COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council on the establishment of European Business Wallets
Date: 2025-11-19
Institutions: Directorate-General for Communications Networks, Content and Technology, European Commission
Subjects: administrative formalities, company law, cross-frontier data flow, data protection, digital economy, digital single market, digital technology, electronic government, exchange of information, information technology applications

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 19.11.2025  SWD(2025) 837 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document Proposal for a Regulation of the European Parliament and of the Council  on the establishment of European Business Wallets {COM(2025) 838 final}  
 
 
Table of contents 

1. 

2. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ................................................. 4 

PROBLEM DEFINITION ....................................................................................................... 7 
2.1.  What are the problems? ............................................................................................................. 7 
2.2.  What are the problem drivers? ................................................................................................ 15 

3.  WHY SHOULD THE EU ACT? ........................................................................................... 22 
3.1.  Legal basis ............................................................................................................................... 22 
Subsidiarity: Necessity of EU action ....................................................................................... 23 
3.2. 
Subsidiarity: Added value of EU action .................................................................................. 24 
3.3. 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................. 26 
4.1.  General objectives ................................................................................................................... 26 
Specific objectives ................................................................................................................... 26 
4.2. 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ....................................................... 27 
5.1.  What is the baseline from which options are assessed? .......................................................... 28 
5.2.  Description of the policy option .............................................................................................. 29 

6. 

IMPACTS OF THE POLICY OPTION ................................................................................ 32 
6.1.  Costs ........................................................................................................................................ 32 
6.2.  Direct benefits ......................................................................................................................... 37 
6.3.  Net benefits ............................................................................................................................. 41 

7.  ANALYSIS OF DIFFERENT USAGE RATES ................................................................... 41 
7.1.  Ranges of adoption by economic operators ............................................................................. 41 
7.2.  Net direct benefits across ranges ............................................................................................. 42 

8.  ADDITIONAL AND INDIRECT BENEFITS ..................................................................... 45 
8.1.  Additional benefits .................................................................................................................. 45 
Indirect benefits ....................................................................................................................... 47 
8.2. 
8.3.  Considerations on proportionality and costs ........................................................................... 52 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................... 53 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................. 56 

1.  LEAD DG, DECIDE PLANNING/CWP REFERENCES .................................................... 56 

2.  EVIDENCE, SOURCES AND QUALITY ........................................................................... 56 

ANNEX 2: STAKEHOLDER CONSULTATION ........................................................................ 57 

1. 

2. 

STAKEHOLDER CONSULTATION STRATEGY ............................................................ 57 
1.1.  Call for Evidence ..................................................................................................................... 58 
1.2.  Meetings and Consultations with Stakeholders ....................................................................... 58 
1.3.  Workshops ............................................................................................................................... 59 

SYNOPSIS OF THE CALL FOR EVIDENCE .................................................................... 59 
2.1. 
Introduction ............................................................................................................................. 59 
2.2.  Key Themes and Recommendations ....................................................................................... 61 
2.3.  Conclusion ............................................................................................................................... 66 

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3. 

SYNOPSIS OF OTHER WORKSHOPS AND CONSULTATIONS ................................... 67 
3.1.  Key challenges ........................................................................................................................ 67 
Support for concept of the business wallets ............................................................................ 69 
3.2. 
3.3. 
Scope of the European Business Wallets ................................................................................ 70 
3.4.  Role of business registers and scope of registration ................................................................ 71 
Power of Attorney and mandate management ......................................................................... 72 
3.5. 
3.6.  Obligations of use and acceptance .......................................................................................... 72 
3.7.  Managing credential validity periods ...................................................................................... 73 
Interoperability, functionalities and technical implementation ............................................... 73 
3.8. 
3.9.  Legally valid communication channel ..................................................................................... 74 
3.10.  Business models and market development .............................................................................. 74 
3.11.  EUBW Market Landscape and Adoption Costs ...................................................................... 74 

ANNEX 3: WHO IS AFFECTED AND HOW? ............................................................................ 77 

1. 

2. 

PRACTICAL IMPLICATIONS OF THE INITIATIVE ....................................................... 77 

SUMMARY OF COSTS AND BENEFITS .......................................................................... 79 

3.  RELEVANT SUSTAINABLE DEVELOPMENT GOALS ................................................. 79 

ANNEX 4: ANALYTICAL METHODS ....................................................................................... 81 

1. 

SCOPE ................................................................................................................................... 81 

2.  ESTIMATING THE ADOPTION RATE FOR PSBS AND EOS ........................................ 82 

3.  ESTIMATING COSTS: OVERVIEW OF THE COST CATEGORIES .............................. 83 

4.  ESTIMATING DIRECT BENEFITS .................................................................................... 85 

5.  RANGES OF ADOPTION FOR ECONOMIC OPERATORS AND NET DIRECT BENEFITS

 ............................................................................................................................................... 86 

6.  TEN-YEAR COST-BENEFIT ANALYSIS.......................................................................... 91 

7. 

SURVEY AND EXPERT INTERVIEWS ............................................................................ 92 

8.  LIMITATIONS TO THE ANALYTICAL METHODS ....................................................... 92 

ANNEX 5: COMPETITIVENESS CHECK .................................................................................. 95 

1.  OVERVIEW OF IMPACTS ON COMPETITIVENESS ..................................................... 95 

2. 

