economic operator has been attributed a European Unique Identifier, that
identifier shall be used as the unique identifier referred to in Article 8(4), point (b) of
this Regulation.
2. Where an economic operator or public sector body has not been attributed a
European Unique Identifier, a unique identifier shall be created in accordance with
the implementing act referred to in paragraph 4.
3. Where a public sector body is a Union entity, the Commission shall create and
attribute a unique identifier to that Union entity in accordance with paragraph 4 of
this Article.
4. The Commission shall, by means of implementing acts, establish specifications,
requirements and procedures relating to the unique identifier referred to in paragraph
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2 of this Article, including measures to ensure that European Business Wallet owners
are not attributed more than one unique identifier. Those implementing acts shall be
adopted in accordance with the examination procedure referred to in Article 19.
Article 10
European Digital Directory
1. The Commission shall establish, operate and maintain a European Digital Directory
which shall act as the trusted source of information for European Business Wallet
owners and shall take the form of a web application comprising of two interfaces:
(a) a machine-readable interface exposed through an API for automated
system-to-system communication;
(b) a secure, web-based platform that provides access to authenticated and
authorised users and system online portal for European Business Wallet
users.
2. For the purpose of maintaining the European Digital Directory, providers of
European Business Wallets shall, upon the provision of a European Business Wallet,
provide to the Commission the categories of information set out in the implementing
act referred to in paragraph 6
3. The Commission shall ensure that the relevant information shall be included in the
European Digital Directory.
4. The Commission shall make the European Digital Directory only accessible to
European Business Wallet owners and their authorised representatives and providers
of European Business Wallets.
5. Any modification or revocation concerning the information referred to in paragraph 2
shall, without undue delay and in any event within one working day, be
communicated by the providers of European Business Wallet directly to the
Commission for the purpose of maintaining the European Digital Directory.
6. The Commission shall, by means of implementing acts, establish standards and
technical specifications for the unique digital addresses and the categories of
information to be communicated to the Commission for the purpose of the European
Digital Directory. Those implementing acts shall be adopted in accordance with the
examination procedure referred to in Article 19.
Article 11
Notification of providers of European Business Wallets
1. Entities that intend to provide European Business Wallets shall notify that intention
together with the information listed in paragraph 2 to the competent supervisory
body.
2. The notification referred to in paragraph 1 shall include the following information:
(a) the entity’s legal name, any commercial names used, website URL,
contact email, telephone number, and physical address;
(b) the entity’s register number issued by a national register, where available
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(c) a description of how the core functionalities, set out in Article 5(1) shall
be offered by the European Business Wallets the entity intends to
provide;
(d) a description of any additional functionalities supported by the European
Business Wallets the entity intends to provide;
(e) a declaration of conformity with the requirements of this Regulation.
3. Qualified trust service providers shall not be subject to the review and verification
procedure set out in paragraphs 4 to 6. Upon submitting the information listed in
paragraph 2, the competent supervisory body shall inform the Commission within
two working days with a view to the addition of that provider to the list referred to in
Article 12(5) and it may immediately offer European Business Wallets.
4. Upon receipt of a notification, the supervisory body shall have 30 days to review the
information submitted.
When that review leads the supervisory body to conclude that the information is
complete and the description referred to in paragraph 2 point (c) appears to
correspond to the requirements laid down in Article 5(1), it shall inform the
Commission within two working days with a view to the addition of that provider to
the list referred to in Article 12(5).
5. When that review leads the supervisory body to conclude that the information is not
complete or the description referred to in paragraph 2 point (c) appears not to
correspond to the requirements laid down in Article 5(1), it shall request additional
information or explanations from the notifying entity and set a reasonable deadline,
not exceeding 15 calendar days, for response. If that information or those
explanations allow the supervisory body to conclude that the information is complete
and the description referred to in paragraph 2 point (c) appears to correspond to the
requirements laid down in Article 5(1), it shall inform the Commission within two
working days with a view to the addition of that provider to the list referred to in
Article 12(5). If not, or no response is received, the supervisory body shall inform the
notifying entity that it will not be added to the list referred to in Article 12(5).
6. Where the supervisory body has not provided the notifying entity with a substantive
response on the outcome of the review referred to in paragraph 4 within 30 calendar
days of receiving the notification, the information shall be considered as complete
and the description referred to in paragraph 2 point (c) shall be considered as
appearing to correspond to the requirements laid down in Article 5(1), and the
supervisory body shall inform the Commission within two working days with a view
to the addition of that provider to the list referred to in Article 12(5)
7. Member States shall ensure that notifying entities have the right to an effective
judicial remedy against a decision of the supervisory authority, without prejudice to
any other administrative or non-judicial remedy, in cases where the supervisory
authority refuses to list them as a provider of European Business Wallets or takes no
decision within a reasonable timeframe.
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Article 12
List of notified providers of European Business Wallets
1. Supervisory bodies shall inform the Commission of any changes to the information
provided pursuant to Article 11, within 24 hours of having become aware of any
changes.
2. The information provided by the supervisory bodies referred to in Article 11 and
Article 12(1) shall include the following:
(a) the purpose of the submission, which may be one of the following:
– the registration of a notified provider of European Business Wallets not
previously present on the list referred to in paragraph 5;
– a change to previously submitted information regarding providers of
European Business Wallets currently present on the list referred to in
paragraph 5;
– a request to remove a provider of European Business Wallets from the
list referred to in paragraph 5;
(b) name and, where applicable, the commercial name of the provider of
European Business Wallets;
(c) the Member State in which the provider of European Business Wallets
has its principal place of establishment;
(d) the name of the competent supervisory body;
(e) an indication whether the provider of European Business Wallets is a
qualified trust service provider.
3. On the basis of the information received pursuant to this Article, the Commission
shall establish and maintain on the Commission’s website, in a machine-readable
format, a list of providers of European Business Wallets.
Article 13
Governance and supervision
1. In each Member State, the supervisory bodies designated pursuant to Article 46a of
Regulation (EU) No 910/2014 shall also be the supervisory bodies for the purposes
of this Regulation.
2. Those supervisory bodies shall be responsible for supervisory tasks as regards
providers of European Business Wallets having their principal place of establishment
in that Member State.
3. Member States shall ensure that the supervisory bodies referred to in paragraph 1
have the necessary powers and adequate resources for the exercise of their tasks in an
effective, efficient and independent manner.
4. The role of national supervisory bodies referred to in paragraph 1 shall be to:
(a) monitor compliance with the requirements laid down in this Regulation and
take action, if necessary, in relation to providers of European Business Wallets,
by means of ex post supervisory activities;
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(b) act as the main liaison office for providers of European Business Wallet owner
identification data, facilitating access to information from relevant national
authorities and registries, where necessary, for the issuance of European
Business Wallet owner identification data and unique identifiers.
5. The tasks of the supervisory bodies referred to in paragraph 1 shall include the
following:
(a) review and assess the notifications submitted in accordance with Article 11;
(b) investigate substantiated claims, particularly those made by European Business
Wallets owners, that a provider of European Business Wallets fails to comply
with any of its obligations under this Regulation and to take action if
necessary;
(c) verify the existence and correct application of termination plans where a
provider of European Business Wallets ceases its activities, including how
information is kept accessible;
(d) ensure that providers of European Business Wallets remedy any failure to fulfil
the requirements laid down in this Regulation;
(e) impose penalties in accordance with paragraphs 6 to 9;
(f) inform the relevant competent authorities designated or established pursuant to
Article 8(1) of Directive (EU) 2022/2555 of the Member States concerned of
any significant security breach or loss of integrity of which it becomes aware in
the performance of its tasks and, in the case of a significant security breach or
loss of integrity which concerns other Member States, to inform the single
point of contact designated or established pursuant to Article 8(3) Directive
(EU) 2022/2555 of the Member State concerned and the single points of
contact designated pursuant to Article 46c(1) of Regulation (EU) No 910/2014
in the other Member States concerned, and to inform the public or require the
provider of European Business Wallets to do so where the supervisory body
determines that disclosure of the breach of security or loss of integrity would
be in the public interest;
(g) cooperate with supervisory authorities established pursuant to Article 51 of
Regulation (EU) 2016/679, in particular, by informing them, without undue
delay, where personal data protection rules appear to have been breached and
about security breaches which appear to constitute personal data breaches;
(h) cooperate, as appropriate, with other national supervisory bodies;
(i) set up and ensure clear publicity of a complaint mechanism whereby
complaints can be filed by providers of European Business Wallets in
accordance with Article 11(7);
(j) report to the Commission on its main activities;
(k) revoke the inclusion in the list established pursuant to Article 12(5) of a
provider of European Business Wallets if the supervisory body determines that
the provider no longer meets the requirements laid down in this Regulation or
that the provider has failed to comply with the obligations imposed by this
Regulation;
(l) cooperate with the supervisory authorities designated pursuant to Article 46b of
Regulation (EU) No 910/2014 by the Member States, in particular, to ensure
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that economic operators established outside the Union are issued only one set
of European Business Wallet owner identification data and European business
Wallet unique identifier.
6. Member States shall lay down the rules allowing the supervisory body referred to in
paragraph 1 of this Article to impose penalties applicable to infringements of this
Regulation and shall take all measures necessary to ensure that they are
implemented. Those penalties shall be effective, proportionate and dissuasive. Those
rules shall not affect Article 31 of Directive (EU) 2022/2555 and Article 83 of
Regulation (EU) 2016/679.
7. By [Publications Office, insert the date 12 months after the entry into force of this
Regulation] Member States shall notify the Commission of the rules laid down by
Member States in accordance with paragraph 6 and shall notify the Commission
without delay of any subsequent amendments to the rules. The Commission shall
regularly update and maintain an easily accessible public register of those rules.
8. Member States shall take into account the following non-exhaustive and indicative
criteria for the imposition of penalties in accordance with paragraph 6:
(a) the nature, gravity, scale and duration of the infringement;
(b) any action taken by the infringing party to mitigate or remedy the damage
caused by the infringement;
(c) any previous infringements by the infringing party;
(d) the financial benefits gained or losses avoided by the infringing party due to
the infringement, insofar as such benefits or losses can be reliably established;
(e) any other aggravating or mitigating factor applicable to the circumstances of
the case;
(f) the infringing party’s total annual turnover in the preceding financial year in
the Union.
Member States shall ensure that infringements of this Regulation committed by
providers of European Business Wallets be subject to administrative fines of a
maximum of 2% of the total worldwide annual turnover in the preceding financial
year.
9. Where the legal system of a Member State does not provide for administrative fines
being imposed by administrative authorities, fines initiated by the supervisory body
and imposed by competent national courts, which have an equivalent effect to the
administrative fines imposed by supervisory bodies, shall be considered to comply
with the requirements laid down in paragraph 6. In any event, the fines imposed shall
be effective, proportionate and dissuasive. That Member State shall notify to the
Commission the provisions of the laws which it adopts pursuant to this paragraph by
[Publications Office, insert the date 12 months after the entry into force of this
Regulation] and, without delay, any subsequent amendment law or amendment
affecting them.
10. In circumstances which justify an immediate intervention to preserve the proper
functioning of the internal market and where the Commission has sufficient reason to
consider that the European Business Wallets provided by a provider are non-
compliant with the requirements laid down in this Regulation and no effective
measures have been taken by the competent supervisory authority, the Commission
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shall carry out an evaluation of compliance. The Commission shall inform the
relevant authorities accordingly and the provider shall cooperate as necessary.
11. Based on the evaluation, the Commission may decide that a corrective or restrictive
measure is necessary, and after consulting the Member States concerned and the
provider, the Commission may determine the appropriate course of action. The
Commission shall take into account the nature and severity of the non-compliance, as
well as the potential impact on the internal market and the rights of economic
operators.
