There is a lot of discussions recently touching on the future of public digital identity wallets and what the future holds in store for the technology.
In part, this may have been spurred on by change after testing phases of the first Large Scale Pilots (LSPs), which are due to complete at the end of 2025 and the new second selections of LSPs. The deadlines for citizen availability of digital wallets available in 2026 and their eventual day-to-day acceptance in use by late 2027. The LSPs have done a good job in ironing out and understanding many of the practical issues of using an EUDI wallet.
There is also a new UK wallet initiative, and the mushrooming Mobile Driving License deployments and use in the USA. It is a bewildering array of different wallets types, methodologies and limitations.
To its credit with the EUDI Wallet, the European Commission has specified a standard technology for use across all Member States (MS) and that they should be distributed free-of-charge to citizens. Uncertainty arises as each MS has the responsibility to deploy the digital wallet themselves. Many of the MSs will try to achieve that, but likely there may be joint efforts, and some may just be delayed. The question is what these government issued digital wallets will be used for. They are required to be Level of Assurance High (LOA3) and therefore any credentials, attributes that are used must . This may limit use to the ‘standard’ offerings of passport, driving license, diplomas, permits etc which are likely to already be able to be distributed via the existing EU digital channels. OK, these credentials will now be under the control of the citizen holder (not necessarily owner) for distribution, or partial distribution. This is good but hardly ground shaking. Unless there are clear guidelines set out ‘Real Soon Now’, these EUDI Wallets may become a footnote in the history of Digital Wallets.
It is intended that the EUDI Wallets will be used in business to business (B-2-B) too, with a number of business use cases within the LSPs already, many relating to payments. There is some doubt as to whether their eventual take up for payments will be massively successful, as there is already a proliferation of payment methods existing. However, there may be lots of mileage for payments being a part of a business centred workflow, and the use cases for business could be substantial.
More confusing is the UK Digital Wallet. The UK Government has made a lot of really loud noise about their ‘new’ UK Government Wallet – enough to disrupt the market – but without really explaining how they plan to make one available in a fraction of the time it has taken for the private sector. Unless of course they take an off-the-shelf wallet. But there is no sign of that and no sign of any procurement process. But they do say that the wallet will include capability for storing a mobile driving license, so it must be serious (?). The UK private sector DIATF initiative for a trust framework will be wondering if many of its members will be able to remain in business when fighting in competition against the UK Government wallet whenever that actually starts. Questions remain unanswered: Who will be able to use this wallet? What will be the minimum specification for the carrier device? Will there be any government liability? There has been no public or industry discussions, no tenders for development, no inclusion policy, and in fact not much of anything except a newly stated official willingness to possibly consider the Apple and Google Wallets for use. This has the recipe of being totally divisive and could put arguments for eIDs and digital wallets in the UK backwards for another 10 years if mishandled! Unless of course the announcement is just hot wind, with the ‘wallet’ being nothing more than a glorified Gov.UK. Let’s face it, a simple, simple on-line wallet is also just called an ‘App’.
So this brings me on to the USA. The use of mDLs as identity, credential and attributes carriers, has grown by natural demand. The concept is quite nice in that it uses a carrier (the driving license) that is well known and almost ubiquitous. Everyone (almost everyone) drives in the USA. – Unless you do not…. Then you do not have access to the credential carrier or its benefits. Undisclosed is what happens if your driving license is revoked? (100mph in a 55mph zone, together with half a bottle of bourbon!) Do they take the license away from the driver, or just remove the driving credential? (is it then still an mDL?). What if you cannot drive due to disability or if you live in the city and have no desire to drive? I guess that in the USA, if you are old, disabled, too young, or a drunkard, then you may lose the ability to assert your citizenship rights easily.
Now let’s look at the herd of elephants in the room…..Privately developed digital wallets and industry (organisational) wallets. (I do not want to discuss the “other, other wallets” yet – those intended for IOT.)
These privately developed digital wallets are the ‘rays of hope’ for the future – on many levels. Privately developed wallets and organisational use of those wallets go hand in hand by necessity. Industry and other organisations have money to pay for their own improved processes as well as business efficiencies. Digital Wallet developers need income to continually develop and improve their products, as well as to repay investors. It is a marriage made in heaven. The consumer, whether part of the transaction or indirectly part of it by outcome, does not lose. Even B-2-B transactions ultimately benefits the consumer. There are additional benefits for business: An example is a tailored set of terms and conditions – not governed by regulation – means that liability and rules can be set between counterparties. Even ultimately on a transaction-by-transaction basis. Special functionality is not hampered by the Architectural Reference Framework (ARF), and there is plenty of room for innovation and customisation. Wallets can be used for any part of a business process, such as onboarding as a carrier for KYC documentation in a lengthy workflow where the company holds its own KYC documents and can use them as it needs. Regulatory licenses, Health and Safety statements, conformity declarations, are other examples, to name just a few. It is actually a win-win for all. A little like the fax machine was in the 1980s. However, unlike that example, the wallet can and will evolve rather than being a static technology artefact.
Am I hopeful? – YES extremely - exciting times ahead!
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