EU Digital Identity Wallet (EUDI) and Online Gambling: How eIDAS 2.0 Will Transform Player Verification and KYC Compliance

What Is the EU Digital Identity Wallet?

The EU Digital Identity Wallet (EUDI Wallet) is a secure digital application that will allow all EU citizens, residents, and businesses to store and present verified identity credentials from their smartphones or other devices. Mandated by Regulation (EU) 2024/1183, commonly referred to as eIDAS 2.0, the wallet framework builds upon the original 2014 eIDAS regulation but introduces a fundamentally new approach to digital identity across Europe.

Unlike the original eIDAS framework, which established mutual recognition of national electronic identification schemes but saw limited cross-border adoption, eIDAS 2.0 requires every EU member state to issue at least one EUDI Wallet to its citizens and residents. The regulation entered into force on May 20, 2024, with member states required to make wallets available by late 2026 to mid-2027, depending on specific implementation milestones.

For the online gambling industry, the EUDI Wallet is not merely a technical upgrade. It represents a potential paradigm shift in how operators perform Know Your Customer (KYC) and age verification checks, how players prove their identity across borders, and how regulators enforce compliance with licensing and responsible gambling requirements.

How eIDAS 2.0 Applies to Online Gambling

The eIDAS 2.0 regulation establishes that online service providers required by national or EU law to perform strong customer identification must accept EUDI Wallets for that purpose. This has direct implications for the gambling sector, where operators are legally obligated to verify player identity under multiple regulatory frameworks.

Legal Triggers for Mandatory Wallet Acceptance

Online gambling operators across the EU are subject to identity verification requirements from several overlapping legal frameworks:

• National Gambling Licensing Laws: Every EU country with a licensing regime requires operators to verify player identity before allowing real-money play. This verification constitutes "strong customer identification" under eIDAS 2.0.
• Anti-Money Laundering Directives: The EU's AML framework classifies gambling as a regulated activity requiring Customer Due Diligence (CDD), including identity verification at specified thresholds. The new Anti-Money Laundering Authority (AMLA), operational since July 2025, reinforces these obligations.
• Age Verification Requirements: All EU jurisdictions mandate age verification for gambling, with minimum ages ranging from 18 to 23 depending on the country and gambling product. EUDI Wallets can provide cryptographically verified proof of legal age.
• Self-Exclusion Registries: Countries operating national self-exclusion systems require identity matching to check player status against exclusion databases, another use case for verified digital identity.

The Selective Disclosure Advantage

One of the most significant features of the EUDI Wallet for gambling is selective disclosure. This cryptographic capability allows a player to prove specific attributes (such as "I am over 18" or "I am a resident of Germany") without revealing their full identity document or date of birth. This represents a substantial improvement over current KYC methods in both privacy protection and verification reliability.

Current gambling KYC processes typically require players to upload copies of passports, national ID cards, or utility bills. These documents contain far more personal information than necessary for gambling verification and create data protection risks if the operator's systems are compromised. Under GDPR obligations, operators must also justify collecting and storing this data, and retain it only as long as necessary.

With EUDI Wallet-based verification, an operator receives a cryptographically signed attestation that a specific claim is true (e.g., the player is over 18 and is a resident of the Netherlands), without needing to process or store the underlying identity document. This aligns with GDPR's data minimization principle and reduces the operator's data protection compliance burden.

Current State of EUDI Wallet Development

As of early 2026, the EUDI Wallet ecosystem is progressing through several parallel development tracks. The EU Digital Identity Wallet Consortium and multiple large-scale pilot projects are testing wallet functionality across various sectors, including financial services, travel, and government services.

Large-Scale Pilot Programs

Four major EU-funded pilot programs have been testing EUDI Wallet functionality since 2023:

• EU Digital Identity Wallet Consortium (EWC): Led by Sweden and involving over 50 organizations across 19 member states, this pilot tests wallet issuance, identity verification, and cross-border recognition.
• POTENTIAL: Focused on payment integration, mobile driving licenses, and identity verification for financial services, with direct relevance to gambling payment processing.
• NOBID: A Nordic-Baltic pilot exploring wallet use in banking, telecommunications, and government services, with participation from Denmark, Estonia, Latvia, and Iceland.
• DC4EU: Concentrated on education and social security credentials, establishing cross-border attestation standards applicable to other sectors.

While none of these pilots explicitly target gambling, the financial services and payment verification use cases being tested are directly transferable to gambling operator KYC workflows. The Architecture and Reference Framework (ARF) published by the European Commission provides the technical specifications that gambling operators will need to implement.

Implementation Timeline

The eIDAS 2.0 regulation establishes a phased implementation schedule:

Impact on Gambling KYC and Player Onboarding

The EUDI Wallet will likely transform the player registration and verification process at multiple stages.

