On 19 February, a draft amendment to the Act on Trust Services and Electronic Identification, as well as certain other acts, was published. The aim of the proposed changes is to align Polish law with the revised eIDAS Regulation (EU 2024/1183). The draft introduces, among other things, the European Digital Identity Wallet (EUDI Wallet), new rules for electronic identification, and solutions concerning electronic signatures and electronic attestations of attributes (EAA).
Scope of the amendment
The draft covers changes to four acts:
- the Act on Trust Services and Electronic Identification,
- the Act on the Computerisation of Activities of Public Entities,
- the Act on e-Delivery,
- the Act on the mObywatel application.
European Digital Identity Wallet (EUDI Wallet)
EUDI Wallet is a key element resulting from the amendment to the eIDAS Regulation. Member States are required to provide a wallet for both natural and legal persons. The Regulation defines functional requirements as well as certification obligations. In Poland, implementation is planned for 24 December 2026. The wallet will function as a means of electronic identification within a national system notified to the European Commission and will be integrated into the national electronic identification node. The source of identification data will remain the PESEL register, and the basic dataset will include first name, last name, date of birth, and the PESEL number.
EUDI Wallet and the mObywatel application
The EUDI Wallet and the mObywatel app will, at least for the time being, operate as independent solutions. The draft does not provide for data exchange between them or full functional equivalence. This results from differing technical and regulatory requirements.
Wallet certification
EUDI Wallet certification will be carried out in two stages:
- cybersecurity – in accordance with the national certification system,
- other requirements – based on the Act on Trust Services and Electronic Identification.
Trusted profiles of public entities
The draft introduces:
- a trusted profile for a public entity,
- a trusted profile for a natural person representing a public entity.
The public entity profile serves as a means of identifying a legal person, while the natural person profile enables acting on its behalf. These solutions are linked to the trusted profiles of natural persons authorised to represent such entities.
User identity verification
The EUDI Wallet onboarding process provides for three possible methods of identity verification:
- a personal profile (high level of assurance),
- a trusted profile combined with additional verification compliant with eIDAS,
- in-person identity verification at a confirmation point using an identity document.
Verification points will be operated by regional governors (voivodes). It will also be possible – subject to the consent of the minister responsible for digital affairs – for domestic banks and selected local government units to perform this function.
Identity of legal persons
The draft defines a minimum dataset for identifying legal persons in line with eIDAS requirements. A wallet for a legal person will be available only to users who already possess a EUDI Wallet as natural persons. Obtaining it will require authentication and the presentation of a qualified electronic attestation of attributes confirming the right of representation. The possibility for sole traders (natural persons conducting economic activity) to obtain a wallet is also provided. No separate application for legal persons is planned. However, further EU regulations on business wallets may influence this approach.
Electronic Attestations of Attributes (EAA)
Electronic Attestations of Attributes is a new trust service introduced by the amendment to the eIDAS Regulation. They enable users across the EU to digitally prove specific rights and data (e.g. a driving licence or a diploma) directly within the wallet, based on verification against official registers. The draft refers to the direct application of the provisions of the EU eIDAS Regulation, including the formats specified in its annexes. Attribute verification will be carried out by competent public authorities responsible for the relevant registers. The minister responsible for digital affairs will be tasked with submitting applications to the European Commission regarding attribute catalogues and attestation schemas. It is not anticipated that current documents from the mObywatel app will be used in this process.
Electronic signature in the wallet
The draft provides for the possibility for EUDI Wallet users to create qualified electronic signatures free of charge. The signature will be executed using qualified devices and services provided by trust service providers, as end-user devices (e.g. smartphones) do not meet certification requirements. The service:
- will be available exclusively for non-professional purposes,
- will be provided by qualified service providers,
- will be subject to a cost compensation mechanism,
- will be coordinated by the minister responsible for digital affairs.
Documents signed in this way will be appropriately marked to enable identification of the nature of the signature’s use. The draft does not provide for sanctions for misuse; however, such markings are intended to allow relying parties to assess trustworthiness. No changes are planned to align the trusted signature or personal signature with qualified signature requirements.
Catalogue of Public Entities (CPE)
In the area of electronic delivery, the draft introduces the Catalogue of Public Entities (CPE), intended to enable verification of entity data, particularly for the purposes of the register of relying parties and its updates.
Entry into force
The draft assumes that the provisions will enter into force on 24 December 2026, with certain exceptions. It provides for the possibility of earlier use of the EUDI Wallet in domestic public services as a means of electronic identification at a substantial level of assurance, even before full certification is completed. Some provisions concerning legal persons and related identification mechanisms are to enter into force at a later date.
Publication date: 24.03.2026