SYNTHETIC ASSESSMENT .............................................................................................. 95 

3.  COMPETITIVE POSITION OF THE MOST AFFECTED SECTORS ............................... 97 

ANNEX 6: SME CHECK .............................................................................................................. 98 

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Glossary 

Term or acronym 

Meaning or definition 

AML 

EAA 

eID  

eIDAS  

EO 

ERDS 

EUBW 

EUDIF 

EUDIW 

EUIBA 

EUID 

GDPR  

LoA  

PSB 

Anti-Money Laundering 

Electronic Attestations of Attributes  

Electronic identity  

Electronic  IDentification,  Authentication  and  Trust 
Services 

Economic Operator 

Electronic Registered Delivery Service 

European Business Wallets 

EU Digital Identity Framework 

EU Digital Identity Wallets 

European  Union  Institutions,  Agencies,  Offices  and 
Bodies 

European Unique Identifier 

General Data Protection Regulation  

Level of assurance 

Public Sector Body 

QTS / NQTS  

Qualified Trust Service / Non-Qualified Trust Service  

QTSP / NQTSP  

Qualified Trust Service Provider / Non-Qualified Trust 
Service Provider  

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1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

The  EU’s  Strategic  Agenda  2024-2029  calls  for  an  ambitious  reduction  in  bureaucratic  and 
regulatory burdens  as well as the simplification  and digitalisation of administrative procedures to 
allow businesses to flourish, particularly taking account of the needs of SMEs1. In September 2024, 
the European Council reiterated this commitment by calling for more efforts to enhance the EU’s 
competitiveness, notably in light of the challenges identified in the Letta2 and Draghi Reports3. 

These  priorities  of  simplification,  administrative  burden  reduction  for  businesses  and  improved 
regulatory  compliance  are  reflected  in  the  Political  Guidelines  for  the  2024-2029  European 
Commission. Drawing on the findings of the Letta and Draghi Reports, the Guidelines highlight the 
need  to  make  doing  business  in  Europe  easier,  faster  and  less  costly.  Simplification  of  the 
regulatory environment is a key horizontal enabler for addressing constraints to growth. 

The priorities of simplification and administrative and regulatory burden reduction were reinforced 
in  the  March  2025  European  Council4,  specifically  calling  on  the  Commission  and  the  co-
legislators to work towards achieving the target of reducing the cost of all administrative burdens 
by at least 25 %, and by at least 35 % for SMEs. In June 2025, the European Council stressed the 
need  for  ‘simplicity  by  design’  to  ensure  a  clear,  simple,  smart,  innovative  and  SME-friendly 
regulatory framework, without undermining predictability, policy goals and high standards5.  

Simplification  and  burden  reduction  are  not  merely  about  lowering  costs,  but  also  improving  the 
quality of doing business. Simpler procedures with fewer bureaucratic steps and complexities allow 
businesses  to  focus  on  generating  sales  and  innovating,  with  accelerated  product  development. 
Lower  entry  barriers,  particularly  across  borders  within  the  Single  Market,  can  stimulate  greater 
competition,  enhancing  not  just  the  dynamism  of  the  European  market  but  also  its  international 
standing.  The  Draghi  report  notes  that  remaining  trade  frictions  in  the  Single  Market  account  for 
around 10% of unexploited potential GDP in the EU6. Or, as President von der Leyen put it in her 
State of the Union address 2025, “Our Single Market is far from complete. Internal barriers within 
the Single Market  are equivalent to a 45% tariff on goods and a 110% tariff on services says the 
IMF. This cannot be. It should not be easier to find fortune across an ocean, than across European 
borders.”7  By  shifting  entrepreneurs’  and  SMEs’  focus  to  their  core  business,  instead  of  on 
administrative and regulatory compliance, productivity is enhanced and greater participation in the 
Single  Market  is  encouraged.  It  is  not  just  businesses  that  stand  to  benefit.  Enhanced  efficiency 
allows public administrations to be more agile, responsive and supportive of businesses. The use of 
robust  digital  tools,  and  the  move  to  ‘digital-by-default’  to  achieve  these  ends  are  central  and 
critical  success  factors  to  achieving  these  ambitions  and  revitalising  Europe’s  economy  and 
enhancing its digital sovereignty. 

1 European Council, Strategic Agenda 2024 – 2029 
2 Much more than a Market, Enrico Letta, 2024; this high level report was commissioned by the European Council in 
response  to  the  Commission  Communication  ‘The  Single  Market  at  30’.  The  Council  called  for  ambitious  action  to 
complete  the  Single  Market  and,  in  particular,  for  work  to  be  advanced  in  simplifying  the  general  regulatory 
environment and reducing the administrative burden to businesses. 
3 The future of European competitiveness, Mario Draghi, 2024; the report stressed amongst other things the importance 
of regulatory burden reduction on companies, with 55% of SMEs flagging regulatory obstacles and the administrative 
burden as their greatest challenge. 
4 European Council Conclusions, 20 March 2025, EUCO 1/25 
5 European Council Conclusions, 26 June 2025, EUCO 12/25 
6 Draghi report, Part A: p.17, footnote ix 
7 https://commission.europa.eu/strategy-and-policy/state-union/state-union-2025_en 

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With  increased  digitalisation  across  all  sectors  of  the  economy,  businesses  and  the  public  sector 
demand  trust,  reliability,  and  interoperability.  To  underpin  this,  Europe  requires  robust  digital 
public  infrastructure,  characterised  by  common  standards,  interoperable  frameworks,  and  secure 
mechanisms  for  exchanging  verified  information.  These  provide  the  foundational  elements  that 
enable secure, legally recognised digital interactions across sectors and national borders, which in 
turn simplify compliance obligations, streamline administrative tasks, and support efficient business 
operations and innovation throughout the Single Market. 

Under the Digital Decade Policy Programme, the EU has adopted measures to empower people and 
businesses  to  benefit  from  a  human-centric,  sustainable  and  prosperous  digital  future.  Ensuring 
access  to  digital  identities  for  all  and  enabling  their  use  has  been  identified  as  a  key  enabler  to 
support  many  of  the  initiatives  set  out  in  the  Digital  Decade  Communication8.  This  includes  the 
targets  to  digitally  transform  businesses  and  public  services.  Reducing  the  need  for  travel  and 
relying  instead  on  the  use  of  electronic  identities,  the  provision  of  electronic  attestations  of 
attributes and electronic signatures and seals to access services and conclude agreements at distance 
aligns with the EU’s climate goals, transforming the EUs economy for a sustainable future. While 
the  State  of  the  Digital  Decade  2025  report  notes  the  progress  achieved  in  respect  of  the  EU 
Digital  Identity  Wallets  to  provide  citizens  with  a  secure  and  user-controlled  tool  to  prove  their 
identity, share documents, and sign digitally, it also notes that all metrics covering the digitalisation 
of businesses fall short of their intended targets, especially around SME digital intensity and cloud 
take-up9. 

