The long-term success of the EU Digital Identity ecosystem under eIDAS2 hinges not only on regulatory implementation and technical interoperability but also on viable economic and operating models for services around it. Lower-friction KYC processes alone are insufficient to support the full range of digital uses, as many private-sector use cases, such as consumer-facing journeys in transport, hospitality, payments, and loyalty, rely on person-centric wallet interactions. Private actors, including issuers, wallet providers, and verifiers, must invest in secure, scalable, and compliant services, balancing capabilities like trust infrastructure, security, compliance, integration, operations, and service continuity with strong privacy guarantees, high transaction volumes, and manageable costs. Public wallets funded by authorities must coexist with private solutions on a level-playing field to avoid unclear competition and innovation dynamics.
The challenge extends to functional and architectural design, focusing on how private tools can connect effectively to sovereign or public-interest functions of the eIDAS framework, including actor certification, end-to-end security, privacy, and interoperable interfaces. Maximizing value for users, businesses, and authorities requires practical models enabling these layers to work together, such as certified private wallets at appropriate assurance levels or simple, interoperable interactions with public wallets. The balance must be struck between user experience, security, privacy, flexibility, deployment speed, and cost.
Concrete functional questions arise, such as how to organize value allocation and settlement when actors do not directly interact, and how to avoid unnecessary visibility into user behavior. Discovering and using credentials or attributes held by users also requires careful design to preserve user trust and compliance. Scalability must be considered as a functional objective, and the provision of attributes like MSISDN as certified credentials by mobile network operators illustrates the implementation challenges that other sectors will face. Public authorities play an enabling role by clarifying roles, responsibilities, and constraints and supporting structured work on sustainable deployment.
Large Scale Pilots (LSPs) are ideal environments to test operating assumptions, integration models, and value-allocation mechanisms in realistic conditions. Dedicated workstreams should examine viable models for issuers, wallet providers, and verifiers, connections between private services and eIDAS trust functions, minimizing onboarding costs, designing value-allocation mechanisms without unnecessary visibility, and supporting scalable contractual, operational, and economic arrangements. Addressing these questions does not predetermine market structure but recognizes the need for workable deployment conditions to fully realize the economic and societal impact of the EU Digital Identity ecosystem. European mobile network operators are committed to supporting the development and testing of business models for the ecosystem in the interest of all stakeholders.
