November 2025 marked the digital identity sector's transition from experimentation to implementation. The EU concluded major pilots and proposed business wallets with projected annual savings of €150-225 billion. Ireland launched an ambitious Digital Public Services Plan targeting 100% online services by 2030. The UK achieved its first independent accreditation for certifying providers while navigating industry tensions.
For enterprises, this shift creates immediate clarity around compliance requirements and implementation timelines. The common challenge across all jurisdictions remains balancing government-led standardisation with private-sector innovation.
The European Commission proposed European Business Wallets on 19th November, introducing unified digital identity for businesses across the bloc. The proposal projects €150-225 billion in annual savings once fully adopted, with €5 billion in administrative cost savings achievable by 2029. Public sector bodies would be required to accept the wallets within two years of adoption.
Why this matters: This represents the EU's recognition that business identity is as significant as consumer identity, potentially generating savings that dwarf consumer applications. For enterprises, this creates a clear business case for digital identity infrastructure beyond customer-facing use cases. The mandatory public-sector acceptance requirement establishes a guaranteed market, reducing implementation risk. The projected €5 billion in near-term savings (by 2029) provides concrete ROI justification for investment decisions being made today.
Vidos perspective: The business wallet opportunity validates our focus on verification infrastructure that serves enterprises rather than consumer wallet provision. Businesses need to verify credentials from partners, suppliers, and employees across borders. Unlike consumer wallets where issuance and user experience dominate the conversation, business credentials require verification infrastructure that can handle complex policies, audit requirements, and integration with existing systems. The €150-225 billion savings potential comes from eliminating manual verification processes, and that's precisely where verification infrastructure creates value.
The POTENTIAL Large-Scale Pilot officially concluded on 27th November after running from April 2023 to September 2025. The pilot achieved 1,300+ tests across 140+ organisations from 19 Member States plus Ukraine, with 1,000+ successful transactions including 249 cross-border operations. Six use cases were validated: e-Government, bank account opening, SIM registration, mobile driving licence, qualified eSignature, and e-prescriptions.
Key findings from POTENTIAL emphasised that cross-border interoperability is "achievable but fragile," requiring EU-wide conformance testing. Coordinator Florent Tournois concluded: "POTENTIAL has proven that Europe can achieve cross-border interoperability, but only if we apply common standards rigorously. Security is not just about technology; it requires governance, certification, and liability."
Why this matters: This is the proof that the EUDI Wallet concept actually works across borders at scale. The 249 successful cross-border transactions demonstrate technical feasibility while the "achievable but fragile" finding highlights the critical importance of rigorous standards compliance. For organisations planning implementation, this validates the technology stack while emphasising the need for proper certification and testing. The conclusion of all four original Large-Scale Pilots marks the end of the experimentation phase and the beginning of production implementation.
Vidos perspective: The "achievable but fragile" finding resonates strongly with our experience. Cross-border interoperability breaks when organisations interpret standards differently or skip conformance testing. Verification is where these differences surface: credentials that technically validate but fail business rules, or credentials that work in test environments but fail in production under load. POTENTIAL proved the architecture works, but the fragility they identified is why relying parties need verification infrastructure that handles edge cases, provides clear error messages, and supports multiple standards versions during transition periods.
Germany accelerated implementation at the Franco-German Summit, signing a Memorandum of Understanding with over 75 organisations including IDNow, Persona, WebID, and Giesecke+Devrient. Signatories will present readiness assessments by Q3 2026, targeting gradual wallet usability by 2027. Both France and Germany announced a joint task force on European digital sovereignty covering cloud services, cybersecurity, and AI.
Why this matters: Germany's approach demonstrates how to mobilise private-sector resources and expertise at scale. The 75+ signatories represent the breadth of the digital identity supply chain, from identity verification providers to hardware manufacturers. These organisations are committing to readiness assessments and timelines, not just expressing interest. This provides a model for other Member States and signals strong industry confidence in implementation.