To address these priorities, the European Commission adopted A Competitiveness Compass for the 
EU10  and  A  simpler  and  faster  Europe11  in  early  2025.  These  Communications  called,  amongst 
others,  for  the  establishment  of  European  Business  Wallets  (EUBW)  as  the  cornerstone  of  doing 
business simply and digitally in the EU. The Competitiveness Compass recognised the significant 
challenges that regulatory fragmentation and administrative complexity continue to pose for start-
ups, SMEs, and innovators12. The Commission Work Programme for 202513 includes the EUBWs 
as a tool to simplify business-to-business and business-to-government interactions, facilitate secure 
data exchange and unlock new business opportunities. 

The Commission’s Single Market Strategy14 calls for more effective digitalisation in the EU, with 
Member  States  and  the  EU  collaborating  closely  to  enable  the  optimal  functioning  of  the  Single 
Market, to speed up doing business and making it easy to grow, all of which goes hand in hand with 
the  European  ambition  to  simplify  by  reducing  red  tape  and  administrative  burden.  In  particular, 
this  means  shifting  from  a  document-based  to  a  data-based  Single  Market,  resulting  in  the 

8 2030 Digital Compass: the European way for the Digital Decade (COM (2021) 118 final) 
9 State of the Digital Decade 2025: Keep building the EU's sovereignty and digital future 
10  European  Commission  (2025),  A  Competitiveness  Compass  for  the  EU  (https://commission.europa.eu/topics/eu-
competitiveness/competitiveness-compass_en).  
11 European Commission (2025), A simpler and faster Europe: Communication on implementation and simplification 
(https://commission.europa.eu/document/download/8556fc33-48a3-4a96-94e8-
8ecacef1ea18_en?filename=250201_Simplification_Communication_en.pdf).  
12  European  Investment  Bank,  EIB  Investment  Survey  2024  European  Union  overview,  2024:  according  to  the  EIB 
survey, European Union firms are more likely than their US counterparts to view business regulations as a significant 
obstacle 
13 European Commission (2025), Commission Work Programme 2025 – Moving forward together: A Bolder, Simpler, 
Faster 
(https://commission.europa.eu/strategy-and-policy/strategy-documents/commission-work-
programme/commission-work-programme-2025_en). 
14 European Commission (2025), The Single Market: our European home market in an uncertain world. A Strategy for 
making the Single Market simple, seamless and strong; (COM(2025) 500 final) 

Union 

5 

 
 
(automated)  exchange  and  sharing  of  digital  data  for  reporting  purposes  through  secure, 
interoperable  solutions.  The  initiative  would  be  a  key  component  of  realising  these  ambitions.  In 
addition,  the  EU  Startup  and  Scaleup  Strategy  (“Choose  Europe  to  Start  and  Scale”)15, 
explicitly  supports  the  creation  of  the  European  Business  Wallets,  recognising  that  a  business-
friendly,  digital-first  regulatory  environment  is  essential  to  support  the  launch  and  growth  of 
startups and scaleups.  

In July 2025, the European Parliament’s Committee on Internal Market and Consumer Protection 
(IMCO)  adopted  an  own-initiative  report  on  strengthening  the  EU’s  Single  Market  rules16.  The 
report  called  on  the  Commission  to  continue  exploring  ways  to  streamline  access  to  information, 
administrative procedures, and assistance services for businesses, particularly SMEs, by leveraging 
digital  public  infrastructure  such  as  the  EU  Digital  Identity  Wallets  and  the  upcoming  European 
Business  Wallets.  The  report  further  highlighted  that  data  sharing  and  reporting  requirements 
should be data-driven and automated, and recommended the development of a single IT tool with 
harmonised  reporting  formats  and  interfaces  across  Member  States.  The  IMCO  report  also 
acknowledged the Commission’s intention to establish a new EU-wide ‘28th legal regime’ to foster 
a  more  favourable  business  environment,  especially  for  SMEs  and  startups.  It  noted  that  the 
European  Business  Wallets  could  support  the  implementation  of  this  regime  by  enabling  trusted 
and streamlined cross-border digital interactions for economic operators. 

The European Business Wallets will build on and extend the ecosystem of trust established under 
the  European  Digital  Identity  Framework,  established  by  Regulation  (EU)  910/2014  on 
electronic  identification  and  trust  services  for  electronic  transactions  in  the  internal  market17,  as 
amended by Regulation (EU) 2024/118318 (including adopted implementing acts). Seamless digital 
identification  and authentication  enable the secure, cross-border  access  to digital services and the 
sharing of data, attributes and other trust services with legal effect across the EU, further supporting 
the Single Market Strategy mentioned above. 

The  European  Digital  Identity  Framework  establishes  the  EU  Digital  Identity  Wallets  and 
provides the foundational legal and technical framework to ensure that digital identity solutions are 
interoperable, secure, and widely accepted throughout Europe. The European Business Wallets will 
build on this foundation and introduce functionalities tailored explicitly to business contexts. They 
will allow businesses to securely identify themselves, manage and exchange electronic attestations 
of  attributes,  such  as  regulatory  licenses,  VAT  registrations,  and  compliance  certificates,  and 
engage digitally with other economic operators and public authorities. This approach will not only 
help 
improve 
interoperability, but also combat fraud and strengthen cybersecurity, enabling businesses to operate 
more effectively, resiliently and confidently across Europe’s digital single market. In doing so, the 
European  Business  Wallets  will  provide  a  significant  contribution  towards  meeting  the  European 
Council’s  goals  to  bring  down  regulatory  and  administrative  burdens,  as  well  as  to  drive  digital 
transformation at scale.  