12. On the basis of the consultation, the Commission may adopt implementing acts to
provide for corrective or restrictive measures, including temporarily suspending the
provider from the list of notified providers or requiring the provider to take specific
actions to bring the European Business Wallets into compliance with the Regulation.
Those implementing acts shall be adopted in accordance with the examination
procedure.
13. The Commission shall immediately communicate the implementing acts to the
provider and Member States shall implement those implementing acts without delay
and inform the Commission accordingly. These measures shall be applicable for the
duration of the exceptional situation that justified the Commission’s intervention,
provided that the European Business Wallets concerned are not brought into
compliance with this Regulation.
Article 14
European Digital Identity Cooperation Group
The European Digital Identity Cooperation Group established pursuant to Article 46e of
Regulation (EU) No 910/2014 shall be responsible for facilitating cooperation and
information sharing among Member States and the Commission on matters related to the
European Business Wallets. This shall include sharing best practices, discussing technical and
operational issues, and coordinating efforts to ensure the proper implementation and
functioning of the European Business Wallets.
Article 15
Governance and supervision of Union entities that are providers of European Business
Wallets
1. Where a Union entity is a provider of European Business Wallets the Commission
shall be its supervisory body.
2. The role of the Commission acting as a supervisory body in accordance with
paragraph 1 shall be to monitor compliance with the requirements laid down in this
Regulation and take action, if necessary, in relation to providers of European
Business Wallets, by means of ex post supervisory activities.
3. When acting as a supervisory body in accordance with paragraph 1, the Commission
shall perform the tasks referred to in Article 13(5) points a, b, c, d, h and k.
The Commission shall prepare a report on its main activities in this respect.
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Chapter III – Acceptance of the European Business Wallets
Article 16
Obligations on public sector bodies
4. By [Publications Office, please insert the date 24 months after the entry into force of
this Regulation] public sector bodies shall enable economic operators to take the
following actions by using the core functionalities of European Business Wallets as
set out in Article 5(1):
(a) identify and authenticate;
(b) sign or seal;
(c) submit documents;
(d) send or receive notifications.
The actions listed in points (a) to (d) of the first subparagraph shall take place for the
purpose of meeting a reporting obligation or fulfilling an administrative procedure.
5. For the purposes of paragraph 1, points (c) and (d), public sector bodies shall have
European Business Wallets, including the qualified electronic registered delivery
service referred to in Article 5(1), point (i).
6. By way of derogation from paragraph 2 and until [Publications Office, insert the date
36 months after entry into force of this Regulation], public sector bodies may choose
not to offer the qualified electronic registered delivery service referred to in Article
5(1), point (i), and support instead other existing alternative solutions which enable
economic operators to take the actions listed in paragraph 1, points (c) and (d),
provided those solutions:
(a) comply with the requirements applicable to qualified electronic
registered delivery services set out in Regulation (EU) No 910/2014;
(b) offer a gateway that enables European Business Wallet owners to submit
documents and send and receive notifications using the qualified
electronic registered delivery service referred to in Article 5(1), point (i).
After the expiry of the derogation period laid down in this paragraph, public sector
bodies may continue to support the alternative solutions referred to in that
subparagraph but shall, in accordance with paragraph 2, have European Business
Wallets, including the qualified electronic registered delivery service referred to in
paragraph 1 of Article 5(1), point (i).
Chapter IV - International aspects
Article 17
Business wallets and other similar instruments and frameworks offered in third
countries
1. The Commission may adopt implementing acts establishing that business wallets or
systems offering similar functions that are issued by providers established in third
countries are to be considered as offering assurances that are equivalent to European
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Business Wallets issued in accordance with this Regulation, provided that such
business wallets or systems are interoperable with the trust framework laid down in
Regulation (EU) 910/2014 and allow for the support of at least an identification and
authentication functionality and the exchange of electronic attestations of attributes.
Such implementing acts shall be adopted in accordance with the examination
procedure referred to in Article 19.
2. The Commission may adopt implementing acts establishing that third country
frameworks for systems offering similar functions as the European Business Wallets
are to be considered as offering assurances that are equivalent to European Business
Wallets issued in accordance with this Regulation, provided that the systems
provided under that framework are interoperable with the trust framework laid down
in Regulation (EU) 910/2014 and allow for the support of at least an identification
and authentication functionality and the exchange of electronic attestations of
attributes. Such implementing acts shall be adopted in accordance with the
examination procedure referred to in Article 19.
3. Prior to the adoption of the implementing acts referred to in paragraphs 1 and 2, the
Commission shall assess whether the assurances can be considered as equivalent to
the requirements under this Regulation.
4. The Commission shall, where available information reveals that those assurances can
no longer be considered as equivalent to the requirements under this Regulation, to
the extent necessary, repeal, amend or suspend the act referred to in paragraphs 1 and
2 by means of an implementing act.
5. The Commission shall publish on its website a list of frameworks, business wallets
or systems offering similar functions that are issued by providers established in third
countries in relation to which the Commission has adopted an implementing act
pursuant to this Article.
Article 18
Issuing of European Business Wallets to economic operators established outside the
Union
1. Providers of European Business Wallets may provide European Business Wallets to
economic operators established in a third country under the condition that such
economic operators have been issued European Business Wallet owner identification
data and a unique identifier in accordance with this Article.
2. For the purposes of this Article, economic operators shall request only one set of
European Business Wallet owner identification data from one provider of European
Business Wallet owner identification data.
3. Where an economic operator established outside the Union requests a European
Business Wallet, the provider of European Business Wallets shall notify this request
to the supervisory body of the Member State in which the provider is notified.
4. Providers of European Business Wallets shall request European Business Wallet
owner identification data from a provider of European Business Wallet owner
identification data on behalf of the economic operator established in a third country.
5. Providers of European Business Wallet owner identification data may issue
European Business Wallet owner identification data and unique identifiers pursuant
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to Articles 8 and 9 to economic operators established outside the Union, provided
that:
(a) the identity proofing and verification of those economic operators fulfils one
or, when needed, a combination, of the methods for verification of identity set
out in Article 24 (1a) of Regulation (EU) No 910/2014;
(b) the economic operator has not been issued another set of European Business
Wallet owner identification data.
6. Member States shall cooperate to ensure that providers of European Business Wallet
owner identification data can verify that an economic operator established outside the
Union has not yet been issued European Business Wallet owner identification data.
Chapter V – Final provisions
Article 19
Committee procedure
The Commission shall be assisted by the committee established by Article 48 of Regulation
(EU) No 910/2014. That committee shall be a committee within the meaning of Regulation
(EU) No 182/2011.
Article 20
Amendment to Regulation (EU) No 910/2014
In Regulation (EU) No 910/2014, Article 5a is amended as follows:
(1) paragraph 1 is replaced by the following:
‘1. For the purpose of ensuring that all natural persons in the Union have secure, trusted and
seamless cross-border access to public and private services, while having full control over
their data, each Member State shall provide at least one European Digital Identity Wallet
within 24 months of the date of entry into force of the implementing acts referred to in
paragraph 23 of this Article and in Article 5c(6).’
(2) in paragraph 5 point (f) is replaced by the following:
‘(f) ensure that the person identification data, which is available from the electronic
identification scheme under which the European Digital Identity Wallet is provided, uniquely
represents the natural person or the natural person representing the natural or legal person, and
is associated with that European Digital Identity Wallet;’;
(3) in paragraph 9 point c) is replaced by the following:
‘(c) upon the death of the user.’;
(4) Paragraph 15 is replaced by the following:
’15. The use of European Digital Identity Wallets shall be voluntary. Access to public and
private services, access to the labour market and freedom to conduct business shall not in any
way be restricted or made disadvantageous to natural persons that do not use European Digital
Identity Wallets. It shall remain possible to access public and private services by other
existing identification and authentication means.’.
EN 47 EN
Article 21
Evaluation and review
7. The Commission shall review the application of this Regulation and shall, by
[Publications Office, insert the date – 3 years after entry into force], submit a report
to the European Parliament and to the Council. The report shall evaluate the
effectiveness of the provisions of this Regulation with regard to facilitating the
submission of electronic documents and electronic attestations to public sector
bodies, by the usage of the European Business Wallets, as well as technological,
market, and legal developments. The report shall also assess whether it is necessary
to modify the scope of this Regulation or its specific provisions to set out an
obligation for the use of the European Business Wallets to address the risks of legal
fragmentation.
8. The report referred to in paragraph 1 shall include the following aspects:
(a) the minimum core functionalities of European Business Wallets;
(b) the level of compliance of providers of European Business Wallets and
the notification procedure and criteria established in Article 11;
(c) the application and functioning of the rules on penalties laid down by the
Member States pursuant to Article 13;
(d) the detailed requirements and technical specifications for the qualified
electronic registered delivery service referred to in Article 5(1) point I;
No later than one year before the report referred to in paragraph 1 is due, Member
States shall provide the Commission with the information necessary for the
preparation of the reports.
Article 22
Entry into force and application
This Regulation shall enter into force on the twentieth day following that of its publication in
the Official Journal of the European Union.
It shall apply from [Publications Office, insert the date – 1 year after entry into force].
This Regulation shall be binding in its entirety and directly applicable in all Member States.
Done at Brussels,
For the European Parliament For the Council
The President The President
EN 1 EN
LEGISLATIVE FINANCIAL AND DIGITAL STATEMENT
1. FRAMEWORK OF THE PROPOSAL/INITIATIVE ................................................. 3
1.1. Title of the proposal/initiative ...................................................................................... 3
1.2. Policy area(s) concerned .............................................................................................. 3
1.3. Objective(s) .................................................................................................................. 3
1.3.1. General objective(s) ..................................................................................................... 3
1.3.2. Specific objective(s) ..................................................................................................... 3
1.3.3. Expected result(s) and impact ...................................................................................... 3
1.3.4. Indicators of performance ............................................................................................ 3
1.4. The proposal/initiative relates to: ................................................................................. 4
1.5. Grounds for the proposal/initiative .............................................................................. 4
1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for
roll-out of the implementation of the initiative ............................................................ 4