Vidos perspective: Germany's collaborative model shows how Member States can accelerate implementation by mobilising existing private-sector capabilities rather than building everything from scratch. The 75+ organisations span the full stack from wallet providers to relying party infrastructure. This creates partnership opportunities where component providers like Vidos can integrate with multiple wallet and identity providers through a single technical approach. The Q3 2026 readiness deadline also creates urgency. Organisations need verification infrastructure operational well before wallets launch to avoid being on the critical path.
The Architecture Reference Framework continues iterative development, with Iteration 3 running from 20th August to 26th November 2025. Version 2.3.0 addresses 24 open discussion topics with Member States and incorporates recent implementing regulations on qualified electronic attestations, registered delivery services, and preservation services.
Why this matters: The ARF provides the technical blueprint ensuring wallets remain interoperable across Member States. While less visible than policy announcements, this ongoing refinement is foundational to the ecosystem actually working. The resolution of 24 discussion topics shows Member States are working through implementation details, not just high-level concepts. For technical teams, tracking ARF changes is essential for avoiding integration rework.
All four original Large Scale Pilots have now concluded:
Two new consortiums have launched: APTITUDE for digital travel credentials and advanced banking, and WE BUILD with approximately 200 participants and a €25 million budget for B2B/B2G/B2C use cases.
Why this matters: The transition from experimental pilots (POTENTIAL, NOBID, DC4EU, EWC) to production-focused initiatives (APTITUDE, WE BUILD) signals the ecosystem moving from "can we do this?" to "how do we scale this?". The new pilots focus on specific high-value use cases rather than proving general feasibility. This progression from experimentation to implementation is a healthy sign that the technology has been validated and the focus is shifting to adoption and integration challenges.
Vidos perspective: The transition from experimental pilots to production-focused initiatives makes the Brussels Launchpad particularly timely. Members of the Vidos team will attend the EUDI Wallet Launchpad from 10th-12th December to engage with Member State representatives, pilot participants, and organisations preparing for implementation. With the Architecture Reference Framework resolving its final discussion topics and new consortiums like APTITUDE and WE BUILD focusing on specific use cases, the conversations have shifted from "can this work?" to "how do we implement this effectively?"
For organisations planning relying party infrastructure, this is an opportunity to discuss verification requirements before architectural decisions become locked in. The business wallet proposal adds another dimension: enterprise verification requirements differ significantly from consumer use cases, and early engagement helps ensure infrastructure can support both. If you'd like to discuss credential verification, policy design for complex use cases, or how to prepare for cross-border acceptance requirements, please get in touch to arrange a meeting.
Ireland launched the Digital Public Services Plan 2030 on 10th November, establishing the country's most significant digital identity policy milestone of the year. Ministers Jack Chambers and Emer Higgins announced targets of 100% of key public services available online and 90% of applicable services consumed digitally by 2030.
The plan introduces a "life events" approach, redesigning 17 priority life events between 2026-2028, including becoming a parent, starting school, learning to drive, and retiring. A Government Digital Wallet will store driver's licences, birth certificates, and European Health Insurance cards, integrated with a new Life Events Portal.
Cabinet approval came on 4th November, establishing a Public Services Digital Transformation Fund. As an example use case, a new parent could register a birth, apply for child benefit, and access birth certificates both digitally and physically all through a single integrated experience.
Why this matters: Ireland is the first EU Member State to publish a thorough digital identity roadmap with specific targets and timelines. The life events approach demonstrates how digital identity creates value beyond simple authentication, and it addresses the persistent criticism of digital identity that it solves a problem people don't recognise they have. By connecting digital credentials to tangible life milestones, Ireland has created a framework that other Member States are likely to adopt. The Cabinet-level approval and dedicated funding shows this is a political priority with resources behind it, not just a policy aspiration.