to  simplify  complex  administrative 

lower  compliance  costs,  and 

tasks, 

EU 

“The 

Communication 

15 
https://ec.europa.eu/commission/presscorner/detail/en/ip_25_1350 
16  European  Parliament,  press  release  15  July  2025,  Streamlining  and  strengthening  the  EU  single  market  (‘INI  on 
Simplification’). 
17  Regulation  (EU)  No  910/2014  of  the  European  Parliament  and  of  the  Council  of  23  July  2014  on  electronic 
identification and trust services for electronic transactions in the internal market and repealing Directive 1999/93/EC 
18 Regulation (EU) 2024/1183 of the European Parliament and of the Council of 11 April 2024 amending Regulation 
(EU) No 910/2014 as regards establishing the European Digital Identity Framework 

Strategy” 

Scaleup 

Startup 

and 

6 

 
 
This  proposal  aligns  itself  with,  and  can  facilitate  the  uptake  of,  other  important  strategic 
digitalisation  initiatives  aimed  at  streamlining  data  exchange  and  digital  reporting.  These  include 
the Single Digital Gateway, the Digital Product Passport (DPP), the Interoperable Europe Act, the 
28th regime and EU company Law, and the VAT in the Digital Age package. As the Single Market 
Strategy notes, these initiatives will collectively establish a cohesive ecosystem of digital solutions 
designed  to  create  synergies  that  facilitate  and  simplify  doing  business  in  the  EU  and,  more 
broadly, foster greater economic integration and drive innovation throughout Europe. 

2.  PROBLEM DEFINITION 

2.1.  What are the problems? 

As  the  digital  transformation  of  the  European  economy  continues  to  accelerate,  economic 
operators  –  whether  corporates,  SMEs,  or  individual  sole  proprietors  operating  in  an  array  of 
different  fields  as  diverse  as  manufacturing,  finance,  services,  agriculture  and  logistics  –  have 
specific and evolving needs related to digital identity and trust services.  This is particularly the 
case in the context of complex digital data flows and transactions, commercial relationships, cross-
border operations  and fulfilling  regulatory compliance requirements. This  requires digital identity 
solutions  and  trust  services  that  are  interoperable  across  borders  and  adaptable  to  different 
organisational structures. 

The  European  Digital  Identity  Framework  aims  to  strengthen  the  legal  framework  for  digital 
identity  and  trust  services  through  enhanced  security,  trust,  interoperability,  harmonisation  and 
privacy.  While  the  scope  of  the  EU  Digital  Identity  Wallets  established  under  the  Framework 
covers  both  natural  and  legal  persons  and  provides  a  solid  basis  to  enable  secure  and  user-
controlled identification and data sharing for both natural and legal entities, further clarifications on 
specific  legal  persons'  needs  would  facilitate  a  smoother  roll-out.  Additional  measures  will 
therefore support consistent interpretation and implementation across Member States.19 Moreover, 
the technical implementation of the EUDI Wallets focused on a personal application to be used on 
mobile devices which is not fully match the specific needs for business-to-government (B2G) and 
business-to-business (B2B) interactions.  

The  intervention  logic  supporting  the  European  Business  Wallets  proposal  is  built  on  and 
complements  the  one  provided  in  the  2021  Impact  Assessment.  An  overview  of  this  intervention 
logic  is  presented  in  the  figure  below.  This  chapter  will  set  out  the  problems  and  then  the 
underlying  problem  drivers  that,  if  unaddressed,  will  continue  to  present  economic  operators  and 
public sector bodies with unresolved challenges that will impair efforts to enhance competitiveness 
and  reduce  administrative  burdens  by  driving  forward  the  digital  transformation  of  the  European 
economy and the delivery of digital public services. The objectives to be achieved by the current 
proposal are set out in chapter 4. 

19  The  Digital  Identity  Framework  caters  both  to  natural  and  legal  persons.  To  ensure  a  clearer  distinction  between 
natural and legal persons, the proposal will propose to amend Regulation 910/2014 to remove legal persons  from the 
scope and focus solely on natural persons. 

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Figure 1 – Intervention logic behind the European Business Wallets proposal 

2.1.1.  Increased  demand  for  tailored  solutions  enabling  the  secure  digital 

identification of EOs and PSBs, particularly in a cross-border context 

In  today’s  economic  and  digital  landscape,  legal  entities  face  challenges  in  identifying  or 
authenticating  themselves  in  digital  processes,  particularly  in  cross-border  contexts  where 
procedures  differ  across  Member  States.  While  the  revised  eIDAS  framework  extends  trusted 
identification  and  attribute  sharing  to  legal  persons,  administrative  and  commercial  use  cases 
often  require  additional  capabilities,  including  the  ability  to  manage  multiple  digital  identities 
across  different  Member  States,  rely  on  interoperable  mandates,  and  ensure  secure  attribute 
exchange  across  different  national  systems.  The  need  of  EOs  to  interact  with  both  public  sector 
bodies  and  private  partners  in  multiple  Member  States  therefore  increases  the  practical  and 
operational complexity they must navigate when operating within the Single Market. 

This development is consistent with the problem identified in the 2021 Impact Assessment for the 
EUDI  Wallets,  which  addressed  the  increased  demand  for  trusted  identification  and  digital 
attribute  exchange.  This  analysis  focuses  that  assessment  on  the  organisational  dimension: 
whereas  eIDAS  and  the  EUDI  Wallets  address  individuals’  access  to  digital  public  and  private 
services, economic operators require targeted capabilities to support secure identification, mandate 
verification and attribute exchange in B2G and B2B contexts. 

