EU Digital Identity Wallets may become available before relevant credentials are widely issued. This article explores how the empty wallet scenario could slow early adoption and what public-sector organisations and relying parties should consider.
Member States are expected to make EU Digital Identity Wallets available by the end of 2026. However, availability alone may not translate into immediate usage. Public-sector organisations and relying parties may need to plan for a transition period in which credential populations, service support and user habits mature at different speeds. Finland’s DVV has stated that the Finnish wallet application is to be introduced at the end of 2026 and that its features will be expanded gradually.
Across Europe, public-sector organisations and regulated businesses are beginning to prepare for the introduction of the EU Digital Identity Wallet (EUDI Wallet). Much of the discussion understandably focuses on regulatory timelines, technical standards and implementation planning.
At the same time, there is a practical question that receives less attention: what happens if wallets become available but many users initially have only a limited number of credentials relevant to the services they use?
One way to think about this is as an empty wallet scenario. Early users may have a wallet installed, but only a small number of credentials available for use in specific services.
In that situation, the pace of adoption may depend less on the availability of the wallet itself and more on how quickly useful credentials are issued, how broadly services support them, and how familiar users become with this new model of digital identification.
The early adoption of the EUDI Wallet is likely to depend on several developments progressing in parallel:
Wallet availability from Member States
Credential issuance by public and private issuers
Service integration among relying parties
User awareness and behavioural change
The regulatory framework provides timelines for wallet availability, and the overall direction is clear. National authorities, including in Finland, have indicated that wallet solutions are expected to become available around 2026. DVV has also described the wider wallet ecosystem as one whose capabilities and services will expand in phases rather than all at once.
However, the broader ecosystem envisioned for the EUDI Wallet extends beyond the wallet application itself. It includes a network of credential issuers, relying parties and supporting services.
This distinction is important. A wallet may be introduced on schedule, while the population of credentials inside it grows more gradually. Credentials are expected to be issued by a wide range of organisations, including government authorities, educational institutions, professional bodies and private-sector issuers. Each of these organisations must assess legal, operational and technical questions before issuing credentials.
As a result, wallet availability could precede the widespread issuance of credentials that are directly useful in everyday services.
In the early phase of deployment, the most important credential is likely to be the Person Identification Data (PID) credential defined in the EUDI Wallet implementing framework. The European framework and related national materials position the wallet as a container for core identity data first, with broader use cases and credentials developing over time.
PID provides core identity attributes that allow users to prove their identity with a high level of assurance. Even on its own, this credential may support certain use cases such as:
identity confirmation
age verification
step-up authentication for sensitive actions
However, many sector-specific credentials, including professional licences, educational qualifications and other attestations, will depend on issuer onboarding and integration work. These credentials may therefore appear gradually rather than simultaneously across Member States.
As a result, the early stage of adoption may be shaped primarily by a relatively small set of identity-related use cases, while the broader credential ecosystem develops over time.
Finland’s experience with Mobiilivarmenne (Mobile Certificate) provides a useful illustration of how digital identity solutions may take time to achieve widespread use.
Mobile Certificate has been available for more than a decade as a strong electronic identification method supported by Finnish mobile operators. Despite this, adoption grew gradually rather than immediately.
In 2010, the Finnish Ministry of Transport and Communications noted that approximately 99 percent of electronic identification transactions were carried out using bank identifiers, while Mobile Certificate was only beginning to enter the market.
Several years later, adoption still appeared relatively modest. In a 2018 release published in connection with public-sector identification services, Telia estimated that Mobile Certificate accounted for roughly four percent of digital identification events at that time.
Statistics published by the Digital and Population Data Services Agency show that in 2021, Mobile Certificate accounted for about 8 percent of authentications in the Suomi.fi identification service, specifically 1,567,875 out of 19,284,848 authentication events in December 2021.
More recently, usage has increased further. In 2025, Telia stated, citing Suomi.fi reporting, that Mobile Certificate’s share of authentications within public administration e-services had risen to over 14 percent.
This trajectory demonstrates that the availability of a technically sound and widely supported identification method does not necessarily result in rapid adoption. User habits, service integration, security considerations and institutional trust all influence how quickly new identification mechanisms become part of everyday digital services.
While the EUDI Wallet ecosystem differs in several respects, the Finnish experience suggests that changes in identification behaviour can develop gradually.
If such an empty wallet phase occurs during the early stages of EUDI Wallet deployment, relying parties may observe patterns such as:
users who have installed a wallet but do not yet possess the credential required for a particular service
continued reliance on existing identification methods during the transition period
gradual rather than immediate growth in wallet-based verification volumes
These outcomes would not necessarily indicate a problem with the wallet framework itself. They may simply reflect the time required for credential issuance, service integration and user familiarity to develop across the ecosystem.
It is also relevant that the use of digital identity wallets by citizens is intended to remain voluntary, which may influence adoption patterns in the early years. DVV’s own materials describe the wallet as a service citizens can use if they choose to do so.
Organisations preparing to support the EUDI Wallet may benefit from planning for a transitional phase rather than assuming immediate widespread use.
Several practical considerations may help support a smoother introduction.
Wallet-based verification can be introduced as an additional option while existing identification methods remain available. This approach helps ensure that services remain accessible even when users do not yet possess the necessary credentials in their wallet.
Services that benefit from basic identity attributes may be able to adopt wallet-based verification earlier, without waiting for a broader range of credentials.
Credential issuance will likely vary across sectors and Member States. Systems designed to accommodate new credential types through configuration rather than redevelopment may adapt more easily as the ecosystem evolves.
Analysing wallet usage, credential availability and fallback behaviour can help organisations understand how adoption is progressing and where improvements to service design may be needed.
The introduction of the EUDI Wallet may be better understood as the beginning of a multi-year ecosystem rollout rather than a single launch event.
Wallet availability represents an important milestone, but the broader ecosystem of credentials, services and user behaviour will develop over time.
In practice, the success of the EUDI Wallet may depend less on the moment of its introduction and more on how the surrounding ecosystem evolves in the years that follow.
Recognising the possibility of an empty wallet scenario can help organisations approach implementation with realistic expectations and resilient service designs.
Authbound develops integration infrastructure for organisations preparing to support EUDI Wallet verification. Its APIs and SDKs enable wallet-based verification alongside existing identification methods, helping organisations manage the transition as the EUDI ecosystem develops.
Organisations evaluating their EUDI Wallet readiness or integration strategy can contact [email protected] for further discussion.
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