1.5.2. Added value of EU involvement (it may result from different factors, e.g.
coordination gains, legal certainty, greater effectiveness or complementarities). For
the purposes of this section 'added value of EU involvement' is the value resulting
from EU action, that is additional to the value that would have been otherwise
created by Member States alone. ................................................................................. 4
1.5.3. Lessons learned from similar experiences in the past .................................................. 4
1.5.4. Compatibility with the multiannual financial framework and possible synergies with
other appropriate instruments ....................................................................................... 5
1.5.5. Assessment of the different available financing options, including scope for
redeployment ................................................................................................................ 5
1.6. Duration of the proposal/initiative and of its financial impact .................................... 6
1.7. Method(s) of budget implementation planned ............................................................. 6
2. MANAGEMENT MEASURES................................................................................... 8
2.1. Monitoring and reporting rules .................................................................................... 8
2.2. Management and control system(s) ............................................................................. 8
2.2.1. Justification of the budget implementation method(s), the funding implementation
mechanism(s), the payment modalities and the control strategy proposed .................. 8
2.2.2. Information concerning the risks identified and the internal control system(s) set up
to mitigate them............................................................................................................ 8
2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between
the control costs and the value of the related funds managed), and assessment of the
expected levels of risk of error (at payment & at closure) ........................................... 8
2.3. Measures to prevent fraud and irregularities ................................................................ 9
3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE ............ 10
3.1. Heading(s) of the multiannual financial framework and expenditure budget line(s)
affected ....................................................................................................................... 10
EN 2 EN
3.2. Estimated financial impact of the proposal on appropriations ................................... 12
3.2.1. Summary of estimated impact on operational appropriations.................................... 12
3.2.1.1. Appropriations from voted budget ............................................................................. 12
3.2.1.2. Appropriations from external assigned revenues ....................................................... 17
3.2.2. Estimated output funded from operational appropriations......................................... 22
3.2.3. Summary of estimated impact on administrative appropriations ............................... 24
3.2.3.1. Appropriations from voted budget .............................................................................. 24
3.2.3.2. Appropriations from external assigned revenues ....................................................... 24
3.2.3.3. Total appropriations ................................................................................................... 24
3.2.4. Estimated requirements of human resources.............................................................. 25
3.2.4.1. Financed from voted budget....................................................................................... 25
3.2.4.2. Financed from external assigned revenues ................................................................ 26
3.2.4.3. Total requirements of human resources ..................................................................... 26
3.2.5. Overview of estimated impact on digital technology-related investments ................ 28
3.2.6. Compatibility with the current multiannual financial framework.............................. 28
3.2.7. Third-party contributions ........................................................................................... 28
3.3. Estimated impact on revenue ..................................................................................... 29
4. DIGITAL DIMENSIONS .......................................................................................... 29
4.1. Requirements of digital relevance .............................................................................. 30
4.2. Data ............................................................................................................................ 30
4.3. Digital solutions ......................................................................................................... 31
4.4. Interoperability assessment ........................................................................................ 31
4.5. Measures to support digital implementation .............................................................. 32
EN 3 EN
1. FRAMEWORK OF THE PROPOSAL/INITIATIVE
1.1. Title of the proposal/initiative
Regulation of the European Parliament and the Council on the establishment of the
European Business Wallets
1.2. Policy area(s) concerned
Communications Netwokrs, Content and Technology
Internal Market
1.3. Objective(s)
1.3.1. General objective(s)
The general objective of this initiative is to ensure the proper functioning of the
internal market by meeting economic operators’ and public sector bodies’ specific
needs in the area of digital identification and trust services and providing them with a
harmonised, trusted, and user-friendly instrument for secure and legally valid
identification, authentication and data exchange
1.3.2. Specific objective(s)
Specific objective No 1
Reduce administrative burdens, streamline compliance processes, and improve
service delivery.
Specific objective No 2
To ensure economic operators and public sector bodies have access to secure and
trusted digital identification across borders, meeting user needs and market demand.
1.3.3. Expected result(s) and impact
Specify the effects which the proposal/initiative should have on the beneficiaries/groups targeted.
Overall, the biggest main expected beneficiaries of the initiative are economic
operators and public sector bodies. By establishing a harmonised and trusted digital
framework for business identification, authentication, and document exchange and
storage, the initiative will reduce administrative burdens and compliance costs both
at national and EU level. The European Business Wallets will allow companies to
interact seamlessly with public authorities and business partners across borders,
eliminating repetitive submissions of data and accelerating key processes such as
registration, licensing, and reporting. SMEs and micro-enterprises in particular will
benefit from simplified, secure, and interoperable digital channels, freeing resources
for innovation, growth, and cross-border expansion.
Public sector bodies will gain in efficiency, quality, and reliability of service
delivery. The Business Wallets will streamline administrative procedures by enabling
automation of verification and document handling, reducing manual intervention,
duplication, and error rates. The secure communication channel will improve data
quality and transparency, supporting better regulatory oversight and facilitating the
use of innovative RegTech solutions.
1.3.4. Indicators of performance
Specify the indicators for monitoring progress and achievements.
EN 4 EN
To ensure consistency and proportionality, the monitoring framework draws on the three-
pillar structure referenced in the impact assessment for the revision of the eIDAS Regulation,
implementation, application, and contextual indicators, and adapts it to the specific scope of
the European Business Wallets. This ensures alignment while avoiding duplication of
monitoring obligations and respecting Better Regulation principles, including proportionality
and re-use of existing data streams. Additionally, a set of additinal indicators, specifically
linked to the Specific Objectives will be leveraged to assess the outcomes of the initiative via
proxy-indicators. These broader macro-economic and administrative-burden trends remain
contextual and will be interpreted alongside eIDAS data to support statistical inference rather
than implying direct causality.
The new set of indicators linked to the Specific Objectives is reported underneath:
Monitoring and
evaluation aspect
and relevant
objectives
Indicator(s) Responsibility for
collection Source(s)
SO1: Reduce administrative burdens, streamline compliance processes, and improve service delivery.
To reduce the
administrative burden
of regulatory
compliance and
reporting
requirements on
businesses through
demonstrable
economic benefits
Quantifiable reduction in the
burden of government regulation
indicator
European Commission Single Market and
Competitiveness
Scoreboard 14
To improve public
service delivery
Measured improvements in
Digital Public Services for
Business indicators under the
eGov benchmark, particularly in
respect of online service delivery
and interoperability signifiers
(specific indicators: (cross-
border) online availability;
(cross-border) eID; pre-filled
forms; OOTS)
European Commission eGovernment
benchmark study
feeding the Digital
Decade Policy
Programme
To enhance European
competitiveness
Measurable improvements in the
exports of goods to other EU
countries by SMEs in the
industrial sector (% of SMEs)
European Commission Single Market and
Competitiveness
Scoreboard
SO2: To ensure economic operators and public sector bodies have access to secure and trusted digital
identification across borders, meeting user needs and market demand.
To develop a market
for secure digital
identification and
trust services between
Number of compliant and
notified European Business
Wallet providers, including
Qualified Trust Service Providers
Supervisory bodies Data reported to
European Commission
European Digital
14 Plus any potential KPI on administrative burden reduction following the review of the Digital Decade
Policy Programme
EN 5 EN
Monitoring and
evaluation aspect
and relevant
objectives
Indicator(s) Responsibility for
collection Source(s)
economic operators
and public sector
bodies
Directory
To ensure that
available solutions
are trusted and secure
and comply with all
requirements to
provide European
Business Wallets
Number of withdrawn
authorisations of notified
European Business Wallet
providers, excluding any
providers who have voluntarily
ceased their commercial
provision of business wallets and
related services
Number and level of penalties
imposed on European Business
Wallet providers
Supervisory bodies Data reported to
European Commission
To stimulate adoption
of the European
Business Wallet
across all sectors of
the economy
Number of European Business
Wallets issued to economic
operators and public sector
bodies and registered in the
European Digital Directory 15
European Commission European Digital
Directory
1.4. The proposal/initiative relates to:
a new action
a new action following a pilot project / preparatory action16
the extension of an existing action
a merger or redirection of one or more actions towards another/a new action
1.5. Grounds for the proposal/initiative
1.5.1. Requirement(s) to be met in the short or long term including a detailed timeline for
roll-out of the implementation of the initiative
The Regulation will require public sector bodies to accept European Business Wallets for the
purposes of identification and authentication, signing or sealing documents, submitting
documents, and sending or receiving notifications. Public sector bodies have 24 months after
entry into force of the Regulation to ensure they can accept Business Wallets for these
purposes. For a transition period of up to 36 months after entry into force, public sector bodies
may continue to support other existing communication solutions instead of implementing the
Business Wallets’ communication channel, provided that these solutions comply with
applicable requirements set out in Regulation (EU) 910/2014 and offer a gateway between
these existing solutions and the communication channel of the Business Wallets. After this
15 The number of wallets is not necessarily equivalent to number of owners because one owner attributed
with one unique identifier may have multiple wallets registered to them, but it will be a good
approximation to determine the levels of usage 16 As referred to in Article 58(2), point (a) or (b) of the Financial Regulation.
EN 6 EN
transition period, public sector bodies will have to support the Business Wallets’
communication channel, either instead of or in addition to other eIDAS-compliant solutions.
1.5.2. Added value of EU involvement (it may result from different factors, e.g.
coordination gains, legal certainty, greater effectiveness or complementarities). For
the purposes of this section 'added value of EU involvement' is the value resulting
from EU action, that is additional to the value that would have been otherwise
created by Member States alone.
Reasons for action at EU level (ex-ante)
Divergent national digital identity solutions hinder the freedom of establishment and the
freedom to provide services, undermining the optimal functioning of the Single Market. The
current fragmentation creates duplication, delays, and additional costs for economic
operators especially cross-border. Uneven levels of digitalisation of public sector bodies
may also distort competition, giving economic operators in more advanced Member States a
procedural advantage and weakening the level playing field in the Single Market.
The functioning of the internal market relies on uniform and consistent rules applied across
all relevant public sectors bodies performing equivalent functions or providing comparable
services. The Commission often carry out similar activities to national public sector bodies
and have key supervisory and regulatory roles. Thus, their involvement in supporting the
proper functioning of the Single Market is necessary. Excluding them would create
regulatory gaps, fragmentation and uneven application of the rules, thereby undermining the
Business Wallet’s objective of safeguarding the integrity, stability and resilience of the
internal market. In addition, simplification remains a key driver of the EU’s commitment to
building a bolder, simpler, and faster Union, as outlined in the 2025 Work Programme. A
competitive and well-functioning Single Market requires active participation from both
national and EU-level authorities, with the latter leading by example. Accordingly, the
Commission should adopt and use the European Business Wallet, extending simplification
and efficiency to their interactions with economic operators.
Expected generated EU added value (ex-post)
The European Business Wallets will eliminate duplication and reduce compliance costs,
while also improve transparency, data quality, and provide public sector bodies with more
reliable information, enhancing service delivery. At the same time, EU-level harmonisation
prevents dependency on high-risk providers, strengthens the resilience of critical
infrastructures, and consolidates the Union’s digital sovereignty. Beyond the internal
market, the initiative can also enhance the Union’s role as a global standard-setter for trusted
digital infrastructures, supporting European competitiveness in international trade.
1.5.3. Lessons learned from similar experiences in the past
The European Business Wallets proposal builds on and extends the ecosystem of trust
established under the European Digital Identity Framework - Regulation (EU) 910/2014, the
legal reference in the EU on electronic identification and trust services for electronic
transactions in the internal market, as amended by Regulation (EU) 2024/1183. This
frameowrk - a state-of-the-art, privacy-friendly and interoperable system for digital
identification empowering citizens and legal entities to share data securely across borders -
represents already a major milestone in the EU simplification agenda.
The European Business Wallets proposal aims at complementing the European Digital
Identity Wallets by introducing a market-driven digital framework designed for the specific
needs of businesses transactions, including treceability, the digital management of
EN 7 EN
representation rights and mandates, and a secure channel for exchanging official documents
and attestations supported by a common directory. All this will be achieved while
guaranteeing full interoperability with the European Digital Identity Wallets
Recent technological and societal developments require a new harmonsied and digital
approach to business-to-governement and business-to-business interactions. AI, cloud
computing and secure digital identity are moving at an unprecedented pace, affecting the
way of doing business in Europe: processes have shifted from being document-based to
automated and data-driven. For instance, 91% of scaleups consider digital technologies
critical to their growth. These developments, combined with the EU’s strategic priorities for
competitiveness, digital sovereignity, simplification and digital-by-default public services,
create the need for agile solutions that can support trusted cross-border business transactions
at scale.
As a consequence, the demand for means to identify and exchange and store different
business credentials, securely and with full legal effect across border has increased radically.
The Regulation also builds on the achievements of Directive (EU) 2025/25, which
introduced the EU Company Certificate and digital EU power of attorney. These pioneering
tools aim to ease administrative burdens in cross-border operations for Union companies by
reducing fragmentation. This regulation takes the next step to offer a tool for enabling
companies to seamlessly exchange EU Company Certificates and digital powers of attorneys
via European Business Wallets.
1.5.4. Compatibility with the multiannual financial framework and possible synergies with
other appropriate instruments
The initiative supports the EU’s simplification and competitiveness goals by providing
economic operators with tools such as the Business Wallets, enabling trusted, secure, and
user-friendly compliance with administrative requirements through harmonised
identification, authentication, and data exchange. Hence, it is fully in line with the
objectives of the MFF.
The inclusion of the Commission will have financial implications, which will be
predominantly covered by the EU budget under the Multiannual Financial Framework
(MFF) 2028-2034. These costs are mainly associated with the implementation and use of
the European Business Wallets, the establishment and maintenance of the European Digital
Directory within the Commission, the integration of these with existing IT systems and the
establishment of supervisory activities related to the European Business Wallets.