Disconnected  digital  platforms  result  in  fragmentation  and  often  create  unnecessary  complexity 
and  cost  for  organisations,  undermining  trust  and  confidence.  This  fragmentation  does  not  mean 
that  national  or  sectoral  systems  are  unreliable.  Instead,  it  means  that  economic  operators  cannot 
always  be  confident  that  a  credential  or  authorisation  recognised  in  one  Member  State  will  be 
readily  accepted  in  another  without  additional  checks.  This  creates  a  lack  of  smooth  and  reliable 
information  exchange  and  can  slow  down  onboarding  and  verification  processes  with  customers, 

8 

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                               
 
 
suppliers  or  authorities  in  other  markets  -  potentially  discouraging  firms,  especially  SMEs,  from 
exploring new cross-border opportunities.  

Stakeholders  consistently  ranked  identification,  and  representation  checks  among  the  most 
burdensome compliance obligations, particularly in cross-border contexts where procedures differ 
and are repeated for each interaction. Many of these national processes are often incompatible with 
one another, and so legal person identifiers issued in one Member State may not be automatically 
recognised  in  another  Member  State,  eroding  confidence  in  cross-border  digital  transactions. 
Moreover, companies might be requested the same documents multiple times in different countries 
and might face identification procedures that include on paper exchanges and/or in person duties, 
making it hard for EOs to rapidly scale and expand internationally20. 

Expanding business operations across borders – an illustrative use case 

For example a consulting firm established in Member State 1 (MS1) decides to open a new branch 
in  Member  State  2  (MS2).  The  process  can  quickly  become  complex  and  time-consuming.  The 
company has to collect a range of official documents from MS1 authorities, have them notarised, 
and  either  send  a  representative  physically  to  MS2  or  appoint  a  local  legal  representative.  Each 
authority  in  MS2  –  the  business  registry,  tax  office,  and  licensing  agencies  –  requests  similar 
information, but in different formats and often with requirements for original signatures or certified 
copies.  In  addition,  opening  a  local  bank  account  triggers  further  Know  Your  Customer  (KYC) 
checks, again requiring many of the same documents. 

Furthermore,  trust  services  like  eSignatures,  eSeals  and  time  stamps  rely  on  verified  business 
identities.  The  ongoing  differences  in  national  electronic  identification  and  make  it  difficult  for 
trust  service  providers  to  quickly  and  reliably  confirm  the  legitimate  identities  of  economic 
operators across borders. 

Under  the  EU  Company  Law  Directive21,  the  EU  has  respectively  established  the  Business 
Registers  Interconnection  System  (BRIS).  In  addition,  digitalisation  of  company  law  increases 
transparency and trust in the business environment in the single market (for companies, investors, 
consumers).  Every  limited  liability  company  in  the  EU  and  commercial  partnerships  can  be 
identified  with  the  European  unique  company  identifier  (EUID).  BRIS  also  ensures  the  cross-
border exchange of information between business registers and enables the application of the once-
only  principle  across  Member  States.  The  EUID  is  also  used  by  the  anti-money  laundering 
(AML)  Directive22  in  the  context  of  the  Beneficial  Ownership  Registers  Interconnection  System 
(‘BORIS’). However, a significant number of economic operators are not covered by BRIS and 
BORIS: depending on the Member State in question, business and company registers may exclude 
government  authorities  and  public  sector  bodies23  (for  example,  agencies,  local  governments, 
educational establishments, public hospitals), and other institutional actors, as well as sole traders 

20Centre for European Policy Studies (CEPS). (2025). Identification of hurdles that companies, especially innovative 
start-ups, face in the EU justifying the need for a 28th Regime. Available at: https://www.ceps.eu/ceps-
publications/identification-of-hurdles-that-companies-especially-innovative-start-ups-face-in-the-eu-justifying-the-
need-for-a-28th-regime/ 
21 Company Law Package, specifically Directive (EU) 2017/1132 (as amended by Directive (EU) 2019/1151) 

23 BORIS connects beneficial ownership registers which in some Member States are business registers but not always 

9 

 
 
 
and  the  self-employed.  By  not  assigning  unique  identifiers  to  all  such  economic  operators,  they 
cannot  be  reliably  identified  and  their  credentials  cannot  therefore  be  associated  with  a  unique 
identifier. 

Another  under-addressed  challenge  in  the  area  of  identification  is  the  secure  and  interoperable 
delegation  of  mandates  and  representation  rights24:  the  ability  for  economic  operators  and 
public  sector  bodies  to  digitally  grant  authority  to  multiple  individuals  or  entities  to  act  on  their 
behalf.  In  practice,  businesses  often  need  to  demonstrate  representation  to  sign  contracts,  submit 
tenders,  fulfil  reporting  obligations,  or  access  remote  services.  While  economic  operators  are 
legally  able  to  grant  powers  of  attorney  and  mandates  today,  there  is  limited  support  for  there  is 
currently no standardised EU-wide way to digitally store and exchange verifiable evidence of such 
mandates across borders. Today, this is typically managed through paper-based powers of attorney, 
or repeated manual checks with national registries. Such processes are frequently inefficient, costly, 
and  not  suited  to  a  digital  and  cross-border  environment,  where  authorities  and  partners  lack  a 
trusted way to verify representation  in real  time  thus creating further uncertainty in transactional 
and  operational  decision-making.  Stakeholders  described  this  process  as  time-consuming, 
fragmented, and prone to errors, particularly in cross-border contexts. 

Stakeholder responses to challenges around presentation of Powers of Attorney (PoA) 

According to interview participants in the accompanying study, verifying the identity of a company 
legal  representative  and  confirming  the  legitimacy  of  the  PoA  are  two  of  the  most  burdensome 
administrative  activities  for  economic  operators  and  PSBs,  requiring  manual  checks  and  involve 
consulting  heterogeneous  and  non-standardised  data  sources  for  validation.  This  burden  was 
echoed in the Call for Evidence highlighting that procedures for identifying legal persons and their 
representatives differ across MSs, involving commercial courts, notaries, registries, and documents 
that  may  require  apostille  certification  and  substantive  law  compatibility.  The  recognition  of 
powers  of  representation  is  currently  not  automatic  and  some  Member  States  rely  on  informal 
mandates that lack legal documentation, creating uncertainty and risk. 

