Digital customer identification using the EUDI Wallet from 2027

Digital customer identification is due to become available from 2 January 2027 through the government EUDI Wallet, “d-you”. Businesses will be able to use it to verify identity details and proof of age digitally, and to conclude suitable contracts without switching to paper. For most small and medium-sized enterprises, accepting the wallet will initially be voluntary.

What will digital customer identification change from January 2027?

In future, customers will be able to manage selected credentials in a free app and choose which ones to share with a business. Users will decide for themselves whether to use “d-you” or continue with an offline process.

The Deutscher Bundestag (German Federal Parliament) passed the Digitale Identitätengesetz (Digital Identities Act) on 15 October 2026. According to the Bundesregierung (German Federal Government), the government wallet “d-you” is due to launch on 2 January 2027.

EUDI stands for European Digital Identity. An EUDI Wallet is a digital wallet in which official and private credentials can be stored and presented. According to the Bundesministerium für Digitales und Staatsmodernisierung (Federal Ministry for Digital Transformation and Government Modernisation), identity cards, driving licences, electronic signatures and pseudonymous logins will be added gradually.

According to the German Federal Government, the initial launch is expected to include applications from around 40 partners in business, academia and public administration. The Federal Ministry says that more than 150 companies are already testing use cases in a government test environment known as the sandbox.

Which processes can businesses simplify with the wallet?

The wallet is particularly suitable for processes in which a business needs to verify a person’s identity, age or specific permissions. Depending on the process, this could remove the need for copies of identity documents, manual data entry and postal correspondence.

The German Federal Government cites digital proof of age, legally valid contracts and the opening of bank accounts as initial applications. Examples for day-to-day business operations include:

• Retail and hospitality: A customer confirms that they are over 18. The business does not necessarily need to receive their name, address and full date of birth.
• Care services: A new customer provides digital proof of their identity or insurance details. The credentials available will depend on the wallet’s stage of development.
• Temporary staffing: Applicants can transfer identity details into a registration process. This reduces typing errors, but does not automatically replace every check required under employment law.
• Law firms: Clients can identify themselves before an initial digital consultation. The type of verification required will continue to depend on the relevant legal obligations.

A process without changes of medium means that data does not first have to be transferred from an app to a PDF, onto paper or manually into specialist software. Identification can be connected directly to a customer portal, contract process or registration process. When digitalising processes and replacing paper and Excel, the entire process should therefore always be considered.

Do small businesses have to accept the EUDI Wallet?

For most small and medium-sized enterprises, there is initially no general obligation to accept it. They can offer the wallet voluntarily if it suits their customer processes.

EU Regulation 2024/1183 establishing the European Digital Identity Framework sets out specific acceptance rules for certain private providers. These apply to providers that require strong online authentication under EU law, national law or contractual requirements. This type of authentication verifies a person using several independent factors.

Microenterprises and small enterprises are exempt from this specific EU acceptance requirement. However, this does not mean that all statutory identity checks no longer apply. Anti-money laundering requirements, the protection of minors, professional regulations and requirements for particular forms of contract will remain in force.

Use of the wallet itself will also be voluntary and free of charge for citizens and residents. According to the German Federal Government, existing offline processes will remain available. Businesses should therefore offer an alternative route, at least during a transition period.

How is the EUDI Wallet integrated into customer portals?

A business needs a technical interface between the wallet and its own process. This interface transfers only the requested data and returns the verification result to the customer portal or specialist software.

For an age check, it may be sufficient simply to confirm the attribute “over 18”. The business will not then automatically need a complete copy of the person’s identity document. This can reduce the amount of personal data stored, but does not remove the obligations under the Datenschutz Grundverordnung (General Data Protection Regulation).

Before implementation, you should decide:

1. Which specific credential is required for the process?
2. Which data needs to be stored, and which does not?
3. How will the process continue for customers without a wallet?
4. Which specialist software will receive the verification result?
5. How will errors, expired credentials and abandoned processes be handled?

For an existing online shop, a standard add-on module may be sufficient. For specific contract processes, multiple locations or proprietary specialist software, a bespoke web app or customer portal for the business may be required. The precise technical implementation will depend on the interfaces that become available and the terms of the relevant wallet services.

What should businesses prepare before the launch?

Businesses do not need to redesign every customer portal as a precaution. A sensible first step is to review processes in which identity documents are copied, age details are checked, signatures are obtained or data is entered more than once.

Then choose one clearly defined use case. A drinks retailer could begin with digital proof of age. A law firm could first test identification before the initial consultation, while a staffing company could test the transfer of verified master data.

You should also check which type of signature the relevant contract requires. A simple electronic confirmation is not automatically equivalent to a qualified electronic signature. For contracts subject to a statutory written form or sector-specific requirements, legal advice should be obtained before technical implementation begins.

Only make a firm implementation plan once the required credentials, interfaces and terms of use have been published. The announced launch date and the scope of individual functions may still change before January 2027.

ibx company advises small and medium-sized enterprises in Hannover and the surrounding region on selecting and implementing suitable digital processes. During a no-obligation initial consultation, we can assess together whether connecting a wallet would be appropriate for your business.