This scorecard reflects publicly available information as of 27 April 2026 and will be updated rolling.
Update — 8 May 2026. Two changes since first publication. (1) Germany declined to deploy the Commission's white-label EU age-verification app on 29 April and will route age verification through the EUDI Wallet's age attribute instead — context unpacked in our member-state fragmentation post. (2) The Netherlands has been moved from Tier 3 to Tier 4: post-29 April reporting describes the Dutch wallet as officially missing the December 2026 deadline. Both changes are reflected below.
The deadline
Under Article 5a of the revised eIDAS Regulation (Regulation (EU) 2024/1183), every EU member state must make at least one EUDI Wallet available to its citizens, residents, and legal persons by 24 December 2026. The Article 5f obligations that follow are in many ways more consequential: by the end of 2027, banks and other relying parties in regulated sectors — payment service providers, telecommunications operators, and any service required to use strong user authentication for online identification — must accept the wallet when the user requests it (Article 5f(2)). Very large online platforms designated under the Digital Services Act sit under a parallel obligation in Article 5f(3) for user authentication on their services. The Commission's digital strategy page on EUDI Wallet implementation sets out the legal architecture and the implementing acts that have followed since November 2024. Eight months out from the citizen-availability deadline, and roughly twenty months out from the relying-party acceptance deadline, the picture across the EU 27 is anything but uniform.
Methodology
We classify each member state into one of four tiers:
- Tier 1 — Live or near-live: a wallet is in citizen hands today, even if officially still in beta, with credentials usable for at least one real-world flow.
- Tier 2 — Public beta or sandbox: a national wallet exists in testable form (developer sandbox, controlled pilot, or limited consumer beta) but is not yet a general-purpose citizen tool.
- Tier 3 — On schedule, public testing: a credible launch plan and dates exist, with at least documented testing or stakeholder engagement under way.
- Tier 4 — Late or unclear: no firm public timeline, no published architecture, or known slippage that puts December 2026 at material risk.
The criteria we score against are: (i) public launch announcement with a date or programme, (ii) verified pilot or beta access (citizens, businesses, or developers can actually try it), (iii) Article 5b register for relying parties operational or in pilot, and (iv) merchant or verifier SDK availability. We rely only on public sources — official government pages, industry trackers, and named stakeholder reporting. We do not score readiness on the basis of unverified vendor claims or marketing decks.
Tier 1 — Live or near-live
Italy — IT-Wallet (live in IO app)
Italy is the EU's stand-out. Through the IO app, Italian citizens can already digitise their driving licence, the European Health Insurance Card (TS-CNS), and the national ID card. The wallet is in the hands of millions of users and has been beta-testing additional credential types into early 2026. Namirial's regularly updated status check on EUDI Wallet rollout describes IT-Wallet as the most advanced national implementation in the bloc, with public sector authentication flows already live. Italian relying parties — including municipal services, healthcare portals, and a growing number of private-sector identity verification flows — have integration documentation that an external developer can follow without bespoke onboarding. The remaining questions are about cross-border interoperability with other member states' wallets, not about whether Italy will meet the December 2026 deadline. For merchants outside Italy, IT-Wallet is the single most useful learning environment because it is the only wallet where you can run end-to-end tests against real credentials issued to real users today.
Luxembourg — pilot complete
Luxembourg is the smaller surprise. The country participated in the POTENTIAL large-scale pilot, which wrapped its work in late 2025 and reported its findings in November. A national wallet announcement is pending, but the technical groundwork is done, the policy track is clearly funded, and the country's small population makes a clean rollout operationally tractable in a way it is not for Germany or Poland. Expect a public rollout announcement within the next two quarters. Luxembourg is also strategically relevant because of its outsized presence in EU financial services: a wallet that works there will be tested against banking and asset-management flows earlier than in most member states, which produces useful Article 5f(2) acceptance precedent for the wider bloc.
Tier 2 — Public beta or sandbox
France — France Identité sandbox
France has shipped the France Identité developer sandbox, with documented support for PID (person identification data) presentation in both proximity (face-to-face, NFC or QR) and online flows. The sandbox is good enough for verifier integration testing and has already been used by several large French relying parties — banks and government services in particular — to prototype OpenID4VP flows. What France does not yet have is a citizen-grade wallet of the IT-Wallet variety. The current France Identité app is a digital ID, not a full EUDI Wallet, and the migration path to the full Article 5a wallet is still being publicly clarified. France is on a clear trajectory but is not in Tier 1 yet. The country's policy preference for a sovereign French stack — visible in the explicit positioning of France Identité against US-hosted alternatives — is going to keep French rollout choices distinctive even after the broader EU framework converges.