The estimated direct costs for the Commission as user amount to approximately €7 million
during the first year due to expenditure for initial implementation (procurement process),
licensing fee and maintenance costs for the European Business Wallet. As of the second
year, the Commission will incur additional €5 million in recurring annual costs. For the
European Digital Directory, the setup cost is estimated at just under €2 million, with
annual maintenance costs projected at €1.7 million in the second year and €1.3 million in
subsequent years.
In addition, potential costs for integrating the Business Wallets into all the relevant IT
systems are estimated at €33.8 million for the first year and €7.5 million for the second
year. As the systems are already in place, the costs are related to the first two years as it is
an integration and not a development of a new system.
Synergies with other instruments are illustrated as follows:
EN 8 EN
- The Single Digital Gateway (SDG) and its Once-Only Technical System (OOTS)
implement the “once-only” principle, requiring authorities to reuse data already held in
another Member State without repeated submissions by businesses. The European
Business Wallets will complement the SDG and OOTS by providing trusted identification
and authentication of economic operators and public administrations and a secure
exchange layer that enables businesses and public sector bodies to share and reuse verified
data and official attestations seamlessly across borders.
- The Digital Product Passport (DPP), central to the EU’s circular economy agenda,
depends on trusted access to conformity and sustainability data. The Business Wallets can
prove legal identity and any granted access rights, allow conformity declarations to be
signed and sealed, and ensure product data is exchanged securely and verifiably across
borders.
- The Interoperable Europe Act (IEA) establishes the framework for cross-border
interoperability of public services. The Business Wallets will complement this by serving
as a trusted infrastructure that administrations can integrate into digital-by-default service
delivery, reinforcing the removal of technical and organisational barriers.
- The upcoming proposal on the 28th Regime corporate legal framework will provide
simple, flexible and fast procedures for companies to set up and operate and attract
investment in the EU through digital solutions. It will ensure inter-operability with the
business wallet and ensure that digital tools such as the EU Company certificate and the
EU digital Power of Attorney are compatible with the Business Wallet so that companies
can use these with their Business Wallet.
- The VAT in the Digital Age (ViDA) package modernises VAT reporting, introduces
mandatory e-invoicing across borders and strengthens fraud prevention. The Business
Wallets will enable secure storage and verifiable exchange of VAT attestations and
transaction data, thereby supporting real-time reporting and trusted invoicing.
1.5.5. Assessment of the different available financing options, including scope for
redeployment
The staff requested in the amount of 20 FTEs will be redeployed by existing allocations of
the DG that is assigned to the management of the action or other Commission services.
EN 9 EN
1.6. Duration of the proposal/initiative and of its financial impact
limited duration
– in effect from [DD/MM]YYYY to [DD/MM]YYYY
– financial impact from YYYY to YYYY for commitment appropriations and
from YYYY to YYYY for payment appropriations.
unlimited duration
– Implementation with a start-up period from 2028 to 2029,
– followed by full-scale operation.
1.7. Method(s) of budget implementation planned
Direct management by the Commission
– by its departments, including by its staff in the Union delegations;
– by the executive agencies
Shared management with the Member States
Indirect management by entrusting budget implementation tasks to:
– third countries or the bodies they have designated
– international organisations and their agencies (to be specified)
– the European Investment Bank and the European Investment Fund
– bodies referred to in Articles 70 and 71 of the Financial Regulation
– public law bodies
– bodies governed by private law with a public service mission to the extent that
they are provided with adequate financial guarantees
– bodies governed by the private law of a Member State that are entrusted with
the implementation of a public-private partnership and that are provided with
adequate financial guarantees
– bodies or persons entrusted with the implementation of specific actions in the
common foreign and security policy pursuant to Title V of the Treaty on
European Union, and identified in the relevant basic act
– bodies established in a Member State, governed by the private law of a
Member State or Union law and eligible to be entrusted, in accordance with
sector-specific rules, with the implementation of Union funds or budgetary
guarantees, to the extent that such bodies are controlled by public law bodies or
by bodies governed by private law with a public service mission, and are provided
with adequate financial guarantees in the form of joint and several liability by the
controlling bodies or equivalent financial guarantees and which may be, for each
action, limited to the maximum amount of the Union support.
EN 10 EN
2. MANAGEMENT MEASURES
2.1. Monitoring and reporting rules
The Regulation will be reviewed threer years after its full application. The
Commission must report on the findings to the European Parliament and to the
Council.
2.2. Management and control system(s)
2.2.1. Justification of the budget implementation method(s), the funding implementation
mechanism(s), the payment modalities and the control strategy proposed
The Regulation establishes harmonised rules for the provision of eID and QERDS to
economic operators and public sector bodies in the internal market while ensuring
the respect of trust and users’ control over their own data. These new rules require
the development of technical specifications and standards, and supervision and
coordination of the activities of European Union Institutions, Bodies, Offices and
Agencies.
In addition, there is also a need to take into consideration the resources needed to
communicate and coordinate with third countries on interoperability and equivalence
of third country solutions.
In order to face these tasks, it is necessary to appropriately resource the
Commission’s services. The enforcement of the provisions of the new Regulation is
estimated to require 20 FTEs.
2.2.2. Information concerning the risks identified and the internal control system(s) set up
to mitigate them
One of the main issues leading to shortcomings in the current legislative framework
is the lack of harmonisation of national systems in the context of business-to-
government interactions, which results in red tape and administrative burdens,
particularly across borders. To mitigate this issue, the initiative builds on early
engagement with potential providers and coordination with ongoing Large-Scale
Pilots to ensure technological readiness and interoperability. In parallel, close
cooperation with Member States and related EU initiatives will help prevent further
fragmentation and foster a coherent, competitive, and trusted provider ecosystem
within the Single Market.
2.2.3. Estimation and justification of the cost-effectiveness of the controls (ratio between
the control costs and the value of the related funds managed), and assessment of the
expected levels of risk of error (at payment & at closure)
For the meeting expenditure of the expert group, given the low value per transaction
(e.g. refunding travel costs for a delegate for a meeting if the meeting is physical),
standard internal control procedures seem sufficient.
Also for pilot projects, DG CNECT standard procedures should be sufficient.
2.3. Measures to prevent fraud and irregularities
The existing fraud prevention measures applicable to the Commission will cover the
additional appropriations necessary for this Regulation.
EN 11 EN
3. ESTIMATED FINANCIAL IMPACT OF THE PROPOSAL/INITIATIVE
3.1. Heading(s) of the multiannual financial framework and expenditure budget
line(s) affected
• Existing budget lines
In order of multiannual financial framework headings and budget lines.
Heading of
multiannual
financial
framework
Budget line Type of
expenditure Contribution
Number
Diff./Non-
diff. 17
from
EFTA
countries 18
from
candidate
countries
and
potential
candidates 19
From
other
third
countries
other assigned
revenue
MFF headings and budget lines to be
determined 20
Diff./Non
-diff. YES/NO YES/NO YES/NO YES/NO
[XX.YY.YY.YY]
Diff./Non
-diff. YES/NO YES/NO YES/NO YES/NO
[XX.YY.YY.YY]
Diff./Non
-diff. YES/NO YES/NO YES/NO YES/NO
• New budget lines requested
In order of multiannual financial framework headings and budget lines.
Heading of
multiannual
financial
framework
Budget line Type of
expenditure Contribution
Number
Diff./Non-
diff.
from
EFTA
countries
from
candidate
countries
and
potential
candidates
from
other
third
countries
other assigned
revenue
[XX.YY.YY.YY]
Diff./Non
-diff. YES/NO YES/NO YES/NO YES/NO
17 Diff. = Differentiated appropriations / Non-diff. = Non-differentiated appropriations. 18 EFTA: European Free Trade Association. 19 Candidate countries and, where applicable, potential candidates from the Western Balkans. 20 Budget lines for the new MFF are not yet known.
EN 12 EN
[XX.YY.YY.YY]
Diff./Non
-diff. YES/NO YES/NO YES/NO YES/NO
[XX.YY.YY.YY]
Diff./Non
-diff. YES/NO YES/NO YES/NO YES/NO
EN 13 EN
3.2. Estimated financial impact of the proposal on appropriations
3.2.1. Summary of estimated impact on operational appropriations
– The proposal/initiative does not require the use of operational appropriations
– The proposal/initiative requires the use of operational appropriations, as explained below
– The amounts indicated are strictly indicative, pending the final outcome of the MFF negotiations 2028-2034.
– This initiative will be financed by redeployment within the operational programmes of the next MFF, and partially by administrative
expenditure. At this stage, it is not possible to indicate accurately the contribution from each MFF heading and programme, while it is
expected that a significant contribution will come from programmes under heading 2 of the 2028-2034 MFF (e.g. the European
Competitiveness Fund).
–
3.2.1.1. Appropriations from voted budget
EUR million (to three decimal places)
First Year
Second
Year
Following
Years
(yearly
amount)
TOTAL
appropriations under
HEADINGS 1 to 4
Commitments 45,442 16,867 8,929
of the multiannual
financial framework Payments 45,442 16,867 8,929
The figures as shown in the table above arestrictly indicative pending the outcome of the MFF negotiations.
EN 14 EN
First Year Second Year
Following Years
(yearly amount)
TOTAL
appropriations
under HEADINGS
1 to 4
Commitments 45.442 16.867 8.929
of the multiannual
financial framework Payments 45.442 16.867 8.929
The figures as shown in the table above are strictly indicative pending the outcome of the MFF negotiations.
3.2.2. Estimated output funded from operational appropriations (not to be completed for decentralised agencies)
Commitment appropriations in EUR million (to three decimal places)
Indicate
objectives and
outputs
Year 2028
Year 2029
Year 2030
Year 2031
Enter as many years as necessary to show the
duration of the impact (see Section1.6) TOTAL
OUTPUTS
EN 15 EN
Type21
Avera
ge
cost
N o
Cost N o
Cost N o
Cost N o
Cost N o
Cost N o
Cost N o
Cost Total
No
Total
cost
SPECIFIC OBJECTIVE No 122…
- Output
- Output
- Output
Subtotal for specific objective No 1
SPECIFIC OBJECTIVE No 2 ...
- Output
Subtotal for specific objective No 2
TOTALS
21 Outputs are products and services to be supplied (e.g. number of student exchanges financed, number of km of roads built, etc.). 22 As described in Section 1.3.2. ‘Specific objective(s)’
EN 16 EN
3.2.3. Summary of estimated impact on administrative appropriations
– The proposal/initiative does not require the use of appropriations of an
administrative nature
– The proposal/initiative requires the use of appropriations of an administrative
nature, as explained below
3.2.3.1. Appropriations from voted budget
EUR million (to three decimal places)
VOTED
APPROPRIATIONS
First Year Second Year Following Years
(yearly amount)
Human resources 2.629 2.629 2.629
Other administrative
expenditure pm pm pm
TOTAL 2.629 2.629 2.629
The figures in the table above are all strictly indicative pending the outcome of the MFF negotiations.
The appropriations required for human resources and other expenditure of an administrative nature
will be met by appropriations from the DG that are already assigned to management of the action
and/or have been redeployed within the DG, together, if necessary, with any additional allocation
which may be granted to the managing DG under the annual allocation procedure and in the light of
budgetary constraints.
3.2.4. Estimated requirements of human resources
– The proposal/initiative does not require the use of human resources
– The proposal/initiative requires the use of human resources, as explained below
EN 17 EN
3.2.4.1. Financed from voted budget
Estimate to be expressed in full-time equivalent units (FTEs)
VOTED APPROPRIATIONS First Year Second Year Following Years
Ÿ Establishment plan posts
(officials and
temporary staff)
20 01 02 01 (Headquarters and
Commission’s
Representation Offices)
7 7 7
20 01 02 03 (EU Delegations) 0 0 0
(Indirect research) 0 0 0
(Direct research) 0 0 0
Other budget lines (specify) 0 0 0
• External staff (inFTEs)
20 02 01 (AC, END from the
‘global envelope’) 13 13 13
20 02 03 (AC, AL, END and JPD
in the EU Delegations) 0 0 0
Admin.