Registration and Account Opening

Current player onboarding for EU gambling operators typically involves a multi-step process: email registration, manual document upload (passport or ID card), address verification (utility bill or bank statement), and sometimes video verification calls. This process can take hours to days and creates friction that discourages legitimate players while consuming significant operator resources.

With EUDI Wallet integration, the entire verification process could be reduced to a single step. A player presents their wallet credentials, and the operator receives cryptographically verified attestations of identity, age, address, and nationality within seconds. No document uploads, no manual review, no waiting periods.

Cross-Border Player Verification

For players who gamble with operators licensed in other EU member states, a topic covered in our guide to cross-border online gambling in the EU, the EUDI Wallet offers particular advantages. A German citizen wishing to register with a Spanish-licensed operator could present their German-issued EUDI Wallet, and the Spanish operator would receive verified attestations recognized across the EU. This eliminates the complications operators currently face when verifying foreign identity documents.

Enhanced AML Compliance

The EUDI Wallet integrates with the EU's evolving AML framework. As the Anti-Money Laundering Authority (AMLA) enhances cross-border AML supervision, wallet-based identity verification provides a standardized mechanism for Customer Due Diligence that satisfies requirements across multiple jurisdictions simultaneously. Operators currently managing separate KYC procedures for each licensed market could potentially streamline to a single wallet-based verification process.

Country-by-Country Considerations

While eIDAS 2.0 is an EU-wide regulation, its implementation intersects with national gambling laws in different ways depending on each country's regulatory structure.

Germany

Germany's gambling framework under the Interstate Treaty on Gambling (GlStV 2021) already mandates robust identity verification through the GGL (Gemeinsame Glucksspielbehorde der Lander). The German government has been among the most active in EUDI Wallet development, with the Bundesdruckerei leading national wallet implementation. Germany's existing OASIS self-exclusion system could integrate with EUDI Wallet credentials to enable real-time exclusion checks during player authentication.

Netherlands

The Netherlands' Kansspelautoriteit (KSA) has emphasized stringent identity verification since the regulated market opened in October 2021. The Dutch government's DigiD system provides a foundation for EUDI Wallet integration, and the KSA's requirement that operators verify player identity before allowing any gambling activity aligns with the wallet's instant verification capabilities.

Italy

With Italy's new nine-year licensing regime imposing the highest license fees in the EU (EUR 7 million per license), operators have strong incentives to reduce operational costs. EUDI Wallet integration could significantly lower KYC processing expenses while meeting ADM (Agenzia delle Dogane e dei Monopoli) verification requirements. Italy's existing SPID digital identity system provides institutional experience with digital identity infrastructure.

France

France's ANJ (Autorite nationale des jeux) regulates a partially liberalized market where sports betting and poker are licensed but online casino remains prohibited. The French government's France Identite application, launched as a precursor to the EUDI Wallet, is already testing digital identity verification in financial services. For the gambling sector, ANJ could mandate EUDI Wallet acceptance as a condition of license renewal, providing verified age and identity data that is more reliable than current methods.

Spain

The DGOJ (Direccion General de Ordenacion del Juego) in Spain has progressively strengthened identity verification requirements. Spain's participation in the POTENTIAL pilot program positions it well for EUDI Wallet adoption. The existing ClavePin digital identity system provides a transition path toward EUDI Wallet integration for gambling operators.

Privacy, Data Protection, and Player Rights

The EUDI Wallet framework incorporates strong privacy protections that address several ongoing concerns in the gambling sector.

Data Minimization in Practice

Under current KYC procedures, operators collect and store extensive personal data including passport images, date of birth, full address, and sometimes source-of-funds documentation. This creates substantial GDPR compliance obligations and security risks. In 2024 alone, several EU gambling operators reported data breaches exposing player identity documents.

EUDI Wallet verification fundamentally changes this model. An operator that needs to verify a player's age and country of residence receives only those specific attestations, cryptographically signed by a trusted identity provider, without accessing the underlying identity document. The operator does not need to store passport images or other sensitive documents, reducing both the GDPR compliance burden and the consequences of any data breach.

Player Control Over Personal Data

The wallet design places the individual in control of their data. Players decide which credentials to share and with whom, can revoke access, and maintain a transaction log of all verification requests. This addresses growing consumer concerns about how gambling operators handle personal information, a topic that has driven regulatory action across multiple EU jurisdictions.

Anti-Surveillance Protections

The eIDAS 2.0 regulation explicitly prohibits wallet providers from tracking which services a user accesses with their wallet. This means a government-issued wallet cannot be used to build profiles of gambling behavior at the wallet provider level, though operators themselves remain subject to responsible gambling monitoring obligations under national law.

