AMLR and the EUDI Wallet: when you must accept it, and what is left
Blog post from Didit
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EU rules distinguish between the European Digital Identity (EUDI) Wallet acceptance obligation under eIDAS 2 and customer identity verification requirements under the Anti-Money Laundering Regulation (AMLR). eIDAS Article 5f(2) requires larger private service providers that are subject to strong online authentication requirements to accept compliant wallets at a user’s request, while exempting micro and small enterprises; based on the first implementing act’s entry into force, the text calculates this deadline as 24 December 2027. The AMLR, applicable from 10 July 2027, treats electronic identification at substantial or high assurance as one permitted method of identity verification, with EUDI Wallets meeting the high-assurance threshold, but it does not itself impose the broader wallet-acceptance duty in its operative provisions. A wallet can verify personal identity attributes that it contains, though firms must obtain missing information through other means and still complete separate due-diligence tasks such as identifying beneficial owners, assessing relationship purpose and risk, conducting sanctions and politically exposed person screening, and monitoring customers over time. Identity documents remain a valid alternative verification route, including for remote onboarding with appropriate safeguards, while proposed AMLA technical standards support the use of qualifying national eID schemes and wallets but were not yet legally binding at the time described.
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