Vidos perspective: The life events approach creates clear use cases for verification infrastructure that go beyond simple "prove you're over 18" scenarios. A new parent registering a birth needs credentials verified to access multiple services simultaneously, benefits need to be calculated based on verified attributes, and credentials need to flow between different government departments. This multi-party, multi-credential complexity is where verification infrastructure creates value: ensuring credentials from different issuers all meet policy requirements and work together reliably. We've been preparing for Ireland's wallet rollout through discussions with several government departments, and the life events framework provides a practical structure for those conversations.
Ireland's MyGovID has established a substantial foundation with over 740,000 verified accounts across 140+ government services, targeting 80% citizen adoption by 2030. The government allocated €20 million for wallet development in 2025, with beta testing for the public wallet planned for late 2025.
Why this matters: Ireland's existing MyGovID user base provides a substantial foundation for wallet introduction, unlike Member States starting from zero. Citizens are already familiar with digital government services, reducing the behavioural change required for wallet adoption. The 80% target by 2030 is ambitious but achievable given existing momentum. For organisations planning services, this means a large user base will be ready to use digital credentials relatively quickly compared to other markets.
Minister of State Niamh Smyth signed the EU Declaration for European Digital Sovereignty on 18th November at a ministerial summit in Berlin. The declaration establishes a common framework for enhancing Europe's digital capabilities while preserving interoperability with international partners. Smyth stated: "By signing this Declaration, Ireland reaffirms its commitment to building a digitally sovereign Europe that protects our democratic values, supports innovation, and strengthens our economic resilience."
Why this matters: This signals Ireland's commitment to EU-wide digital identity standards rather than pursuing a purely national approach. For multinational organisations operating across Europe, this alignment reduces compliance complexity. The emphasis on interoperability with international partners also suggests Ireland will maintain pragmatic connections to UK and US systems despite European sovereignty goals.
Public Service Transformation Week (10th-14th November) showcased cross-departmental digital initiatives under the theme "Transformation at Scale," featuring sessions on AI in public services, Microsoft 365 implementation in the Courts Service, and a single online application system for schools.
Vidos perspective: Much of this foundational work is building towards a strong digital identity infrastructure. Once the wallet is introduced, opportunities will emerge to reduce fragmentation while keeping citizens safe with an identity they'll become familiar with using.
Mandatory identity verification for Companies House went live on 18th November, requiring directors and Persons with Significant Control to verify identity before incorporation or appointment. Over 1.5 million individuals had already verified voluntarily since April 2025, with average completion time of just 2.4 minutes. The implementation uses GOV.UK One Login or Authorised Corporate Service Providers.
Why this matters: This represents the UK's first mandatory digital identity verification for a major business process. It demonstrates that digital identity can move from optional convenience to regulatory requirement, setting precedent for other sectors. The 2.4-minute verification time and voluntary early adoption by over 1.5 million users proves the technology works at scale with acceptable user experience.
Vidos perspective: Mandatory verification for Companies House creates a clear market signal: digital identity is moving from optional to required. This validates the business case for verification infrastructure and creates opportunities beyond voluntary use cases. The over 1.5 million voluntary early adopters demonstrate market readiness, while the 2.4-minute average shows that proper implementation achieves acceptable user experience. For relying parties in other sectors, this provides proof that mandatory digital identity requirements can work in practice.
The Office for Budget Responsibility released the first official cost estimate for the national digital ID system: £1.8 billion over three years, comprising £1.3 billion in capital expenses and £0.5 billion in operating costs. Notably, "no specific funding has been identified" for the digital ID cards.
Why this matters: This is the first transparent cost assessment for UK digital identity infrastructure, providing the scale of investment required. However, the lack of identified funding creates uncertainty for implementation timelines. For enterprises planning integration, this signals both the government's commitment (evidenced by detailed costing) and potential delays (evidenced by missing funding).
