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The EUDI Wallet Covers 27 Countries. What About the Other 152?

·Mairi Kutberg ·
eudidigital-identitycross-bordereidasnon-euidentity-gap

The EU Digital Identity Wallet is a milestone for Europe. But it leaves non-EU partners, suppliers, and workers without a digital identity — and that gap affects your business.

The EUDI Wallet Covers 27 Countries. What About the Other 152?

The European Digital Identity Wallet is, by any measure, an ambitious project. By the end of 2026, all 27 EU member states must provide their citizens with a digital identity wallet. Banks, large online platforms, and public services will be required to accept it. The goal is clear: give every European a single, trusted, portable digital identity that works across borders.

For transactions between EU citizens and EU businesses, this is transformative. But there is a question that the EUDI framework does not answer — and it is a question that matters to every European company doing business internationally: what about the people who cannot get an EUDI wallet?

What EUDI Actually Covers

To understand the gap, you first need to understand the scope. The EUDI wallet is designed for EU member state citizens and, in some countries, legal residents. Each wallet is issued by a member state and tied to that country's national identity infrastructure. A Greek citizen uses a Greek EUDI wallet. A German citizen uses a German one. Cross-border recognition means that a Greek wallet works when authenticating with a German service — but only within the EU ecosystem (Signicat / Intesi Group, EUDI Wallet Readiness Report).

EEA countries (Iceland, Liechtenstein, Norway) have an extended deadline of December 2027. Western Balkan countries aspiring to EU membership also have extended timelines. Switzerland is developing its own Swiyu wallet outside the EUDI framework entirely.

The EU's target is ambitious: 80% citizen adoption by 2030. If achieved, that would create the world's largest interoperable digital identity ecosystem — covering approximately 450 million people across 27 countries.

But the world has 8 billion people and 179 countries with biometric passports. The EUDI wallet, by design, covers a fraction of the global population.

Who Is Left Out — and Why It Matters for European Businesses

The EUDI wallet is not available to citizens of non-EU countries. A Turkish supplier, an Indian IT contractor, a Moroccan agricultural worker, a Ukrainian freight driver, a Brazilian fintech customer — none of them can obtain an EUDI wallet. They are outside the system.

This is not a theoretical concern. It directly affects how European businesses operate today.

Logistics and freight. The EU's freight corridors rely heavily on carriers and drivers from Turkey, Ukraine, Morocco, and other non-EU countries. When eFTI mandates digital freight documentation from July 2027, these drivers need a digital identity to sign electronic consignment notes. EUDI does not provide one.

Financial services and fintech. European fintechs and neobanks serve customers globally. KYC onboarding for a client from India, Nigeria, or Indonesia cannot rely on EUDI — those customers have no access to the EU wallet ecosystem. Current KYC processes for non-EU clients cost €1,500–3,000 per client and take 30–60 days.

International trade and supply chains. EU companies sourcing from or selling to partners in Turkey, China, Africa, and the Middle East need to verify identities and sign contracts across jurisdictions. The EUDI wallet is not designed for this scenario.

Seasonal and migrant workers. Agriculture, construction, and hospitality across the EU employ millions of workers from non-EU countries. Digital identity verification for these workers falls outside the EUDI scope.

The common thread is clear: any time a European business interacts with a person or entity from outside the EU's 27 member states, the EUDI wallet does not help.

EUDI's Readiness Problem Compounds the Gap

Even within the EU, the picture is more complex than the regulation suggests. According to industry analysis, several member states are unlikely to meet the December 2026 deadline with fully functional wallets. The Netherlands has already signalled it may not be ready. Bulgaria has not begun development. Other countries plan to launch with limited functionality — identity only, without additional credentials or qualified electronic signatures (Biometric Update, December 2025).

Technical standards and implementing acts are still being finalised. Wallet developers are building against changing specifications, and cross-border interoperability — the core promise of EUDI — has not been tested at scale outside of pilot programmes.

This means that for the next several years, European businesses will operate in a fragmented environment even within the EU: some countries with functional wallets, others without, and varying levels of functionality across member states. Add non-EU partners to that mix, and the complexity multiplies.

The Complementary Layer: Digital Identity Beyond EUDI

The EUDI wallet is not flawed — it is scoped. It was designed to solve identity within the EU, and for that purpose, it will eventually work well. The problem is that international business does not stop at EU borders.

What is missing is a complementary layer that handles digital identity for the scenarios EUDI was not built for: cross-border interactions with non-EU parties, identity verification for citizens of countries without national eID infrastructure, and digital signing across jurisdictions where neither party may have access to a European digital identity wallet.

This is exactly the gap IdentiGate was built to fill. Our platform creates a digital identity from any biometric passport — and modern biometric passports with NFC chips exist in 179 countries. The identity is device-bound, cryptographically verifiable, and produces advanced electronic signatures that meet eIDAS requirements. Onboarding takes 90 seconds via NFC passport scan on a smartphone.

The key distinction: EUDI is infrastructure provided by governments for their citizens. IdentiGate is infrastructure available to anyone with a biometric passport, regardless of citizenship. The two are not competing — they are complementary layers of a global identity stack.

A Turkish freight driver signs an eCMR with IdentiGate. A German warehouse operator signs with their EUDI wallet or national eID. Both signatures carry legal weight under eIDAS. Both identities are cryptographically verified. The document is complete, regardless of which country issued either party's passport.

What This Means for Your Digital Identity Strategy

If your business operates entirely within the EU, with EU customers and EU partners, the EUDI wallet will eventually meet your needs. Plan for integration and watch the rollout timeline.

If your business interacts with non-EU parties in any capacity — international suppliers, cross-border logistics partners, global customers, non-EU workforce — you need a digital identity strategy that extends beyond EUDI. Waiting for the wallet to somehow expand to 179 countries is not a plan. The regulation was not designed for that, and there is no roadmap for it.

The practical approach is to treat EUDI as one layer in your identity stack, not the entire stack. Accept EUDI wallets where available. Use complementary infrastructure like IdentiGate for non-EU parties. Ensure that both produce signatures and identity verifications that meet the same legal standard under eIDAS.

The EU built the wallet for Europe. The other 152 countries still need a solution.


IdentiGate is a cross-border digital identity and electronic signature infrastructure supporting biometric passports from 179 countries via a single API. We complement EUDI by providing digital identity where the wallet does not reach. Learn more at identigate.com

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