European UnionCommission Implementing Regulation (EU) 2025/848: Registration of Wallet-Relying Parties
Commission Implementing Regulation (EU) 2025/848
An identity reliance rule binding public and private bodies.
- Obligation class
- Licensing
As of .
What it requires
- Register as a wallet-relying party by providing at least the information set out in Annex I to the national register of wallet-relying parties of the Member State where you are established, from (Art. 5(1), Art. 11).
- State, for each intended use, the data you intend to request, with a user-friendly name, a technical name and the attestation type, in a machine-readable format, and a description of the intended use of that data (Annex I, points 9 and 10).
- Provide your name, identifiers, establishment address, URL, contact information and a description of the services you provide, indicate whether you are a public sector body, and state the entitlement or entitlements you act under (Annex I, points 1 to 8, 11 and 12).
- Where you rely upon an intermediary acting on your behalf, indicate that you do and give your association to that intermediary in your registration (Annex I, points 14 and 15).
- If you are an intermediary to whom the wallet-relying party access certificate has been issued, acting on behalf of a relying party, give your association to the wallet-relying party that relies upon you (Annex I, point 16, added by Implementing Regulation (EU) 2026/1730).
- Ensure the information you provide is accurate at the time of registration (Art. 5(2)).
- Update any information you registered without undue delay (Art. 5(3)).
- Provide a URL to the privacy policy for the intended use, which is expressed in your registration certificate (Art. 8(2), point (g), and Art. 8(3)).
- When you no longer intend to rely upon wallet units for the provision of public or private services under a registration, notify the registrar without undue delay and request the cancellation of that registration (Art. 6(7)).
- Keep your registration accurate and current, within the attributes you registered and in line with the registration policy, because the registrar may suspend or cancel it otherwise, and must do so where a supervisory body or you request it (Art. 9(1) to (3)).
These lines are LexLint's reading of the law's text, as of .
Who enforces it
Enforcement body
The registrar each Member State designates for its national register of wallet-relying parties, which may suspend or cancel a registration under Article 9(2) and must do so where a supervisory body requests it pursuant to Article 46a(4), point (f), of Regulation (EU) No 910/2014 (Article 9(1)).
What this law does
Implementing Regulation (EU) 2025/848 lays down rules for the registration of wallet-relying parties, and Article 5(1) requires a wallet-relying party to provide at least the information set out in Annex I to the national registers. A wallet-relying party is a relying party that intends to rely upon wallet units for the provision of public or private services by means of digital interaction.
Article 5(2) and (3) require a wallet-relying party to ensure that the information it provides is accurate at the time of registration and to update any registered information without undue delay. Annex I requires, for each intended use, a list of the data the relying party intends to request and a description of the intended use of that data. Annex I also requires an indication whether the wallet-relying party is a public sector body.
Annex I requires, where applicable, an indication that the wallet-relying party relies upon an intermediary acting on behalf of the relying party who intends to rely upon the wallet. Article 6(7) requires a wallet-relying party that no longer intends to rely upon wallet units under a specific registration to notify the registrar without undue delay and request the cancellation of that registration.
Under Article 9(2) a registrar may suspend or cancel a registration where it has reason to believe that the registration contains inaccurate, out of date or misleading information, that the wallet-relying party is not compliant with the registration policy, that it is requesting more attributes than it registered, or that it is otherwise acting in breach of Union or national law in a manner related to its role as wallet-relying party.
Article 9(1) requires a registrar to suspend or cancel a registration where a supervisory body requests it pursuant to Article 46a(4), point (f), of Regulation (EU) No 910/2014. Article 7(2) requires Member States to ensure that wallet-relying party access certificates are issued exclusively to registered wallet-relying parties.
Implementing Regulation (EU) 2026/1730 requires Member States to ensure that providers of wallet-relying party registration certificates issue those certificates in an automated manner and without undue delay after the registration. Implementing Regulation (EU) 2026/1730 provides that registrars collect the Annex I information on contact details, services, requested data and intended use in an automated manner only for the purpose of transparency and apply no preauthorization process to it.
Article 10 requires registrars to keep the registered information, and any later change to it, for 10 years. Article 11 provides that Implementing Regulation (EU) 2025/848 applies from . Implementing Regulation (EU) 2026/1730 of amended Articles 6 and 8 and Annexes I, IV and V of Implementing Regulation (EU) 2025/848, and entered into force on .
When LexLint raises it
When your app profile says your app relies on a digital identity.