Spain — Cartera Digital plus Royal Mint
Spain is running two parallel tracks. The Cartera Digital programme is the main consumer-facing effort, while the Royal Mint of Spain (Fábrica Nacional de Moneda y Timbre) is testing wallet credentials in a controlled university setting, primarily for academic credentials and student ID. The harder problem in Spain is bridging the legacy DNI electrónico smart-card system to the new EUDI Wallet credential model. That technical work is genuinely difficult — it touches PKI, card personalisation, and an installed base of card readers — and is the main reason Spain is not yet in Tier 1. Public testing windows have been announced and a citizen-facing beta is expected later in 2026. The autonomous communities add a further wrinkle: regional governments operate their own digital identity programmes (Catalonia's idCAT, the Basque Country's BAK), and the EUDI Wallet rollout has to find a coexistence model with them rather than steamrolling them.
Germany — scheduled 2 January 2027
Germany has officially scheduled its national wallet launch for 2 January 2027 — eight days after the Article 5a deadline. The federal Ministry for Digitalisation (BMDS) and Bitkom signed a memorandum of understanding committing more than 100 companies to integrate the wallet at launch, including the major banks, telcos, and online retailers. The accompanying Bitkom survey produced the most sobering single data point of the entire rollout: only five percent of German consumers can explain what an EUDI Wallet is. The technical readiness is high, the public awareness is not. Germany is the largest economy in the bloc and is going to miss the formal deadline by a hair, with a serious adoption gap to close after launch.
Update (29 April 2026). Germany has declined to deploy the Commission's white-label EU age-verification app and will route age verification through the EUDI Wallet's age attribute. For relying parties planning Article 5f flows in Germany, the wallet-attribute path is now the canonical integration target — the standalone EU app is not part of the German rollout. Cross-reference our activation-gap post for the user-side bottleneck this creates.
Tier 3 — On schedule, public testing
Ireland — end 2026
Ireland is on track. The Department of Public Expenditure, NDP Delivery and Reform has opened consultation and testing for the Government Digital Wallet on gov.ie. A specific point of public engagement is age assurance: the consultation explicitly addresses how the wallet will support age-restricted online services, which is a useful signal that Ireland is thinking about the merchant-side integration story and not just the citizen credential store. End-2026 is the stated target and the public artefacts are consistent with hitting it.
Sweden, Finland, Denmark, Austria, Belgium
This Tier 3 cluster is progressing roughly on the published roadmaps. Sweden, Finland, and Denmark — the Nordic group — are coordinating on credential harmonisation, leveraging their long history of cross-border digital identity collaboration through the Nordic Council, and have functioning developer programmes. Austria and Belgium are slightly behind the Nordics but have not signalled slippage. None of these countries are likely to be the early adoption story, but none are likely to miss the deadline outright either. Merchants integrating cross-border should plan for these wallets to be production-grade by Q2 or Q3 2027 rather than at the formal December 2026 mark.
Tier 4 — Late or unclear
Netherlands — officially missing the deadline
The Netherlands has moved from Tier 3 to Tier 4 since this scorecard was first published. Post-29 April reporting describes the Dutch national wallet as no longer expected to launch within the EU-mandated December 2026 window. The institutional pathway through DigiD and the GDI (Generieke Digitale Infrastructuur) architecture remains intact, and the engineering work is not in question — what changed is the public timeline. Treat the Dutch wallet as a Q2–Q3 2027 production target rather than a December 2026 launch. Cross-border merchants serving Dutch customers should plan to accept presentations from German, Italian, and French wallets through the first half of 2027 and add Dutch wallet support when it actually ships.
The wider Tier 4 group
This is where the picture deteriorates. The other countries in Tier 4 — Cyprus, Bulgaria, Romania, Malta, Slovenia, Slovakia, Croatia, Greece, Portugal, Estonia, Latvia, Lithuania, Czech Republic, Hungary, and Poland — present a mix of situations. Some, like Estonia, have strong existing national digital identity infrastructure (e-Estonia, mobile-ID, Smart-ID) but have not yet published a clear migration path to an Article 5a-compliant EUDI Wallet. Others, like Greece and Portugal, have made high-level commitments without published technical architectures or testing windows.