Sup
port
line
- at
Headquarters 0 0 0
[XX.01.YY.YY] - in EU
Delegations 0 0 0
(AC, END - Indirect research) 0 0 0
(AC, END - Direct research) 0 0 0
Other budget lines (specify) -
Heading 4 0 0 0
Other budget lines (specify) -
Outside Heading 4 0 0 0
TOTAL 20 20 20
Considering the overall strained situation in Heading 4, in terms of both staffing and the level of
appropriations, the human resources required will be met by staff from the DG who are already
assigned to the management of the action and/or have been redeployed within the DG or other
Commission services.
The staff required to implement the proposal (in FTEs):
EN 18 EN
To be covered by
current staff
available in the
Commission
services
Exceptional additional staff*
To be financed
under Heading 4
or Research
To be financed
from BA line
To be financed
from fees
Establishment
plan posts
7 N/A
External staff
(CA, SNEs, INT)
13
Description of tasks to be carried out by:
Officials and temporary staff The tasks to be carried out by the officials and temporary staff pertain the legal
workstream, the technical workstream, the coordination and international outreach and
the supervisory role.
External staff The tasks to be carried out by the external staff pertain the legal workstream, the
technical workstream, the coordination and international outreach and the supervisory
role.
3.2.5. Overview of estimated impact on digital technology-related investments
Compulsory: the best estimate of the digital technology-related investments entailed
by the proposal/initiative should be included in the table below.
This expenditure refers to the operational budget to be used to re-use/ buy/ develop
IT platforms/ tools directly linked to the implementation of the initiative and their
associated investments (e.g. licences, studies, data storage etc). The information
provided in this table should be consistent with details presented under Section 4
“Digital dimensions”.
TOTAL
Digital and IT
appropriations
First
Year
Second
Year
Following
Years
IT expenditure 42,813 14,238 6,300
3.2.6. Compatibility with the current multiannual financial framework
The proposal/initiative:
– can be fully financed through redeployment within the relevant heading of the
proposed multiannual financial framework (MFF) 2028-2034
– requires use of the unallocated margin under the relevant heading of the MFF
and/or use of the special instruments as defined in the MFF Regulation
EN 19 EN
– requires a revision of the MFF
3.2.7. Third-party contributions
The proposal/initiative:
– does not provide for co-financing by third parties
– provides for the co-financing by third parties estimated below:
Appropriations in EUR million (to three decimal places)
Year 2024
Year 2025
Year 2026
Year 2027
Total
Specify the co-financing body
TOTAL appropriations co-
financed
3.3. Estimated impact on revenue
– The proposal/initiative has no financial impact on revenue.
– The proposal/initiative has the following financial impact:
– on own resources
– on other revenue
– please indicate, if the revenue is assigned to expenditure lines
EUR million (to three decimal places)
Budget revenue line:
Appropriations
available for the
current financial
year
Impact of the proposal/initiative23
Year 2024 Year 2025 Year 2026 Year 2027
Article ………….
For assigned revenue, specify the budget expenditure line(s) affected.
Other remarks (e.g. method/formula used for calculating the impact on revenue or
any other information).
23 As regards traditional own resources (customs duties, sugar levies), the amounts indicated must be net
amounts, i.e. gross amounts after deduction of 20% for collection costs.
EN 1 EN
9. 4. DIGITAL DIMENSIONS
4.1. Requirements of digital relevance
If the policy initiative is assessed as having no requirement of digital relevance:
Justification of why digital means cannot be used to enhance policy implementation and why the ‘digital by default’ principle is not
applicable
N/A
Otherwise:
High-level description of the requirements of digital relevance and related categories (data, process digitalisation & automation, digital
solutions and/or digital public services)
Reference to the
requirement Requirement description
Actors affected or concerned
by the requirement High-level Processes Categories
Article 4 Principle of equivalence
European Business Wallet
owners
Self-employed persons
Sole traders
Union entities
Use of the EBW and
the qualified
electronic registered
delivery service as
digital solutions
Process
digitalisation
Digital solutions
Digital public
service
Article
5(1),(2),(3),(4)
European Business Wallet (EBW)
functionalities
Providers of European Business
Wallets
European Business Wallet
owners
Authorised representatives of
European Business Wallet
owners
Business Wallet-relying parties
IT development (core
functionalities)
Digital solutions
Digital public
service
Process
digitalisation
EN 2 EN
Article 6(1),(2),(4) Technical features for European
Business Wallets
Providers of European Business
Wallets
European Business Wallet
owners
Business Wallet-relying parties
IT development
(technical features)
Data
Digital solutions
Digital public
service
Article 6(3) Making available information notified European Commission
General Public
Publish validation
mechanisms
Data
Process automation
Digital public
service
Article 6(5) Establish a set of reference standards
and specifications
European Commission Development of
implementing acts
Digital public
service
Article 7 Requirements and obligations for
providers of European Business Wallets
Providers of European Business
Wallets
European Business Wallet
owners
Authorised representatives of
European Business Wallet
owners
Competent supervisory bodies
The European Commission
Establishing
requirements and
obligations for
providers of
European Business
Wallets
Digital solutions
Data
Digital public
service
Process
digitalisation
Article 8 European Business Wallet owner
identification data
Providers of European Business
Wallet identification data
European Business Wallet
owners
EU entities
Management of
owner identification
data pertaining to
EBW owners
Data
Digital public
service
EN 3 EN
The European Commission
Article 9 Unique identifiers for EBW owners Providers of European Business
Wallet owner identification
data
Economic operators
Public sector bodies
The European Commission
Allocation of unique
identifiers for
European Business
Wallet owners
Data
Digital solutions
Digital public
services
Article 10 European Digital Directory The European Commission
Providers of European Business
Wallets
European Business Wallet
owners
Establishment,
operation, and
maintenance of the
European Digital
Directory
Digital solutions
Data
Digital public
service
Article 11 Notification of providers of European
Business Wallets
Providers of European Business
Wallets
Supervisory body in the
Member State of establishment
Notification
procedure for
providers of EBW
Data
Digital public
service
Article 12 Notification of providers of European
Business Wallets by the Member States
to the European Commission
Member States
The European Commission
Notification
Publication
Digital solutions
Digital public
service
Data
Article 13 Member State supervision Supervisory bodies in each
Member State
The European Commission
Supervision of EBW
providers
Notification of
Data
Digital public
service
EN 4 EN
Providers of European Business
Wallets
relevant national
registries
Article 14 European Digital Identity Cooperation
Group extension of support to EBW
European Digital Identity
Cooperation Group
The European Commission
Member States
Information exchange
and coordination
Digital public
service
Article 15 Governance and supervision of Union
entities that are providers of European
Business Wallets (reports)
Data
Article 16 Obligations on public sector bodies to
enable the use of the EBW and provide a
Qualified Electronic Registered Delivery
Service (QERDS)
Public sector bodies
European Business Wallet
owners
Providers of European Business
Wallets
Identification
Authentication
Signature and Seal
Submission of
documents
Notification
Digital solutions
Digital public
service
Process
digitalisation
Article 17 List of Business Wallets and other
similar instruments offered in third
countries
The European Commission
Non-EU countries
Publication of
equivalent systems
from third countries
Data
Digital solutions
Digital public
service
Article 18 Issuing of European Business Wallets to
economic operators established outside
the Union
Providers of European Business
Wallets
Economic operators established
in a third country
Qualified trust service
providers established in a
Issuance of European
business wallets
Identity proofing and
verification
Data
Digital solution
Digital public
service
EN 5 EN
Member State
Member States of the qualified
trust service providers
Article 20 Removal of legal persons from
Regulation (EU) 910/2014, due to
obsolescence with advent of EBW
Legal person
Member states
Legal person
identification,
authentication and
data sharing
Digital public
service
Digital solution
Data
EN 6 EN
4.2. Data
High-level description of the data in scope
Type of data Reference to the requirement(s) Standard and/or specification (if applicable)
//
EBW owner identification data Article 8(1) EBW owner identification data shall be issued in a
format according to one of the standards listed in
Annex II of Commission Implementing Regulation
(EU) 2024/2979 and as:
- QEAA when provided by qualified trust
service providers;
- EAA when issued by or on behalf of a public
sector body responsible for an authentic
source, when provided by a public sector
body;
- EAA when provided by the Commission.
EAA/QEAA (Electronic Attestations of Attributes /
Qualified Electronic Attestations of Attributes)
Article 8(1) Issuer requirements: For QEAA, the issuer must be a
Qualified Trust Service Provider, satisfying legal and
technical requirements.
Standards / formats: The attestations must follow the
schemas / formats prescribed (within ARF / toolbox)
for attribute attestations. The attributes themselves
must be accurate, derived from authentic sources.
Interoperability, trust / verification: Relying parties
might be able to verify them, there must be
revocation / suspension mechanics, and trust
infrastructure must ensure their validity.
Regulation (EU) 2024/1183 (eIDAS 2.0) - Annex V;
ETSI TS 119 471; ETSI EN 319 412 (series); ETSI
EN 7 EN
TS 119 182-1; ETSI TS 119 102-1; ETSI TS 119
102-2; ETSI EN 319 401; ETSI EN 319 411-1 / 411-
2; ETSI TS 119 461; ETSI TS 119 172-4; CEN/EN
319 521
EBW owner identification data elements Article 8(6) Must contain at least the following attributes: the
official name of the economic operator or public
sector body, as recorded in the relevant register or
official record, the relevant unique identifier
attributed in accordance with Article 9.
Unique identifiers for EBW owners (EUID) Article 9(1) EUID identifier must be used if an economic operator
falls within the scope of Directive (EU) 2017/1132 or
Directive (EU) 2015/849
Information for the purpose of maintaining the
EDD
Article 10(3)(6) Standards and technical specifications for the EDD to
be established in the implementing acts to be adopted
Notification of providers of EBW Article 11(2) Lists elements to be included in the notification
List of notified providers of EBW Article 12 Machine readable format
List of MS supervisory bodies Article 13(3) Data elements to be included: names and addresses
Information on national registries holding
information on economic operators and public
sector bodies
Article 13(5)(f) Not specified
List of Business Wallets and other similar
instruments offered in third countries
Article 17(4) Not specified
EBW owner’s data for portability purposes
Annex Open format
EN 8 EN
Alignment with the European Data Strategy
Explanation of how the requirement(s) are aligned with the European Data Strategy
The proposal aligns with the European Data Strategy by implementing data-driven approach to innovation and enhancing the digital economy.
It aims to reduce administrative burdens, streamline compliance processes, and improve service delivery through the provision of market-
driven solutions, further enhancing competitiveness. The European Business Wallets facilitate seamless information exchange across borders
in a transparent, trustworthy and secure way. The proposal promotes interoperability and compatibility with the existing systems.
Alignment with the once-only principle
Explanation of how the once-only principle has been considered and how the possibility to reuse existing data has been explored
The proposal promotes the once-only principle by requiring authorities to reuse data already held in another MS without need for the repeated
submissions by businesses. The European Business Wallets will complement the SDG and OOTS by providing trusted identification and
authentication of economic operators and public administrations and a secure exchange layer that enables businesses and public sector bodies
to share, and reuse verified data and official attestations seamlessly across borders. Additionally, while the OOTS focuses on the interactions
among Public Sector Bodies (G2G), the European Business Wallets is focusing the on the interactions between Public Sector Bodies and
economic operators (B2G) and between economic operators (B2B).