The Upgrading Digital Company Law Directive (EU) 2025/25 introduces the digital EU power of 
attorney  and  requires  Member  States  to  use  digital  solutions  to  cut  red  tape  and  to  remove 
administrative  burdens  like  formalities  requiring  an  apostille  on  company  documents25.  These 
digital  EU  PoA’s  will  meet  the  standards  of  EAAs  and  will  be  compatible  with  the  EUDIW, 
allowing  companies  to  use  these  in  in  cross-border  situations.  In  this  context,  the  European 
Business  Wallets  could  provide the secure container to  store and share such digital PoAs, adding 
further simplification to PoA management. 

Furthermore, some Member States still rely on manual PDF uploads and paper-based workflows26. 
This may pose a risk of abuse of PoAs. In some current systems, assignees are typically notified 
through  national  platforms,  such  as  digital  mailboxes  or  directly  within  PoA  platforms,  in  some 

24 The issue of delegation of mandates and representation rights is not only a matter of digitalisation but also related to 
statutory and legal requirements. This Staff Working Document, as well as the proposal it accompanies, do not address 
these latter issues.  
25 Directive (EU) 2025/25 of the European Parliament and of the Council of 19 December 2024 amending Directives 
2009/102/EC and (EU) 2017/1132 as regards further expanding and upgrading the use of digital tools and processes in 
company law; https://eur-lex.europa.eu/eli/dir/2025/25/oj/eng 
26 Nordic Council of Ministers. (2025). Analysis of Power of Attorney in the Nordic Baltic region 

10 

 
 
countries,  however  there  are  no  notifications  enabled,  leaving  the  responsibility  to  inform  other 
parties (such as the assignee) about the PoA to the assignor27. Legal persons may be represented by 
multiple natural persons, and individuals may represent multiple legal entities across jurisdictions. 
This multi-layered representation complicates mandate verification. In some cases, individuals act 
on  behalf  of  companies  based  on  internal  mandates  rather  than  formal  PoAs,  adding  a  layer  of 
complexity. 

2.1.2.  Unmet  demand  for  tailored  digital  solutions  enabling  communication 
and  sharing  of  attributes  between  EOs  and  PSBs  within  and  across 
borders in the EU 

Beyond proving their identity, EOs are often required to provide numerous attributes and sector-
specific attestations (e.g. environmental compliance, safety certifications etc.). These attributes are 
broader  and  more  complex  than  those  required  for  natural  persons,  reflecting  the  diversity  of 
business activities and regulatory requirements.  

The  challenges  identified  here  build  directly  on  the  problem  defined  in  the  2021  Impact 
Assessment, which highlighted that “current user expectations for seamless and trusted solutions 
to identify and share attributes across borders [are] not met”. That assessment focused primarily 
on  individual  users  accessing  online  services  and  the  need  for  secure  attribute  exchange  in 
citizen-to-service interactions. 

Since then, demand has evolved further: economic operators increasingly operating cross-border, 
triggering a growing need to share organisation-level attestations in both B2G and B2B contexts. 
These exchanges require traceable and auditable sharing for regulatory compliance, must function 
across multiple Member States and sectors and often depend on verifying representation rights 
of natural persons acting on behalf of legal entities. 

These  specific  organisational  and  operational  needs  were  not  the  primary  focus  of  the  2021 
problem framing and therefore remain only partially addressed by the updated eIDAS framework 
and the EUDI Wallets. Indeed, while the EU Digital Identity Wallet Regulation already introduces 
the concept of verifiable credentials also applicable to legal persons, their exchange, storage, and 
operational use in business contexts could remain fragmented and burdensome.  

The fragmented nature of current national solutions for information sharing and storage and 
the lack of common rules, standards, and shared building blocks make cross-sector and cross-
agency  data  exchange  difficult  and  inefficient.  Repetition  of  submissions  to  different  authorities 
increases the administrative burden for businesses. From the perspective of public sector bodies, the 
uncoordinated  exchange  of  business  credentials  means  less  accessible,  inclusive  and  transparent 
public  service  delivery.  When  data  cannot  circulate  seamlessly  across  borders,  services  remain 
constrained  by  national  silos,  preventing  businesses  from  experiencing  the  EU  as  a  truly  single 
digital space. Interoperability, however, is not only a technical feature but a measure of institutional 
openness: the ability of administrations to make rules and opportunities visible, understandable, and 
actionable online, where the once-only  principles can be implemented.  Nevertheless,  as shown in 
problem  one,  the  eGovernment  Benchmark  2025  shows  that  accessibility  and  cross-border 
availability remain among the weakest areas of digital public service performance. This gap creates 

27 Ibid. 

11 

 
 
a  risk  of  falling  short  of  the  objective  to  ensure  that  100%  of  key  public  services  are  available 
online by 2030, as set out in the Digital Decade policy programme.”  

Stakeholder consultations, including contributions to the Call for Evidence28, consistently pointed 
out that the exchange of licences, certificates, and compliance data across borders is one of the 
most  challenging  elements  of  business  interactions.  Respondents  stressed  the  importance  of  a 
single  EU-wide  harmonised  solution  in  facilitating  trusted,  interoperable,  and  legally  recognised 
attributes exchange, particularly for cross-border use cases in both B2G and B2B contexts. While 
a  European  Unique  Identifier  (EUID)  exists  for  all  limited  liability  companies  and  commercial 
partnerships  and  the  EUID  is  linked  to  the  official  information  about  those  companies  in  the 
national  business  registers  and  also  accessible  at  the  EU  level  through  Business  Registers 
Interconnection  System,  there  is  no  accepted  EU-wide,  sector-agnostic  solution  guaranteeing  the 
secure  exchange  and  storage  of  identities  and  of  the  different  credentials  of  all  economic 
operators.  

EOs increasingly need to prove in a faster way their legal status, representation, and authorisations 
to  comply  with  regulatory  obligations  (e.g.  VAT  registration,  beneficial  ownership  verification), 
access  financial  services,  participate  in  public  procurement,  or  onboard  partners  in  B2B 
transactions. 

