knowledge 19 May 2026 |

Ireland moves forward with Digital Wallets

On 3 April the Department of Public Expenditure, Infrastructure, Public Service Reform and Digitalisation (the “Department”) launched a public consultation for a new “Government Digital Wallet”. As part of its development, the Government Digital Wallet will be available for pilot testing with the public. The Government has indicated that MyGovID will be used as the method to access Government Digital Wallets.

This is the first step in the Government’s efforts to comply with Regulation (EU) 2024/1183, which establishes the European Digital Identity Framework and amends and expands Regulation (EU) 910/2014 on electronic identification and trust services for electronic transactions in the internal market (known as the eIDAS Regulation) (together “eIDAS 2”).  In force since 20 May 2024, eIDAS 2 aims to create a harmonised framework for digital identity, which will allow EU citizens, residents and businesses to prove their identity or share verified information securely across Member States using digital credentials via ‘European Digital Identity Wallets’ (“EU Digital Wallets”).

Every Member State is required to provide at least one EU Digital Wallet by December 2026. The Irish Government has stated that mandatory acceptance by public bodies of the Government Digital Wallet is also due to commence by the end of 2026. Certain private service providers must also accept EU Digital Wallets by the end of 2027.

What is a Digital Wallet?

eIDAS 2 describes an EU Digital Wallet as an electronic identification means which allows the user to securely store, manage and validate ‘person identification data’ and electronic attestations of attributes for the purpose of providing them to relying parties and other users of EU Digital Wallets, and to sign by means of qualified electronic signatures or to seal by means of qualified electronic seals.

In other words, the EU Digital Wallet will be a mobile application that will allow individuals to store official documents (e.g. driver’s licences, IDs or educational qualifications) and submit them digitally when seeking to verify their identity, authenticate information or access services within the EU. Users of EU Digital Wallets will be able to verify their identity online, prove their educational or professional qualifications or provide company certificates using the Wallet. This will allow for easier online access for users to public and private services, such as applying for a bank account or a passport, or authenticating identity when logging into online platforms.

Users will also be able to use their EU Digital Wallet to support the issuance and validation of electronic attestations. This allows users to electronically verify the authenticity of certain ‘attributes’ or information against the relevant authentic source. By way of example, this could be using documents stored in the EU Digital Wallet to confirm an individual’s:

• civil status;
• nationality; or
• educational or professional qualifications.

Users will also be able to use an EU Digital Wallet to sign or seal documents by way of qualified electronic signatures or qualified electronic seals.

The use of EU Digital Wallets will remain completely voluntary for those seeking access to services. No public or private body may refuse services to an individual if they choose not to use an EU Digital Wallet to access services.

Who will be affected?

1.       Public bodies

To the extent that Member States require electronic identification and authentication to access an online service public sector body, they must also accept EU Digital Wallets to fulfil this requirement. The Irish Government has stated that “mandatory acceptance by public bodies is due to commence by the end of 2026”.

2.       Parties who require strong user authentication/ two-factor authentication

Private service providers who require their customers to use at least two forms of authentication for online identification, either because they are required to do so by law or by the terms of a contract, must accept EU Digital Wallets at the voluntary request of the user by December 2027¹.

This could include service providers in the areas of transport, banking, financial services, health, postal services, digital infrastructure, education or telecommunications.

3.       Very Large Online Platforms (VLOPs)

Providers of VLOPs² who require authentication for access to online services must accept and facilitate the use of the EU Digital Wallet for user authentication (but only on the voluntary request of the user). When doing so, VLOPs must continue to respect the principle of data minimisation.

4.       Other private service providers

Other private service providers may choose to accept Digital Identity Wallets as a method for authentication or to support electronic attestation, but it will not be mandatory for them to do so.

What will happen next?

• Transposition of eIDAS 2 – The Government will need to transpose certain aspects of eIDAS 2 into Irish law. For instance, eIDAS 2 requires Member States to implement penalties for infringement of eIDAS and also requires that Member States provide a way to revoke the validity of an EU Digital Wallet (for instance on the death of a user). The Summer 2026 Government Legislation Programme, published on 14 April 2026, indicates that heads of bill are in preparation for this legislation.
• Appointment of a Supervisory Authority – eIDAS 2 requires Member States to designate at least one supervisory body which will be tasked with supervising providers of EU Digital Wallets. Its functions will include enforcing the requirements eIDAS 2, carrying out inspections and submitting annual reports to the EU Commission.
• Formal Launch of the Government Digital Wallet – Following the public consultation and pilot phase, the Government Digital Wallet will need to be rolled out to the public by December 2026.
• Acceptance of Digital Identity Wallets – Public sector bodies, private sector bodies who require strong user authentication and VLOPs will need to prepare to facilitate the use of EU Digital Wallets. Service providers who intend to rely on EU Digital Identity Wallets for the provision of public or private services, will also be required to register in the Member State it is established.

If you want to keep up to date on the latest developments with the roll out of the Government Digital Wallet and eIDAS 2, please get in touch with us in the Technology & Innovation Group, or your usual contact at McCann FitzGerald.