Explanation of how newly created data is findable, accessible, interoperable and reusable, and meets high-quality standards
Newly created European Business Wallets data adheres to the FAIR principles by employing standards and specifications enhancing
searchability and secure access. It is also designed to seamlessly integrate with a larger European Digital Identity Framework defined under
eIDAS.
Data flows
High-level description of the data flows
Type of data Reference(s) to
the
requirement(s)
Actors who
provide the data
Actors who
receive the data
Trigger for the
data exchange
Frequency (if
applicable)
EN 9 EN
Information on validation
mechanisms
Article 6(2)(g) Providers of EBW The Commission Without undue delay //
Information on validation
mechanisms
Article 6(3) The Commission General public Notification from
the provider of EBW
//
Notification about terms, conditions
rights and obligations related to the
EBW
Article 7(6)(b)(c) Providers of EBW EBW owners/
representatives of
EBW owners
Use of EBW //
Notification about substantive
changes to the EBW service
Article 7(6)(e) Providers of EBW National
supervisory body
or the Commission
// //
Notification about the suspension,
revocation or voluntary termination
of EBW service
Article 7(6)(f) Providers of EBW EBW owners // //
Information on EBW owners (and
subsequent changes)
Article 7(6)(g) Providers of EBW The Commission // //
EBW owner identification data Article 8(1) Providers of EBW
identification data
EBW owner Request of the EBW
owner
once
EAA/QEAA (Electronic Attestations
of Attributes / Qualified Electronic
Attestations of Attributes)
Article 8 (Q)EAA providers EBW owner Request of the EBW
owner
Upon request
Notification on the national registers
and associated registration numbers
Article 9(6) MS The Commission No later than 3
months after the
entry into force
//
EN 10 EN
Information for the purpose of
maintaining the EDD
Article 10(3)(6) Provider of EBW The Commission Upon issuance of the
EBW (for the
purpose of
maintaining the
EDD)
//
Notification on providers of EBW Article 11(1) Notifying entity MS Supervisory
body
// //
Notification on providers of EBW Article
11(4)(5)(6)
MS Supervisory
bodies
Notifying entity Notification sent by
notifying entity – 30
days
//
List of notified providers of EBW Article 12
(1)(2)(3)
MS The Commission 24 hours 4 hours of
the expiration of the
30-day period
referred to in Article
11
//
List of MS supervisory bodies Article 13(3) MS The Commission // //
List of MS supervisory bodies Article 13(3) The Commission General public // //
Information on national registries Article 13(5)(f) MS Supervisory
bodies
The Commission // //
Reporting obligations on the main
activities
Article 13(5)(k) MS Supervisory
bodies
The Commission // //
List of Business Wallets and other
similar instruments offered in third
countries
Article 17(4) The Commission General public // //
EN 11 EN
4.3. Digital solutions
High-level description of digital solutions
Digital
solution
Reference(s) to
the
requirement(s)
Main mandated functionalities Responsible
body
How is
accessibility
catered for?
How is reusability
considered?
Use of AI
technologies
(if
applicable)
European
Business
Wallet
Article 4
Article
5(1),(3),(5)
Article
6(1),(2),(4)
Article 7
Article 9
Article 16
Article
17(1),(3)
Article 18
Annex
Providers of European Business
Wallets shall ensure that the European
Business Wallets they provide enable
European Business Wallet owners, at
a minimum, to:
(10) securely issue, request,
obtain, select, combine, store,
delete, share and present
electronic attestations of
attributes;
(1) selectively disclose
European Business
Wallet owner
identification data and
attributes contained in
electronic attestations
of attributes, in the
context of the
functionalities listed
under point a;
(2) request and share
European Business
Wallet owner
identification data and
electronic attestations
Providers of
the
European
Business
Wallet
The
standards and
specification
that will be
defined in the
implementing
acts will refer
to
accessibility
requirements
as it was the
case for the
EUDIW.
However, it
is important
to consider
that the
solution
providers
will be the
private sector
and as such
their will
need to
comply with
the
Accessibility
Emphasis on open
standards,
interoperability,
and data portability
ensures that the
Wallets can be
reused or
integrated across
various platforms
and services
without vendor
lock-in.
Additionally, the
Business Wallet is
reusing the EU
Digital Identity
Framework and
compatibility with
the EUDIW is
prescribed.
N/A
EN 12 EN
of attributes in a
secured way between
European Business
Wallets and European
Digital Identity Wallets
and with European
Business Wallet-relying
parties;
(3) sign by means of
qualified electronic
signatures and seal by
means of qualified
electronic seals, as
applicable;
(4) bind data in electronic
form to a particular
time by means of
qualified electronic
time stamps;
(5) issue electronic
attestations of attributes
to European Business
Wallets and European
Digital Identity
Wallets;
(6) issue electronic
attestations of attributes
through the European
Business Wallet of the
owner, allowing the
issued attestation to be
linked to other relevant
Directive
2019/882.
EN 13 EN
attestations forming
part of a chain.
(7) enable the use of
qualified and non-
qualified attestations of
attributes to allow
European Business
Wallet owners and their
legal representatives to
authenticate
(8) transmit and receive
electronic documents
and data by means of a
qualified electronic
registered delivery
service able to support
confidentiality;
(9) authorise multiple users
to access and operate
the European Business
Wallet of the owner,
and for the Business
Wallet owner to
manage and revoke
such authorisations;
(10) authorise European
Business Wallet-relying
parties to request
electronic attestations
of attributes issued to
the owner of the
European Business
EN 14 EN
Wallet, and for the
Business Wallet owner
to manage and revoke
such authorisations;
(11) exercise the European
Business Wallet
owner’s right to data
portability and export
their data, including
issued European
Business Wallet owner
identification data,
electronic attestations
of attributes,
communication logs,
and interaction records,
in a structured,
commonly used and
machine-readable
format, at the request of
the owner or in the
event of termination of
service or revocation of
the notification of the
provider of the
European Business
Wallet;
(12) access a log of all
transactions;
(13) access a common
dashboard for
accessing, storing and
verifying
EN 15 EN
communications
exchanged through the
qualified electronic
registered delivery
service referred to in
point (i).
European
Digital
Directory
Article 10 The Commission shall establish,
operate and maintain a European
Digital Directory as a web application
comprising of two interfaces:
• a machine-readable interface
exposed through an API for
automated system-to-system
communication;
• an online portal for European
Business Wallets users, built on
and communicating with the API,
ensuring consistency between both
interfaces.
European
Commission
- N/A
Signature
creation
applications
Annex Signing or sealing data provided by
European Business Wallets users.
Signing or sealing data provided by
relying parties.
Creating signatures or seals in
accordance with at least the
mandatory format.
Creating signatures or seals in
accordance with the optional format.
Informing Wallets users about the
result of the signature or seal creation
European
Business
Wallets
providers
Providers of
trust
services
Business-
Wallet-
relying
parties
- -
EN 16 EN
process.
Qualified
electronic
registered
delivery
service
Annex In line with Article 5 of this
Regulation, Business Wallets shall
integrate and support the use of a
specific qualified electronic registered
delivery service in accordance with
Articles 43 and 44 of Regulation (EU)
No 910/2014.
Interoperability between Business
Wallets and the designated qualified
electronic registered delivery service
shall be mandatory. Providers of
Business Wallets shall ensure
technical integration in accordance
with the implementing acts.
European
Commission
- -
For each digital solution, explanation of how the digital solution complies with applicable digital policies and legislative enactments
European Business Wallet
Digital and/or sectorial policy
(when these are applicable)
Explanation on how it aligns
AI Act N/A
EU Cybersecurity framework Providers of the European Business Wallets shall ensure integrity, authenticity, and confidentiality of the
communication between the Business Wallet’s back-end, front-end and secure cryptographic applications
and device.
Providers of the European Business wallets shall also comply with the requirements of Directive (EU)
2022/2555 of the European Parliament and of the Council on measures for a high common level of
cybersecurity across the Union.
EN 17 EN
eIDAS The European Business Wallet builds on the European Digital Identity Framework defined under eIDAS and
it expands it to all economic operators and public sector bodies.
Access to the European Business Wallets Unit shall be granted only after the European Business Wallets user
has been successfully authenticated as detailed under annex I (1) (2).
Interoperability between European Business Wallets and European Digital Identity Wallets: request and
share European Business Wallet owner identification data and electronic attestations of attributes in a secured
way between European Business Wallets and European Digital Identity Wallets.
Single Digital Gateway and
IMI
N/A
Others N/A
European Digital Directory
Digital and/or sectorial policy
(when these are applicable)
Explanation on how it aligns
AI Act N/A
EU Cybersecurity framework The Commission shall make the European Digital Directory only accessible to European Business Wallet
owners and providers of European Business Wallets.
The Commission shall implement the European Digital Directory in accordance with the relevant principles
of data protection including, where appropriate, with the features of pseudonymisation.
Alignment with Directive 2022/2555.
eIDAS
Single Digital Gateway and
IMI
EN 18 EN
Others
Signature creation application
Digital and/or sectorial policy
(when these are applicable)
Explanation on how it aligns
AI Act N/A
EU Cybersecurity framework -
eIDAS Use of electronic signatures and seals.
Single Digital Gateway and IMI -
Others -
4.4. Interoperability assessment
High-level description of the digital public service(s) affected by the requirements
Digital public
service or category
of digital public
services
Description Reference(s) to the
requirement(s)
Interoperable
Europe Solution(s)
(NOT
APPLICABLE)
Other interoperability solution(s)
EN 19 EN
Digital identity
verification and
authorisation,
European Business
Wallets (COFOG
01.6 - BT.1 -
General public
services)
Public service facilitates secure
cross-border transactions by
providing a framework for digital
identity and authentication for
economic operators and public
sector bodies.
Article 4;
Article 5(1), (3), (5);
Article 6(1),(2),(4);
Article 6(3);
Article 6(5);
Article 7;
Article 8;
Article 9;
Article 10;
Article 11;
Article 12;
Article 13;
Article 18(1),(3);
Article 19;
Article 21.
// Business Registers Interconnection
System (‘BRIS’) and the Beneficial
Ownership Registers Interconnection
System (‘BORIS’)
SDG
DPP Wallet
EDD
EN 20 EN
Digital public
services in Member
States that are
mandated to accept
evidence through
European Business
Wallets
National digital public services
impacted by the use of European
Business Wallets in administrative
procedures where public sector
bodies are required to accept
identification and authentication,
eSignature or eSeal, submission of
documents, the sending or
receiving of notifications.
Article 16(1) (2) //
Impact of the requirement(s) as per digital public service on cross-border interoperability
Digital public service #1: European Business Wallet
Assessment Measure(s) Potential remaining barriers (if applicable)
Alignment with existing digital and
sectorial policies
Please list the applicable digital and
sectorial policies identified
The European Business Wallets will build on and extend
the ecosystem of trust established under the European
Digital Identity Framework, established by Regulation
(EU) 910/2014 on electronic identification and trust
services for electronic transactions in the internal
market, as amended by Regulation (EU) 2024/118318
(including adopted implementing acts).
Providers of the European Business wallets must comply
with the requirements of Directive (EU) 2022/2555
(NIS2) of the European Parliament and of the Council on
measures for a high common level of cybersecurity
across the Union. Likewise, the European Digital
Directory shall be operated in alignment with the
principles enshrined under NIS2.
EN 21 EN
Cryptographic operators or other operations processing
critical assets shall be performed in accordance with the
requirements for the characteristics and design of
electronic identification means at assurance level
substantial as set out in Commission Implementing
Regulation (EU) 2015/1502.
The European Data Protection Supervisor were
consulted in accordance with Article 42(1) of Regulation
(EU) 2018/1725.
The proposal anticipates that the European Business
Wallets should also enable the exchange of attestations
for the purpose of delegating digital power of attorney,
as established by Directive (EU) 2025/25, allowing
economic operators and public sector bodies to exchange
attestations with their Business Wallets to delegate
authority to representatives.