For instance, in B2G contexts, this is particularly important in the realm of  public procurement, 
which  represents  a  significant  economic  activity  within  the  EU.  Every  year,  public  authorities 
spend  approximately  €2  trillion  (around  13.6%  of  GDP)  on  the  purchase  of  services,  works,  and 
supplies29, underscoring the importance of public procurement as a crucial pillar of service delivery 
for  governments.  Yet  research  confirms  that  rates  of  participation  and  success  in  winning  public 
contracts are significantly lower for SMEs compared to their larger counterparts30. A key challenge 
is  the  repeated  need  to  prove  the  company's  legal  identity,  status,  and  representation  rights  to 
multiple  authorities,  often  through  document  uploads  or  paper-based  certificates  -  especially  in 
cross-border  tenders.  Because  there  is  currently  no  harmonised  and  legally  recognised  way  for 
businesses to digitally present verified credentials and mandates to procurement authorities in other 
Member States, bid preparation can be slow and costly31.  

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14663-European-Business-Wallet-digital-

28 
identity-secure-data-exchange-and-legal-notifications-for-simple-digital-business_en 
29 European Commission. (2024). The Public Procurement Data Space (PPDS). Single Market Economy. Available at: 
https://single-market-economy.ec.europa.eu/single-market/public-procurement/digital-procurement/public-
procurement-data-space-ppds_en. The public authorities considered under the PPDs are over 250,000. Please note that, 
for the purpose of the Cost Benefit Analysis presented in Chapter 6 and 7, a representative set of 95,825 Public Sector 
Bodies has been used, as relevant for interactions with EOs under the European Business Wallet framework. 
30 Akenroye, T.O., Owens, J.D., Elbaz, J., & Durowoju, O.A. (2020). Dynamic capabilities for SME participation in 
public procurement. Bus. Process. Manag. J., 26, 857-888  
31 Public procurement processes require EOs to present numerous documents and evidence to meet tender requirements, 
including demonstrating economic and financial standing to prove financial stability; having quality assurance schemes 
and environmental management standards; showing suitability to pursue the professional activity; proving technical and 
professional  ability  through  sufficient  experience  and  resources.  Source:  European  Court  of  Auditors  Special  report 
28/2023: Public procurement in the EU. 

12 

 
 
 
 
Examples of burdensome procedures in both B2G and B2B context:  

B2G: 

•  A  construction  company  active  in  multiple  Member  States  may  need  to  submit  safety 
certifications, proof of liability insurance, and environmental permits to local authorities in 
each  country.  These  must  often  be  re-issued  or  translated  into  different  national  formats, 
even when the underlying certificate is already valid EU-wide. 

•  A  company  applying  for  public  procurement  contracts  in  another  Member  State  may  be 
asked  to  provide  tax  compliance  certificates  or  proof  of  VAT  registration.  Because  no 
legally  valid  communication  channel  exists,  the  company  often  must  obtain  notarised 
copies from its home registry, send them via courier, and then wait for manual verification 
by the foreign authority. 

B2B: 

•  A manufacturer onboarding a new supplier in another Member State may need to verify CE 
conformity  marks  or  sector-specific  licences.  In  practice,  these  checks  are  handled  by 
intermediaries (consultants or certification bodies), raising costs and delaying supply-chain 
integration. 

•  Financial institutions conducting due diligence on corporate clients still rely on fragmented 
KYC processes*. In the absence of a harmonised attribute exchange, they request repeated 
submissions of beneficial ownership information, slowing down client onboarding. 

*Contributions  from  the  Call  for  evidence  highlighted  that  the  Business Wallets  can  particularly 
support KYC and KYB processes as they are currently extremely complex and costly. 

In this context of cross-border data exchanges, the Single Digital Gateway Regulation32 introduces 
the Once-Only Technical System (OOTS).  The OOTS serves as the Union’s G2G digital backbone 
for  the  direct,  secure  and  automated  exchange  of  authentic  evidence  (i.e.,  official  documents  or 
data)  between  competent  authorities  across  Member  States.  Acting  at  the  explicit  request  of  a 
citizen  or  business,  the  OOTS  identifies,  retrieves,  and  transmits  the  necessary  certificates  and 
documents  from  the  authentic  source  authority  to  the  requesting  administration,  so  that  such 
evidence only  needs to  be submitted once. Therefore, the Business Wallet  and the OOTS will be 
complementary. The Business Wallet  should provide the mechanism for secure identification and 
representation and allow users to store their attestation locally for B2G and B2B interactions, while 
the  OOTS  enables  the  identification,  retrieval  and  trusted  transmission  of  official  evidence  and 
documents in the context of G2G public procedures.  

32 Regulation (EU) 2018/1724 of the European Parliament and of the Council of 2 October 2018 establishing a single 
digital  gateway  to  provide  access  to  information,  to  procedures  and  to  assistance  and  problem-solving  services  and 
amending Regulation (EU) No 1024/2012: http://data.europa.eu/eli/reg/2018/1724/oj 

13 

 
 
 
 
The absence of a reliable, secure, and legally recognised way for economic operators to exchange 
and store their attributes digitally across borders - in a manner that is equivalent in legal effect to 
submitting paper documents or appearing in person- represents a gap. Today, EOs often rely on ad 
hoc  means,  such  as  email,  couriers,  or  proprietary  portals,  that  are  less  well-suited  to  the 
simplification agenda and digitalisation political priorities.  

