eIDAS 1 to eIDAS 2 Transition: Impact on Signature in 2025
The eIDAS 2 regulation fundamentally reshapes electronic signature rules in Europe. Discover the key changes, implementation timeline, and actions to take now.
Published in the Official Journal of the European Union on 30 April 2024, the eIDAS 2.0 regulation (EU 2024/1183) overhauls the European framework for digital identity and trust services, ten years after the original regulation. Five major innovations: the EUDI Wallet (European identity wallet) mandatory in all Member States by June 2026, qualified remote signature without smart card, two new qualified trust services (electronic registers and archiving), and strengthened cross-border enforceability. Here are the concrete impacts for businesses.
eIDAS 2.0 does not replace eIDAS 1.0: it amends and complements it. The achievements of the 2014 regulation (three signature levels SES/AES/QES, legal value equivalent to paper) remain in effect.
All Member States must provide their citizens with a free digital identity wallet by June 2026. The wallet stores verifiable credentials (identity, diplomas, driver's license, certificates) and allows online authentication without revealing more than necessary (selective disclosure). Public services and major private platforms (banking, telecoms, health, transport) must accept the EUDI Wallet as an authentication method.
Until now, qualified signature (QES) required a smart card and reader — a major adoption barrier. eIDAS 2.0 explicitly recognizes remote QES: the signatory's private key is stored in a secure HSM device hosted by the trust provider, the signatory uses it via strong authentication (MFA + biometrics). The legal value remains identical to that of QES on card.
New qualified trust service: record data in a tamper-proof register (often a permissioned blockchain) with a presumption of integrity and prior date that is enforceable. Uses: land registers, business registers, shareholder meeting transcripts, supply chain traceability.
New qualified trust service: preserve electronically signed documents over the very long term while maintaining probative value beyond the expiration of original certificates. Essential for contracts with long legal value (real estate, patents, international contracts) where the retention horizon exceeds the validity period of a certificate (~5 years).
Qualified trust services of one Member State are recognized as a matter of law in all other Member States. eIDAS 2.0 adds financial penalties (up to 4% of global turnover) for national authorities that wrongly refuse a qualified signature issued in another country — practical end of administrative nationalism on signatures.
Several milestones extend until 2027. Businesses are well-advised to anticipate the 2026 peak (EUDI Wallet + generalized Remote QES).
30 April 2024
Publication of regulation (EU) 2024/1183. Entry into force 20 days later (20 May 2024). From that date, the text is directly applicable in all Member States without national transposition, except for provisions requiring implementing acts.
May 2025 — May 2026
The European Commission adopts implementing acts defining the technical standards of the EUDI Wallet (interoperability, security, formats of verifiable credentials). Member States prepare their national wallet in parallel.
June 2026
All Member States must make an EUDI Wallet freely available to their citizens. National public services must accept it. Large private platforms have an additional period to align (banking, telecoms, healthcare).
2026 — 2027
Widespread adoption of remote QES, launch of the first qualified trust services in electronic registers and archiving. Companies can now adopt an eIDAS 2.0-compatible electronic signature platform to prepare for this transition.
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