In short
A relying party may only request from the EUDI Wallet the data it registered for the intended use (Art. 5b(3) eIDAS). There is no pre-authorisation, but the wallet checks each request against the registration certificate and warns the user about anything outside it. Requesting more than registered can lead to suspension of the registration. The GDPR applies on top: even registered data may only be requested where it is necessary for the purpose.
A relying party may only request from the EUDI Wallet the data it registered for the intended use. That is the rule in Art. 5b(3) of the eIDAS Regulation. No authority approves requests in advance, but the wallet checks every request against the registration and shows the user who wants what and why. This guide covers which data exists, which rules apply and how to scope your requests.
What data the wallet holds
The wallet contains the person identification data (PID) – the digital ID data – and any number of attestations of attributes, such as a driving licence, student card or professional qualification. The PID of a natural person is defined in Implementing Regulation 2024/2977 as amended by 2026/1731:
| Attributes (data identifier) | |
|---|---|
| Mandatory | family name (family_name), given name(s) (given_name), date of birth (birth_date), place of birth (birth_place), nationality or nationalities (nationality); from 11 Aug 2028 the portrait (portrait) |
| Optional – the member state decides | residential address (full and in parts: country, region, city, postal code, street), personal administrative number, family name and given name at birth, sex, email address, mobile phone number |
| Metadata | issuing authority and country (mandatory); expiry date, document number, issuance date, issuing jurisdiction (optional) |
Each attribute can be shared on its own (selective disclosure). The PID tables contain no “over 18” field; age proofs come as separate attestations or additional attributes from the issuer, and implementations differ between member states.
The rules
- Register what you need. For each intended use you state which data you will request, with a user-friendly and a technical name, plus a description of the intended use (Art. 5b(2)(c) eIDAS, Annex I points 9 and 10 of Implementing Regulation 2025/848). See relying party registration.
- Request only what you registered. You may not ask users for anything beyond that (Art. 5b(3) eIDAS).
- No pre-authorisation. Since the amendment by 2026/1730, registrars collect data and intended uses for transparency only and must not pre-authorise them (Art. 6(3a) Implementing Regulation 2025/848). Whether a request is lawful is your responsibility.
- The wallet checks. The registration certificate expresses each registered intended use and a harmonised access policy. If a relying party requests data not listed there, the wallet informs the user (Art. 8(2)(c) and (d)). You must also provide a link to the privacy policy for each intended use (point (g)).
- Breaches have consequences. The registrar may suspend or cancel the registration of a relying party that requests more attributes than registered (Art. 9(2)(c)). Its certificates are then revoked; without a valid access certificate no request works.
- Accept pseudonyms. Where the law does not require identification, relying parties must not refuse pseudonyms (Art. 5b(9) eIDAS).
On the user side, the wallet provides control: the dashboard lists who received which data, users can request erasure under Art. 17 GDPR, and they can report suspicious requests directly to the data protection authority (Art. 5a(4)(d) eIDAS).
Registered does not mean allowed
The eIDAS rules only set the frame. Whether you may actually request an attribute follows from the GDPR: you need a legal basis (Art. 6) and data minimisation applies – only as much data as the purpose requires (Art. 5(1)(c)). Registering broadly “just in case” does not change that, and it is visible to everyone, because the registers are public.
Some examples of scoping requests:
| Process | Typical need | Not needed |
|---|---|---|
| Age check in online retail | age proof where available, otherwise date of birth | name, address, document number |
| Account opening with anti-money-laundering checks | name, date and place of birth, nationality, address (as required by AML law) | portrait, unless sector law requires it |
| Contract with a credit check | name, date of birth, address | nationality, place of birth (depending on the check) |
| Login to an existing customer account | pseudonym or a few attributes for matching | the full PID |
These examples are orientation, not legal advice. What a process really needs depends on sector law and your process.
Common mistakes
- Registering too broadly: an intended use “customer service” with the full PID looks disproportionate. Several narrow intended uses with few attributes each work better.
- New request without updating the registration: if a process or its data needs change, update the registration first (Art. 5b(6) eIDAS), then the request – otherwise the wallet warns users.
- Relying on optional attributes: address, email or phone number are optional and not every member state issues them. Processes need a path without them.
- Requesting the portrait without need: the portrait comes with a warning, explicit confirmation and a retention ban. See the portrait in the EUDI Wallet.
How request, approval and verification work technically: How the EUDI Wallet works.
FAQ
Does an authority approve which data we request?
No. Registrars collect data and intended uses for transparency only and must not apply any pre-authorisation (Art. 6(3a) Implementing Regulation 2025/848 as amended by 2026/1730). Specific rules in sector law remain unaffected.
What happens if we request more data than registered?
The wallet informs the user (Art. 8(2)(d) Implementing Regulation 2025/848). The registrar may suspend or cancel the registration of a relying party that requests more attributes than registered (Art. 9(2)(c)), and its certificates are then revoked. Users can also report such requests to the data protection authority directly from the wallet.
Can we request just “over 18” for an age check?
That depends on the credentials the wallet offers. The mandatory and optional PID attributes in the implementing regulation contain no “over 18” field, only the date of birth; age proofs come as separate attestations or additional attributes from the issuer. Where such an attribute is available, data minimisation favours it over the date of birth.
May we store the data afterwards?
That is governed by the GDPR and sector law, not by the eIDAS Regulation. The exception is the portrait, which generally may not be retained (Art. 3a Implementing Regulation 2024/2977).
Sources
- Regulation (EU) 2024/1183 (eIDAS 2.0), Art. 5a(4)(d) and Art. 5b – Official Journal of the EU (EUR-Lex), accessed 12/10/2026
- Implementing Regulation (EU) 2025/848, Art. 8, Art. 9 and Annex I – Official Journal of the EU (EUR-Lex), accessed 12/10/2026
- Implementing Regulation (EU) 2026/1730 amending 2025/848 (new Art. 6(3a), Art. 8) – Official Journal of the EU (EUR-Lex), accessed 12/10/2026
- Implementing Regulation (EU) 2026/1731, Annex (person identification data, Tables 1, 2 and 5) – Official Journal of the EU (EUR-Lex), accessed 12/10/2026
- General Data Protection Regulation (EU) 2016/679, Art. 5(1)(c) and Art. 6 – Official Journal of the EU (EUR-Lex), accessed 12/10/2026
Eudigo explains obligations and deadlines to the best of our knowledge but does not provide legal advice. The linked legal sources are authoritative.