Biometric Update's December 2025 piece, "Will the EUDI Wallet be ready in 2026? Experts say probably not", captures the consensus among practitioners: a meaningful number of member states will formally launch a wallet by 24 December 2026 to satisfy Article 5a, but the wallets in this tier are likely to be thin shells — limited credential types, narrow use cases, and minimal merchant integration — for at least twelve months after launch.
Hungary and Poland deserve specific mention. Both have substantial existing eID footprints (Ügyfélkapu and mObywatel respectively) and both have signalled intent to comply, but neither has published a technical roadmap that a merchant or verifier could currently plan against. Hungary's situation is complicated by the recent migration from Ügyfélkapu to Ügyfélkapu+, which is consuming most of the country's available digital identity engineering capacity in 2026. Poland's mObywatel app is widely adopted domestically but its credential model does not yet align with the EUDI Wallet specification, and the integration work is non-trivial. Estonia is the most interesting case in this tier because the country's existing digital identity capability is in many ways more mature than what the EUDI Wallet specifies, and the strategic question is integration versus parallel operation rather than greenfield build. An Estonian e-resident, for example, already does in 2026 what most EU citizens are being told the wallet will let them do in 2027.
The honest assessment for Tier 4 is that the December 2026 deadline will be met formally but not substantively. Expect launches that allow citizens to download an app and store a basic credential, with the broader ecosystem of issuers and relying parties not catching up until well into 2027.
What this means for cross-border merchants
If you are running a checkout or an age-gated service that needs to accept EUDI Wallets across multiple member states, the practical guidance for the next two quarters is straightforward.
Prioritise integration testing against the wallets that are actually live or testable today. IT-Wallet in Italy is the single most important target because it is in citizen hands and will be the first wallet your real users present. The France Identité sandbox is the next priority because the developer documentation is public, the OpenID4VP flows are well-specified, and France is a large enough market to justify dedicated work. Germany's DMSO test environments and the documentation emerging from the BMDS-Bitkom programme are the third priority and should be on your roadmap for Q3 2026 at the latest.
Plan for asymmetric rollout. The merchants that win the first eighteen months of EUDI Wallet acceptance will be the ones that test against three or four national implementations in 2026, not the ones that wait for a single harmonised rollout that is not coming. Tier 4 wallets will not be production-grade for cross-border verification until late 2027 even where they are formally launched on time. Plan your customer support and your fraud rules accordingly: a "wallet not recognised" error is going to be a real user-experience problem in Bulgaria or Slovakia long after it stops being one in Milan or Lyon.
For high-volume verifiers, the cost of running multiple national integrations is real but bounded. The OpenID4VP protocol layer is consistent across implementations; the divergence is in trust list management, credential format support (mdoc vs SD-JWT), and the specific issuer registries each member state maintains. Build to that abstraction and the per-country marginal cost stays manageable. Practically, that means: a single OpenID4VP verifier endpoint, a per-country trust list resolver, and a credential parser that handles both ISO/IEC 18013-5 mobile documents (the format Italy and Germany are leading with) and SD-JWT VCs (the format France and several Tier 3 countries are emphasising). Build that core once and adding a new member state becomes a configuration change rather than a re-architecture.
The post-deadline reality
Even where wallets exist on 25 December 2026, the unsolved problem is cross-border interoperability. The POTENTIAL pilot consortium reported in November 2025 that common standards exist on paper but are applied with enough variation across member states to break real cross-border flows. A French citizen with a France Identité credential should be able to present it to an Italian verifier and have the verification succeed. In the pilot, that flow worked sometimes, did not work often, and required handhold integration work even when it did.
The post-deadline reality is therefore that the EUDI Wallet ecosystem will be live, partial, and uneven for most of 2027. The countries that succeed early will be those that make pragmatic integration choices rather than waiting for a perfect cross-border story.
Update note
This scorecard is a living document. We will re-publish it quarterly through 2027, with intermediate updates whenever a Tier 1 or Tier 2 country crosses a meaningful milestone — a citizen-grade launch, a sandbox going public, or a documented Article 5b register coming online. The next planned full update is July 2026, ahead of the autumn implementation push. If you spot a country status that has materially changed since publication, the canonical source for our updates is the eIDAS Pro blog.
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