Organisational measures for a
smooth cross-border digital public
services delivery
Please list the governance measures
foreseen
In each Member State, the supervisory bodies designated
pursuant to Article 46a of Regulation (EU) No 910/2014
shall also be the supervisory bodies for the purposes of
this Regulation. The Regulation provides for the role and
tasks of such authorities.
Member States shall ensure that the supervisory bodies
referred to in paragraph 1 possess the necessary powers
and adequate resources for the exercise of their tasks in
an effective, efficient, and independent manner.
Where a Union entity is a provider of European Business
Wallets the Commission shall be the responsible
supervisory body.
Measures taken to ensure a shared EBW owner identification data shall be issued in a
EN 22 EN
understanding of the data
Please list such measures
format according to one of the standards listed in Annex
II of Commission Implementing Regulation (EU)
2024/2979 and as QEAA or EAA depending on the
issuing entity.
The annexes define the high-level requirements that will
be then instantiated in specifications and standards in the
upcoming implementing act to ensure a shared
understanding of the data.
Business Wallets shall support the secure export and
portability of an owner’s European Business Wallet data
in at least an open format.
Use of commonly agreed open
technical specifications and
standards
Please list such measures
Adopt implementing acts for the definition of reference
standards and specifications.
Digital public service #2: Digital public services in Member States that are mandated to receive evidence through European Business
Wallets
Assessment Measure(s) Potential remaining barriers (if applicable)
Alignment with existing digital and
sectorial policies
Please list the applicable digital and
sectorial policies identified
Alignment ensured for the European Business Wallets,
as detailed above.
Organisational measures for a
smooth cross-border digital public
services delivery
Article 15 mandates Member States to enable economic
operators to exchange information with public sector
bodies via the European Business Wallet.
EN 23 EN
Please list the governance measures
foreseen
Measures taken to ensure a shared
understanding of the data
Please list such measures
Use of commonly agreed open
technical specifications and
standards
Please list such measures
4.5. Measures to support digital implementation
High-level description of measures supporting digital implementation
Description of the measure Reference(s) to
the
requirement(s)
Commission role
(if applicable)
Actors to be
involved
(if applicable)
Expected timeline
(if applicable)
List of reference standards and, where
necessary, specifications and procedures for
the core functionalities of European Business
Wallets
Article 5(3)(5) Adopt implementing acts // //
List of reference standards and, where
necessary, specifications and procedures for
the technical features of the European Business
Wallets
Article 6 (5) Adopt implementing acts // //
Requirements for European Business wallet Article 8 (6) Adopt implementing acts // //
EN 24 EN
owner identification data issuance
Specifications and detailed requirements for
the unique identifier
Article 9 (4) Adopt implementing acts // //
Standards and technical specifications for the
European Digital Directory
Article 10(6) Adopt implementing acts // //
Acts establishing that Business Wallets or
systems offering similar functions that are
issued by providers established in third
countries are to be considered as equivalent to
European Business Wallets
Article 18(1) Adopt implementing acts // //
EN 1 EN
EN 1 EN
EN EN
EUROPEAN COMMISSION
Brussels, 19.11.2025
COM(2025) 838 final
ANNEX
ANNEX
to the
Proposal for a Regulation of the European Parliament and of the Council
on the establishment of European Business Wallets
{SWD(2025) 837 final}
EN 1 EN
ANNEX
Requirements for minimum functionalities and technical requirements of European
Business Wallets
1. EUROPEAN BUSINESS WALLETS UNIT AUTHENTICATION
Access to the European Business Wallets Unit shall be granted only after the
European Business Wallets user has been successfully authenticated by means of
either:
(1) a notified electronic identification (eID) means in accordance with Article 6 of
Regulation (EU) No 910/2014, fulfilling at least the requirements for a
substantial level of assurance as defined in Article 8 of that Regulation and
further specified in Commission Implementing Regulation (EU) 2015/1502; or
(2) an alternative authentication mechanism recognised as equivalent and fulfilling
at least the requirements for a substantial level of assurance as defined in
Article 8 of Regulation (EU) No 910/2014 and further specified in Commission
Implementing Regulation (EU) 2015/1502.
Until such authentication has been completed, no functionality of the European
Business Wallets Unit or of any other functionalities shall be made accessible to the
Wallets user.
2. EUROPEAN BUSINESS WALLETS UNIT INTEGRITY
Providers of European Business Wallets shall, for each European Business Wallet
unit, generate and sign a European Business Wallet unit attestation in accordance
with the requirements laid down in point 5. The certificate used to sign or seal the
Business Wallet unit attestation shall be issued under a certificate listed in the trusted
list referred to in Commission Implementing Regulation (EU) 2024/2980.
3. EUROPEAN BUSINESS WALLETS SECURE COMMUNICATION AND CRITICAL ASSET
MANAGEMENT
(1) European Business Wallet back-end shall use at least one Wallet secure
cryptographic application and Wallets secure cryptographic device to manage
critical assets.
(2) Providers of the European Business Wallets shall ensure integrity, authenticity
and confidentiality of the communication between the Business Wallet’s back-
end, front-end and secure cryptographic applications and device.
(3) Where critical assets relate to performing electronic identification at assurance
level substantial, the European Business Wallets cryptographic operations or
other operations processing critical assets shall be performed in accordance
with the requirements for the characteristics and design of electronic
identification means at assurance level substantial, as set out in
Commission Implementing Regulation (EU) 2015/1502.
4. WALLETS SECURE CRYPTOGRAPHIC APPLICATIONS
(1) Providers of European Business Wallets shall ensure that European Business
Wallets secure cryptographic applications and devices:
EN 2 EN
(a) perform the wallet’s cryptographic operations involving critical assets
other than those needed for the Wallets unit to authenticate the Wallets
owner only in cases where those applications have successfully
authenticated Wallets users;
(b) where they authenticate the European Business Wallet owner in the
context of performing electronic identification at assurance level
substantial as set out in Implementing Regulation (EU) 2015/1502;
(c) are able to securely generate new cryptographic keys;
(d) are able to perform secure erasure of critical assets;
(e) are able to generate a proof of possession of private keys;
(f) protect the private keys generated by these Wallets secure cryptographic
applications and devices during the existence of the keys;
(g) comply with the requirements for the characteristics and design of
electronic identification means at assurance level substantial, as set out in
Implementing Regulation (EU) 2015/1502.
5. WALLETS UNIT AUTHENTICITY AND VALIDITY
(1) Providers of European Business Wallets shall ensure that the European
Business Wallets unit attestations referred to in point 1 contain public keys and
that the corresponding private keys are protected by a Wallets secure
cryptographic device.
(2) Providers of European Business Wallets shall provide mechanisms,
independent of Wallets units, for the secure identification and authentication of
Wallets users.
6. REVOCATION OF WALLETS UNIT ATTESTATIONS
(1) Providers of European Business Wallets shall establish a publicly available
policy specifying the conditions and the timeframe for the revocation of
Wallets unit attestations.
(2) In line with Article 6, where the providers of European Business Wallets
revoke European Business Wallets unit attestations, they shall inform the
affected European Business Wallets users without undue delay and no later
than 24 hours from the revocation of their European Business Wallets units,
including the reason for the revocation and the consequences for the European
Business Wallets user. This information shall be provided in a manner that is
concise, easily accessible and using clear and plain language.
(3) Where European Business Wallets providers have revoked a European
Business Wallet’s unit attestation, they shall make publicly available the
validity status of the European Business Wallet unit attestation and describe the
location of that information in the Business Wallet’s unit attestation.
7. TRANSACTION LOGS
(1) The providers of European Business Wallets shall provide an appropriate
logging policy that shall include, at a minimum, electronic signing, electronic
EN 3 EN
sealing, and notifications of all transactions with Business-Wallet-relying
parties, other European Business Wallets units, and European Digital Identity
Wallets units, irrespective of whether the transaction is successfully completed.
(2) The logged information shall at least contain:
(a) the time and date of the transaction;
(b) the name, contact details, and unique identifier of the corresponding
Business-Wallet-relying party and the Member State in which that
Business-Wallet-relying party is established, or in case of other Wallets
units, relevant information from the Wallets unit attestation;
(c) the type or types of data requested and presented in the transaction;
(d) in the case of non-completed transactions, the reason for such non-
completion.
(3) Providers of European Business Wallets shall ensure integrity, authenticity and
confidentiality of the logged information.
(4) European Business Wallets back-end shall log reports sent by the Wallets user
to the competent authorities via the Wallets unit, including interactions related
to notifications, regulatory compliance, data sharing, or audit requests.
(5) The logs referred to in subpoints 1 and 2 shall be accessible to the European
Business Wallets provider, where it is necessary for the provision of Wallets
services.
(6) The logs referred to in subpoints 1 and 2 shall remain accessible for as long as
required to be accessible by Union law or national law.
8. QUALIFIED ELECTRONIC SIGNATURES AND SEALS
(1) In line with Article 6, providers of European Business Wallets shall ensure that
Wallets users are able to receive qualified certificates for qualified electronic
signatures or seals which are linked to qualified signature or seal creation
devices that are either local, external, or remote in relation to the Wallet’s unit.
(2) Providers of European Business Wallets shall ensure that European Business
Wallets solutions can securely interface with one of the following types of
qualified signature or seal creation devices: local, external, or remotely
managed qualified signature or seal creation devices for the purposes of using
the qualified certificates referred to in subpoint 1.
9. SIGNATURE CREATION APPLICATIONS
(1) The signature creation applications used by European Business Wallets units
may be provided either by European Business Wallets providers, by providers
of trust services or by Business-Wallet-relying parties.
(2) Signature creation applications shall have the following functions:
(a) signing or sealing data provided by European Business Wallets users;
(b) signing or sealing data provided by relying parties;
(c) creating signatures or seals in accordance with at least the mandatory
format;
EN 4 EN
– creating signatures or seals in accordance with the optional format;
– informing Wallets users about the result of the signature or seal
creation process.
To ensure uniform conditions for the implementation of this Regulation, the
Commission is empowered to adopt implementing acts in accordance with
Article 6 that specify the technical standards referred to in subpoint 2, letters
(c) and (c)(ii).
(3) The signature creation applications may either be integrated into or be external
to European Business Wallets back-end. Where signature creation applications
rely on remote qualified signature creation devices and where they are
integrated into European Business Wallets back-end, they shall support the
application programming interface set out in the implementing acts, which the
Commission is empowered to adopt in accordance with Article 5 in order to
ensure uniform conditions for the implementation of this Regulation.
10. DATA EXPORT AND PORTABILITY
Business Wallets shall support the secure export and portability of an owner’s
European Business Wallet data in at least an open format. This shall enable the
owner to migrate their data to another Business Wallets solution while ensuring a
level of assurance of at least "substantial", as defined in Implementing Regulation
(EU) 2015/1502.
11. SECURE LEGAL COMMUNICATION CHANNEL FOR THE BUSINESS WALLET
(1) In line with Article 5 of this Regulation, Business Wallets shall integrate and
support the use of a specific qualified electronic registered delivery service in
accordance with Articles 43 and 44 of Regulation (EU) No 910/2014.
(2) The Commission shall, by means of implementing acts:
(a) designate one qualified electronic registered delivery service that shall
serve as the mandatory secure legal communication channel for European
Business Wallets;
(b) define the minimum technical and interoperability requirements that such
qualified electronic registered delivery service must fulfil, including
alignment with the reference standards, specifications and procedures
established under Articles 43 and 44 of Regulation (EU) No 910/2014;
(c) ensure that the chosen qualified electronic registered delivery service is
based on open, publicly available and royalty-free standards to guarantee
interoperability and prevent vendor lock-in;
(d) ensure that the chosen qualified electronic registered delivery service
provides end-to-end encryption to guarantee confidentiality;
(e) establish procedures for ensuring continuous availability, redundancy and
fallback mechanisms in case of service failure.
