Key takeaways
- Press reports in mid-September said 24 of the 27 Member States are expected to miss the legal deadline of 24 December 2026.
- Italy is far ahead, with close to 8 million monthly users. France and Finland are also among the most advanced, because they are building on existing apps.
- Germany is aiming for a launch on 2 January 2027 with limited functionality. The Netherlands has pushed its rollout to late 2027.
- The European Commission's Launchpad 2026 event (29–30 October, Brussels) will be the next public checkpoint.
- For banks, the planning dates stay the same: 10 July 2027 (the EU AML Regulation applies) and 24 December 2027 (the deadline to accept the wallet).
What changed since September
Our September tracker listed the official readiness category of each country. Since then, press reports have looked at what is actually in the hands of citizens, and the picture is worse. According to reporting by Euronews on 16 September 2026, only three Member States have delivered a wallet so far. The other 24 are expected to miss the deadline set by Regulation (EU) 2024/1183 (eIDAS 2).
Country snapshot
| Country | Status (early October 2026) |
|---|---|
| Italy | Most advanced: close to 8 million monthly users of its existing wallet app. |
| France, Finland | Among the most advanced, converting existing digital identity apps into EUDI wallets. |
| Croatia | Close behind. Certilia Wallet has been confirmed as the basis of the national EUDI Wallet. |
| Germany | Launch planned for 2 January 2027, with limited functionality at first. |
| Netherlands | Rollout pushed to late 2027, after a pilot reached only 57 users. |
| Greece, Slovakia | Still in private testing. |
| Bulgaria | The national law needed to issue a wallet is still being drafted. |
| Sweden | Earliest expected release: 2028. |
Standards are not finished either. Civil society experts estimate that alignment with the technical standards is only around 50 to 60 percent complete. Digital rights groups such as EDRi have also criticised draft rules on facial recognition and privacy safeguards.
Does the delay move the bank deadline?
No. Nothing published so far changes the obligation for regulated relying parties such as banks to accept the EUDI Wallet by 24 December 2027. In practice, the delay has two effects:
- Fewer wallets to test with in 2027. Your first live integrations will probably cover only a few countries, starting with Italy, France and Germany.
- A stronger case for working through a provider. National wallets will arrive at different times and with different features. A KYC provider that adds each wallet as it launches saves you from rebuilding every quarter.
The EU Anti-Money Laundering Regulation, which applies from 10 July 2027, recognises electronic identification means under eIDAS for remote customer due diligence. Plan your onboarding redesign around both dates.
What to do this quarter
| If you… | Recommended action |
|---|---|
| Onboard customers in Italy or France | Start testing now. These wallets will have real users first. |
| Onboard customers in Germany | Prepare for a limited launch in January 2027, and plan a pilot rather than full production. |
| Operate in several EU markets | Ask your KYC provider for its wallet support roadmap, country by country. |
| Have not started yet | Use the delay to choose a provider and design the flow. Do not delay the 2027 budget. |
See our integration guide for a quarter-by-quarter plan. We will update this tracker after the Commission's Launchpad event at the end of October.
Euronews, "EU digital wallet: 24 of 27 members will miss the deadline" (16 September 2026); Biometric Update, "EUDI Wallet deadline nears as Europe's rollout picture remains uneven" (September 2026); eIDEasy, EU Digital Identity Wallet Status Update (2 September 2026); European Commission, EU Digital Identity Wallet Launchpad 2026; Regulation (EU) 2024/1183 (eIDAS 2); Regulation (EU) 2024/1624 (AMLR). This article is general information, not legal advice.