Following industry concerns, Chief Secretary Darren Jones announced a 2nd December roundtable with DIATF-certified providers. The Association of Document Verification Professionals had issued an open letter on 7th November requesting continued commitment to DIATF. ADVP Chair David Crack stated: "We have been banging on the door, now we have been let in.“
Why this matters: The reopening of dialogue suggests the government recognises the need for private-sector expertise in implementation. This balance between government-led standards and private-sector delivery determines whether the UK maintains its competitive digital identity industry while achieving policy goals. The December roundtable could resolve uncertainty about the role of existing DIATF-certified providers.
The Office for Digital Identity and Attributes published substantial guidance throughout November, including updates on certification requirements and confirmation of user understanding requirements. A major platform update on 21st November added new filtering, sorting, and CSV download capabilities to the DIATF register.
The United Kingdom Accreditation Service (UKAS) granted accreditation to Kantara Initiative on 13th November, making it the first conformity assessment body authorised to certify organisations against the Digital Identity and Attributes Trust Framework, enabling independent private-sector certification of digital identity providers.
Why this matters: These infrastructure improvements make it easier for organisations to find certified providers and understand requirements. The certification capability demonstrates the framework is maturing from policy to operational reality.
Vidos perspective: Vidos is positioned to support existing identity providers as they introduce re-usable identity credentials and prepare for wallet integration. We've also been running training workshops for organisations exploring digital ID implementation, helping teams understand DIATF requirements and how to prepare for GOV.UK Wallet acceptance.
Several themes emerged across all three regions during November that reveal the current state of digital identity implementation.
Member States must provide EUDI Wallets by December 2026, with regulated industries required to accept them by November 2027. The EU targets 80% citizen adoption by 2030, aligning closely with Ireland's MyGovID target.
Why this matters: These are not aspirational targets but legal requirements. The 14-month window to December 2026 means Member States are now in active implementation, not planning. For enterprises, this creates a predictable market where digital identity infrastructure will be required, not optional. The 2027 deadline for regulated sector acceptance means financial services, insurance, and major platforms must begin integration now to meet compliance timelines.
The UK saw explicit industry pushback on government wallet plans, with providers lobbying to preserve their DIATF-certified role. The EU and Germany emphasised collaboration, with 75+ organisations signing partnership commitments. Ireland positioned its wallet as complementary infrastructure rather than competitive.
Why this matters: The approach each jurisdiction takes to public-private balance will determine market structure and opportunities. The UK's tension suggests a more competitive market where private providers maintain distinct roles. Germany's collaborative model suggests shared infrastructure where private providers integrate with government systems. Ireland's complementary approach suggests government provides baseline capability while private sector adds value on top. For vendors, this means different go-to-market strategies across jurisdictions.
The UK's £1.8 billion estimate lacks identified funding sources. EU pilots received €46 million+ in total funding, with new initiatives like WE BUILD securing €25 million. Ireland allocated €20 million for 2025 wallet development.
Why this matters: Announced budgets without identified funding (UK) signal political commitment but implementation uncertainty. Actual allocated funding (Ireland, EU pilots) signals projects moving forward regardless of policy debates. For enterprises planning integration timelines, funded programmes are more reliable indicators of actual delivery dates than policy announcements.
The European Commission's Business Wallet proposal potentially generating €150-225 billion annually signals that business identity represents as significant an opportunity as consumer applications. The Tony Blair Institute proposed a UK "digital identity for business" launching in 2027 with estimated £1.7 billion in annual compliance savings for financial services alone.
Why this matters: This fundamentally changes the digital identity value proposition from a consumer convenience feature to a core business infrastructure investment. The scale of projected savings in B2B contexts exceeds consumer applications, suggesting enterprises should prioritise business credential use cases alongside or even before consumer credentials. For Vidos, this validates our focus on enterprise verification infrastructure rather than consumer wallet provision.
