Skip to content

Home > eID > EUDI-ARF

EUDI Wallet and the ARF (European Union)

Last modified: 2026-10-28

Description

  • Legal basis: eIDAS-Regulation-910-2014 (2014, mutual recognition of national eID schemes) and its 2024 amendment EU-Digital-Identity-Regulation-2024-1183 (EUDI / "eIDAS 2"), which requires every member state to offer a European Digital Identity Wallet, with implementing acts 2024/2977–2982.
  • Technical framework: the EUDI-ARF describes PID and attestations in ISO mdoc and SD-JWT VC, OID4VCI / OID4VP and ISO 18013-5, issuer keys in HSMs and wallet secure cryptographic devices. Reference implementation: eu-digital-identity-wallet.
  • ARF discussion topics relevant to privacy: A (privacy risks and mitigations), B (re-issuance and batch issuance), C (wallet unit attestation), E (pseudonyms), G (zero-knowledge proofs), and later topics on transaction logs, wallet-to-wallet interaction, combined presentations and relying-party registration.
  • Critique: BBC+24-ARF-Feedback argues that SD-JWT / mdoc with conventional signatures cannot meet the regulation's unlinkability requirements and recommends BBS-family anonymous credentials. KVRSCLT26-EUDIF-Harms formally models the framework's information leakage and concludes that PETs reduce information flows but cannot mitigate harms fundamental to deploying digital identity at scale.
  • ZKP status (2026): ZKPs are still not part of the normative ARF. Topic G was moved to the 2026 refinement round because "there is currently no clear, certifiable approach agreed at EU level"; the work focuses on common understanding and boundaries, with input from cryptographers and the ECCG, rather than deployment. Pseudonyms (topic E) are also in the refinement round (EUDI-ARF).
  • ZKP candidates under discussion include Longfellow (proposed as an IETF draft, IETF-draft-google-cfrg-libzk) and BBS (IRTF-CFRG-BBS-Signatures); ETSI is standardising BBS, Longfellow, Vega and OpenAC (DHG26-MS4).

Timeline and implementing acts

The EUDI regulation entered into force in May 2024 and gives member states 24 months, counted from the entry into force of the implementing acts, to offer a wallet, i.e. until 24 December 2026; relying parties that must accept the wallet follow a year later (BL26-SoK-AnonCreds). As of autumn 2026 the rollout is uneven: some member states (e.g. Italy's IT-Wallet) already run national wallets that are being upgraded, while others announced their wallets for 2027 or later. Five implementing regulations were adopted on 2024-11-28: integrity and core functionality (2024/2979), protocols and interfaces (2024/2982), person identification data and electronic attestations of attributes (2024/2977), certification (2024/2981) and notifications to the Commission (2024/2980). The first four are updated regularly to stay in sync with the ARF; the first amending acts (2026/1730, 2026/1731, 2026/1735) were published in 2026, together with the act on relying-party registration (2025/848).

The ARF itself reached v3.0.0 in July 2026: alignment with the amending acts, relying party services (topic X), wallet-to-wallet interactions (topic J), trust anchors from both ETSI Trusted Lists and Lists of Trusted Entities, and a Functional Conformance Assessment Framework with shared test cases (EUDI-ARF).

Technical stack of the reference implementation

Privacy: batch issuance vs. anonymous credentials

The regulation mandates strong privacy: the wallet's technical framework shall not allow issuers or any other party to obtain data that allows transactions or user behaviour to be tracked, linked or correlated, and shall enable privacy-preserving techniques which ensure unlinkability (eIDAS Art. 5a(16)) (BL26-SoK-AnonCreds). The ARF instead relies on classical ECDSA signatures with salted hashes for selective disclosure and batch issuance of one-time credentials for unlinkability. This cannot provide unlinkability when issuer and verifier collude, and unlinkability across verifiers requires a fresh credential for every presentation, which loads the issuer infrastructure and complicates key management on the device (BL26-SoK-AnonCreds, BBC+24-ARF-Feedback). The EU is now gathering requirements for an anonymous-credential standard; the options are compared in Anonymous Credentials.

Resources