Challenges and Obstacles for Gambling Adoption

Despite its potential benefits, EUDI Wallet integration into the gambling sector faces several practical challenges.

Regulatory Fragmentation

While eIDAS 2.0 is an EU-wide regulation, gambling remains nationally regulated. Each country's gambling regulator will need to issue guidance on how EUDI Wallet verification satisfies national KYC requirements. Until all relevant gambling regulators formally recognize EUDI Wallet credentials, operators will need to maintain parallel verification systems, potentially increasing rather than reducing compliance costs during the transition period.

Technical Integration

Gambling operators will need to integrate EUDI Wallet acceptance into their existing platforms. This requires implementing the technical protocols defined in the Architecture and Reference Framework (ARF), potentially upgrading player management systems, and training compliance teams on the new verification workflows. Smaller operators may find these integration costs burdensome, although industry-standard software providers and B2B platforms are expected to offer plug-in solutions.

Self-Exclusion Integration

One of the most complex implementation questions is how EUDI Wallets will interact with national and cross-border self-exclusion systems. Currently, self-exclusion relies on matching player identity data against exclusion databases. A wallet-based system could either enhance this process (by providing more reliable identity matching) or complicate it (if the selective disclosure model limits the data available for exclusion checks).

Consumer Adoption Uncertainty

The EUDI Wallet's impact on gambling verification depends on widespread consumer adoption. While member states are required to offer wallets, citizens are not required to use them. If adoption is slow, operators will need to maintain existing verification methods alongside wallet acceptance indefinitely. Consumer trust in government-issued digital identity solutions varies across EU countries, influenced by cultural attitudes toward privacy and government surveillance.

Implications for Responsible Gambling

The EUDI Wallet has both positive and challenging implications for responsible gambling frameworks across the EU.

Strengthened Age Verification

Underage gambling remains a persistent concern across EU markets. Current age verification methods, including document uploads and database lookups, have known weaknesses. Research published by the UK Gambling Commission and other regulators has documented cases where minors bypass verification using parental documents or falsified information. EUDI Wallet-based age verification, using cryptographically signed government-issued attestations, would be significantly harder to circumvent.

Cross-Border Self-Exclusion Potential

The current lack of a unified EU-wide self-exclusion system means a player excluded in one country can register with operators in another. If EUDI Wallets eventually incorporate self-exclusion status as a verifiable credential, this could enable cross-border exclusion recognition, a goal that responsible gambling advocates have pursued for years. However, the privacy implications of including gambling-related flags in a general-purpose identity wallet require careful consideration.

Affordability and Spending Controls

Some regulators have proposed linking gambling spending limits to verified income data. While controversial, the EUDI Wallet could technically support this by allowing players to present verified income attestations (from tax authorities or employers) to operators implementing affordability checks. Countries like the Netherlands and Germany, which already impose spending limits, could use wallet-based income verification to personalize limits more accurately.

What Operators Should Prepare For

Although full EUDI Wallet integration remains a year or more away for most gambling operators, preparation should begin now. The European Commission's technical specifications are published, and the regulatory direction is clear.

The Broader Digital Identity Landscape

The EUDI Wallet does not exist in isolation. It is part of a broader global trend toward digital identity solutions in regulated industries, documented by organizations such as the Financial Action Task Force (FATF), which has published guidance on digital identity for AML/CFT compliance. The World Bank's ID4D initiative and national programs in countries like Estonia (e-Residency), India (Aadhaar), and Singapore (Singpass) provide context for how digital identity transforms regulated sectors.

For the gambling industry specifically, the EUDI Wallet represents the intersection of three major regulatory trends: digital identity standardization, strengthened AML enforcement through AMLA, and the ongoing push toward more effective responsible gambling measures. Operators that view EUDI Wallet integration as a strategic opportunity rather than a compliance burden will be best positioned to benefit from reduced KYC costs, improved player experience, and stronger regulatory relationships.

Conclusion

The EU Digital Identity Wallet, mandated by eIDAS 2.0, will fundamentally change how online gambling operators verify player identity, confirm legal age, and satisfy anti-money laundering requirements across the European Union. While full implementation is still in progress and national gambling regulators have yet to issue comprehensive guidance, the regulatory direction is unmistakable: digital identity wallets will become a standard mechanism for gambling KYC compliance within the next two to three years.

The selective disclosure capabilities, cross-border recognition, and privacy-preserving design of the EUDI Wallet address many of the friction points and privacy concerns inherent in current gambling verification processes. At the same time, challenges around regulatory fragmentation, technical integration, self-exclusion interoperability, and consumer adoption will require coordinated effort from regulators, operators, and technology providers.

For operators, regulators, compliance professionals, and players, understanding the EUDI Wallet framework now is essential preparation for a gambling verification landscape that will look substantially different by 2028.

Last Updated: January 2026