(3) Interoperability between Business Wallets and the designated qualified
electronic registered delivery service shall be mandatory. Providers of Business
Wallets shall ensure technical integration in accordance with the implementing
acts referred to in subpoint 2.
EN 5 EN
12. EUROPEAN BUSINESS WALLETS ACCESS CONTROL MECHANISM
(1) Providers of European Business Wallets shall ensure that authorisation
decisions under the access control mechanism are based on one or more of the
following criteria, as appropriate to the specific access request:
(a) the electronic attestation of attributes of the acting subject;
(b) the formal role of the acting subjects within a recognised organisational
structure or economic operator;
(c) the scope, validity and constraints of any mandate, delegation, or power
of attorney;
(d) contextual information or policies and rules adopted at Union or national
level for sector-specific compliance.
(2) Providers of European Business Wallets shall ensure the access control
mechanism nables fine-grained and auditable authorisation outcomes, ensuring
that:
(a) visibility of credentials and attestations is selective and conditioned on
access rights;
(b) access to business processes, digital procedures or submission interfaces
is controlled by real-time validation of roles and mandates;
(c) all access and execution events are logged, timestamped, and bound to
cryptographically verifiable proofs of authorisation, suitable for audit and
legal proceedings.
(3) Providers of the European Business Wallets shall ensure that:
(a) mappings between roles and attributes are verifiable, auditable, revocable
and traceable to their legitimate issuers;
(b) conflicts of roles, over-delegation, or expired authorisations are
automatically detected and prevented in real time;
(c) all authorisation logic is interoperable across Member States.
(4) The list of reference standards, technical specifications and procedures to be
applied for the implementation of the access control mechanism shall be
defined in the implementing acts, which the Commission is empowered to
adopt in accordance with Article 5 in order to ensure uniform conditions for the
implementation of this Regulation. These shall cover in particular:
(a) the formats for the representation of roles and attributes;
(b) interoperability mechanisms for mandates and delegations across wallets;
(c) protocols, policy language and constraint enforcement;
(d) requirements for secure logging, timestamping and auditability of
authorisation events.
(5) Compliance with the requirements laid down in this Article shall be presumed
where the standards, specifications and procedures referred to in subpoint 1 are
met.
EN 6 EN
13. GENERAL PROVISIONS FOR PROTOCOLS AND INTERFACES
In line with Article 6 of this Regulation, providers of European Business Wallets
shall ensure that European Business Wallets units:
(1) authorise requests and, where applicable, authenticate those made through
relying-party access certificates or Wallet unit attestations. Authentication of
the relying party shall be required where attestations are intended for a
restricted audience; in all other cases, attestations may be presented by any
requesting party;
(2) display to Wallet users’ information contained in the Business-Wallet-relying
party access certificates or in the Wallets unit attestations where applicable;
(3) display to Wallets users, where applicable, the attributes that Wallets users are
requested to present;
(4) present Wallet unit attestations of the Wallet unit to Business-Wallet-relying
parties or Wallets units that request it.
14. ISSUANCE OF ELECTRONIC ATTESTATIONS OF ATTRIBUTES TO WALLETS UNITS
(1) In line with Article 5 of this Regulation, providers of European Business
Wallets shall ensure that Business Wallet units requesting issuance of,
electronic attestations of attributes are able to authenticate relying parties.
(2) In relation to the issuance of electronic attestations of attributes to a Wallet
unit, Wallet providers shall ensure that the following requirements are
complied with:
(a) where European Business Wallets owners, through their Business Wallet
unit, request from the provider of the European Business Wallet the
issuance of Business Wallets owner identification data or of electronic
attestations of attributes from providers of Business Wallets owner
identification data or providers of electronic attestations of attributes that
enable issuance of Business Wallets owner identification data or
electronic attestations in more than one format, the Wallets unit shall
request it in all formats referred to in Article 8 to this Regulation laying
down rules for the application of the Business Wallets Regulation as
regards the integrity and core functionalities of Business Wallets;
(b) where Business Wallet owners use their Business Wallets unit to interact
with competent national authorities and providers of electronic
attestations of attributes, Wallet units shall enable authentication and
validation of the Wallet unit components by presenting the Wallet unit
attestations to those competent national authorities and providers upon
their request;
(c) Wallet solutions shall support mechanisms that enable providers of
Business Wallets Owner Identification Data to verify issuance, delivery
and activation in compliance with assurance level substantial
requirements set out in Commission Implementing Regulation (EU)
2015/1502 (11);
(d) Wallet units shall verify the authenticity and validity of Business Wallets
owner identification data and electronic attestations of attributes.
EN 7 EN
15. PRESENTATION OF ATTRIBUTES TO EUROPEAN BUSINESS WALLET RELYING
PARTIES
In line with point (d) and (k) of paragraph 1 of Article 5, European Business Wallet
providers shall ensure that:
(1) European Business Wallet solutions support protocols and interfaces for the
presentation of attributes to Business-Wallet-relying parties in accordance with
the standards defined in the implementing acts;
(2) At the request of users, European Business Wallet units respond to successfully
authenticated and validated requests from Business-Wallet-relying parties in
accordance with the standards defined in the implementing acts;
(3) European Business Wallet units support proving the possession of private keys
corresponding to public keys used in cryptographic bindings.
16. ISSUANCE OF EUROPEAN BUSINESS WALLET OWNER IDENTIFICATION DATA TO
WALLETS UNITS
(1) Competent authorities shall ensure that Business Wallets owner identification
data issued to Business Wallets units comply with the technical specifications
set out in the implementing acts, in line with Article 8 of this Regulation.
(2) Competent national authorities shall ensure that Business Wallets owner
identification data that they issue is cryptographically bound to the Wallets unit
to which it is issued.
17. ISSUANCE OF ELECTRONIC ATTESTATIONS OF ATTRIBUTES TO WALLETS UNITS
(1) Electronic attestations of attributes issued to European Business Wallets units
shall comply with at least one of the standards in the list set out in the
implementing acts, in line with Article 5 of this Regulation.
(2) Providers of electronic attestations of attributes shall identify themselves to
European Business Wallets units using their wallet-relying party access
certificate.
(3) Providers of electronic attestations of attributes shall ensure that electronic
attestations of attributes issued to European Business Wallets units contain the
information necessary for authentication and validation of those electronic
attestations of attributes.
Resolutsiooni liik: Riigikantselei resolutsioon Viide: Justiits- ja Digiministeerium / / ; Riigikantselei / / 2-5/25-02178
Resolutsiooni teema: Euroopa Parlamendi ja nõukogu määruse eelnõu Euroopa ärikukru loomise kohta
Adressaat: Justiits- ja Digiministeerium Ülesanne: Tulenevalt Riigikogu kodu- ja töökorra seaduse § 152` lg 1 p 2 ning Vabariigi Valitsuse reglemendi § 3 lg 4 palun valmistada ette Vabariigi Valitsuse seisukoha ja otsuse eelnõu järgneva algatuse kohta, kaasates seejuures olulisi huvigruppe ja osapooli:
- Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the establishment of European Business Wallets, COM(2025)838 Tähtaeg: 02.01.2026
Adressaat: Haridus- ja Teadusministeerium, Kaitseministeerium, Kliimaministeerium, Kultuuriministeerium, Majandus- ja Kommunikatsiooniministeerium, Rahandusministeerium, Regionaal- ja Põllumajandusministeerium, Siseministeerium, Sotsiaalministeerium, Välisministeerium Ülesanne: Palun esitada oma sisend Justiits- ja Digiministeeeriumile seisukohtade kujundamiseks antud eelnõu kohta (eelnõude infosüsteemi (EIS) kaudu). Tähtaeg: 18.12.2025
Lisainfo: Eelnõu on kavas arutada valitsuse 15.01.2026 istungil ja Vabariigi Valitsuse reglemendi § 6 lg 6 kohaselt sellele eelneval nädalal (07.01.2026) EL koordinatsioonikogus. Esialgsed materjalid EL koordinatsioonikoguks palume esitada hiljemalt 02.01.2026.
Kinnitaja: Merli Vahar, Euroopa Liidu asjade direktori asetäitja Kinnitamise kuupäev: 28.11.2025 Resolutsiooni koostaja: Sandra Metste [email protected],
.
Euroopa Parlamendi ja nõukogu määruse eelnõu Euroopa ärikukru loomise kohta (KOM(2025)838)
Otsuse ettepanek koordinatsioonikogule
Kujundada seisukoht
Kaasvastutaja sisendi tähtpäev 18.12.2025
KOKi esitamise tähtpäev 07.01.2026
VV esitamise tähtpäev 15.01.2026
Peavastutaja Justiits- ja digiministeerium, kaasvastutajad Majandus- ja kommunikatsiooniministeerium, Rahandusministeerium, Kliimaministeerium, Sotsiaalministeerium, Välisministeerium, Kaitseministeerium, Kultuuriministeerium, Haridus- ja teadusministeerium, Regionaal- ja põllumajandusministeerium, Siseministeerium.
Seisukoha valitsusse toomise alus ja põhjendus
Algatuse reguleerimisala nõuab vastavalt Eesti Vabariigi põhiseadusele seaduse või Riigikogu otsuse vastuvõtmist, muutmist või kehtetuks tunnistamist (RKKTS § 152¹ lg 1 p 1);
Algatuse vastuvõtmisega kaasneks oluline majanduslik või sotsiaalne mõju (RKKTS § 152¹ lg 1 p 2);
Sisukokkuvõte
Ettepaneku eesmärk on luua Euroopa ettevõtjatele ja avaliku sektori asutustele ühtne digitaalne tööriist, et lihtsustada ettevõtete suhtlust ja toimingute tegemist riigiasutuste ja teiste ettevõtetega, et vähendada seeläbi halduskoormust. Ettevõtjad saaksid ettepaneku kohaselt dokumente digitaalselt allkirjastada, ajatempliga varustada ja pitseerida; turvaliselt luua, säilitada ja vahetada kontrollitud dokumente ning suhelda turvaliselt teiste ettevõtjate või haldusasutustega nii oma riigis kui teistes ELi liikmesriikides. Eesmärk on muuta ettevõtte tegevuse laiendamine teistesse liikmesriikidesse, maksude maksmine ja riigiasutustega suhtlemine ELis lihtsamaks, ühtlasi vähendada ettevõtjate haldusmenetlusi ja -kulusid.
Mõju ja sihtrühm
Mõju valdkonnad
2
Majandus
Ettevõtlus
Sihtrühm: Ettevõtjad
Mõju sihtrühmale: Edendatakse ettevõtlust.
Halduskoormus
Kas lahendusega kaasneb mõju halduskoormusele? Jah
Hinnata mõju ettevõtete halduskoormusele.
Riigieelarve
Kas lahendusega kaasneb mõju riigieelarvele? Jah
Hinnata mõju, kuna potentsiaalselt kaasneb mõju riigieelarvele.
Kaasamine
Kaasata algatustega seotud huvigrupid.
Eelnõude infosüsteemis (EIS) on antud täitmiseks ülesanne. Eelnõu toimik: 17.1.1/25-0583 - COM(2025) 838 Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on the establishment of European Business Wallets Eelnõu kohta seisukoha esitamine Vabariigi Valitsuse istungile vastavalt Riigikantselei 28.11.2025 resolutsioonile. Osapooled: Justiits- ja Digiministeerium Tähtaeg: 02.01.2026 23:59 Link eelnõu toimiku vaatele: https://eelnoud.valitsus.ee/main/mount/docList/701fb4f0-43c1-4f27-9dc1-b849c2e98776 Link menetlusetapile: https://eelnoud.valitsus.ee/main/mount/docList/701fb4f0-43c1-4f27-9dc1-b849c2e98776?activity=1 Eelnõude infosüsteem (EIS) https://eelnoud.valitsus.ee/main