Vidos perspective: The convergence of business wallet proposals across UK and EU creates a clear opportunity window. Business credentials require different verification infrastructure than consumer credentials: higher assurance levels, complex policy rules, audit trails, and integration with enterprise systems. Organisations should be preparing now to verify business credentials when they arrive, not waiting until 2027 when regulatory deadlines create urgency. The €150-225 billion savings opportunity comes from automating verification processes that currently involve manual document review, phone calls, and email exchanges. This is exactly the infrastructure gap Vidos addresses.
The experimentation phase is over. The conclusion of all four original Large-Scale Pilots, the publication of broad implementation plans from Ireland, and mandatory production deployments like Companies House mark the transition from "can we do this?" to "how quickly can we deploy?". Organisations waiting for more proof of concept will find themselves behind those already implementing.
Business identity offers larger opportunities than consumer identity. The €150-225 billion in projected annual savings from European Business Wallets dwarfs consumer applications. For enterprises, this means digital identity infrastructure investments should prioritise B2B use cases: supplier onboarding, corporate authority verification, cross-border business credentials, and regulatory compliance credentials.
Standards are converging, reducing integration risk. W3C Verifiable Credentials, ISO/IEC 18013-5 for mobile driving licences, and OpenID protocols for presentation and issuance are becoming the common stack across UK, EU, and Ireland. Organisations investing in standards-based infrastructure today avoid the risk of backing proprietary approaches that become obsolete.
Regulatory deadlines create predictable markets. December 2026 for EUDI Wallet availability and December 2027 for mandatory acceptance in regulated sectors means digital identity verification infrastructure will be required, not optional. This removes market uncertainty about whether digital credentials will achieve adoption.
Cross-border interoperability requires rigorous standards compliance. POTENTIAL's finding that interoperability is "achievable but fragile" highlights that testing and certification are not optional extras but essential requirements. Organisations planning implementations should budget for conformance testing and certification processes, not just technical integration.
Implementation support reduces time-to-market. Vidos has been running training workshops on eIDAS 2.0, EUDI Wallet implementation, and digital credential verification for compliance teams, technology architects, and business leaders. These sessions cover regulatory frameworks, technical architecture, and practical integration patterns.
Vidos provides the verification infrastructure layer. Rather than building verification capabilities in-house or waiting for wallet providers to offer verification services, organisations can deploy standards-based verification infrastructure now. Vidos supports W3C Verifiable Credentials, ISO/IEC 18013-5 for mobile driving licences, and OpenID protocols across UK DIATF, EU eIDAS 2.0, and Irish Government Digital Wallet requirements. This standards-based approach means a single integration supports credentials from multiple issuers and jurisdictions, reducing both technical complexity and ongoing maintenance burden.
November 2025 marked digital identity's transition from experimentation to implementation. The UK achieved critical certification infrastructure and deployed its first mandatory verification requirement. The EU concluded foundational pilots, proposed business wallets with €150-225 billion in projected savings, and proved cross-border interoperability works at scale. Ireland established a concrete decade-long roadmap with the most extensive national plan published to date.
The common pattern across jurisdictions is clear: the technology works, the standards are converging, and the deadlines are firm. The remaining questions are about implementation approaches, not technical feasibility.
For organisations, this creates both clarity and urgency. Digital identity verification infrastructure will be required for regulated sectors by December 2027. The opportunity lies in business identity applications that generate larger savings than consumer use cases. The risk lies in delayed implementation that leaves organisations scrambling to meet compliance deadlines.
Interested in our training workshops on digital identity implementation?
Want to discuss digital credential acceptance, verification infrastructure, or eIDAS 2.0 compliance?
Contact us to arrange a conversation.
For organisations attending the EUDI Wallet Launchpad in Brussels (10th-12th December), reach out to arrange a meeting with the Vidos team to discuss verification infrastructure and relying party requirements.
This monthly update distils regulatory developments, funding announcements, and implementation milestones affecting digital identity across the UK, EU, and Ireland. For organisations navigating compliance requirements or exploring digital credential adoption, Vidos provides verification infrastructure that supports any credential format through standards-based APIs.