Several stakeholders in the Call for Evidence also identified traceability of sharing of attributes as 
a  further  pressing  challenge.  While  the  EU  Digital  Identity  Wallets  prioritise  user  control, 
privacy, and minimal disclosure for natural persons to protect their personal data, these principles 
can conflict however with economic operators’ needs. They require traceability to keep track of all 
shared  attributes  for  risk  management,  fraud  prevention,  and  compliance  and  auditing  purposes 
(e.g.  tracking  supply  chain  attributes  or  financial  transactions).  In  professional  contexts, 
transparency,  verifiability,  traceability  and  accountability  are  essential  for  enabling  trusted 
transactions and may take precedence over the privacy-by-default principles33 applicable in natural 
persons interactions. Economic operators’ digital identity needs differ: their sensitive business data 
flows across complex collaborations and activities, demanding solutions that integrate with existing 
tools and align with their operating model and organizational structures. 

For  the  EU  Digital  Identity  Wallets  architecture,  traceability  is  intentionally  limited  to  preserve 
privacy,  making  it  difficult  to  integrate  with  existing  business  processes,  particularly  where 
companies rely on Enterprise Resource Planning (ERP) systems, which companies use to manage 
internal business processes such as finance, inventory and supply chains, and Know Your Customer 
(KYC)  solutions,  which  financial  institutions  use  to  verify  business  customers’  identity  and 
representation,  to  track  and  audit  attribute  sharing,  leading  to  audit  gaps  or  costly  and  delaying 
manual workarounds. 

Example: how traceability can benefit the financial audit process 

In this hypothetical example, a logistics company undergoing a financial audit could use issued and 
stored electronic attestations of invoices, delivery receipts, tax filings and payment confirmations to 
demonstrate  to  auditors  that  the  company’s  reported  revenue  matches  its  shipping  and  invoicing 
records  over  the  past  year:  with  each  attribute  linked  to  the  company’s  unique  ID,  a  single 
transaction  could  be  traced  across  multiple  systems  that  would  confirm  the  consistency  of 
documents  without  time-consuming  manual  reconciliations  and  without  the  need  for  third  party 
confirmation  of  the  authenticity  of  documents  and  balances.  This  makes  the  audit  process 
significantly  less  error-prone,  manual,  time-consuming  and  costly,  thus  enhancing  trust  and 
compliance,  and  less  costly  for  the  audited  company  in  terms  of  fees  to  pay  and  in  the  time  and 
resources needed to prepare the records for audit. 

33  The  EU  Digital  Identity  Wallets  have  a  strong  focus  on  personal  data  and  prioritise  the  protection  of  privacy, 
ensuring that individuals have control over their own data and identity information, and that their personal details are 
securely managed and protected from unauthorised access or misuse. 

14 

 
 
 
2.2.  What are the problem drivers? 

2.2.1.  Market  and  technological  developments  give  rise  to  new  and  specific 

needs in relation to trust services for EOs and PSBs 

With  disruptive  technological  developments  moving  at  an  unprecedented  pace,  the  way  of  doing 
business in Europe has evolved dramatically. This technological shift increases the importance of 
secure,  automated  and  trustworthy  digital  interactions  for  economic  operators  and  public  sector 
bodies  

Changes  in  the  technological  landscape  are  key  drivers:  global  advances  in  cloud  computing, 
AI, data analytics, digital trust and cybersecurity and secure digital identity are reshaping how legal 
entities operate. The global shift from document-based to data-driven and automated processes has 
raised expectations for real-time, cross-border exchange of verified information. The EU’s Single 
Market Strategy and Digital Decade targets confirm that digitalisation is the key factor for growth, 
innovation, and sustainability: the aim is to reach digital intensity to more than 90% of SMEs 
for  2030,  showing  a  clear  trajectory  towards  greater  use  of  technology  to  generate  efficiencies, 
including to manage compliance and administrative interactions. Despite this data, many EOs in the 
EU  still  operate  with  low  digital  maturity,  remaining  more  vulnerable  to  administrative 
complexity.  

91%  of  scaleups  consider  digital  technologies  critical  to  their  growth,  and  many  see  regulatory 
complexity  as  a  major  obstacle.  Digital  tools  such  as  e-invoicing  demonstrate  how  targeted 
solutions  can  deliver  outsized  impact:  reducing  late  payments  by  up  to  20%,  enabling  smoother 
cross-border  operations,  and  easing  compliance  with  sustainability  reporting34.  Digitalisation  of 
compliance  and  administrative  processes  is  also  reflected  in  companies’  online  interactions  with 
public  authorities.  Internet  use  by  companies  to  obtain  information  or  submit  forms  to  public 
administrations  continues  to  grow35,  reflecting  firms’  preference  for  online  solutions  in  fulfilling 
regulatory requirements.  

There  is  also  an  important  technological  shift  in  AI  adoption  among  European  companies. 
Eurostat data shows that in 2024, 13.5% of EU enterprises with ten or more employees used AI 
technologies, indicating a 5.5% p.p. growth from 8% in 202336. Businesses adopt such tools to 
automate reporting, optimise compliance, and improve decision-making. As EOs digitise their core 
processes, they naturally expect their engagement with public authorities to follow the same path. 

The  need  to  improve  EU’s  global  competitive  standing  and  digital  sovereignty  are  also  an 
important  development.  Competing  economies  benefit  from  integrated  digital  ecosystems  that 
allow businesses to scale quickly. The Draghi and Letta reports warn that Europe’s fragmentation 
and  administrative  complexity  risk  undermining  its  competitiveness.  Strengthening  made-in-EU, 

34  Sage  Report  “Scaling  for  Growth  Unlocking  the  Potential  of  Europe’s  Startups  and  Scaleups”:  Sage  has 
commissioned new research drawing on insights from over 7,500 scaleups and next-generation scaleups across 15 EU 
Member States.  
35 https://ec.europa.eu/eurostat/web/interactive-publications/digitalisation-2025 
36  Eurostat:  “Usage  of  AI  technologies  increasing  in  EU  enterprises”.  A  McKinsey  analysis  highlights  the  same 
evolution in the UK: 65% of private sector companies use generative AI to streamline operations, while only 37% of 
UK government bodies have adopted similar technologies, underscoring the private sector’s push for efficiency gains 
through automation and digital tools, which economic operators also expect from their interactions with public sector 
bodies. Improving government productivity: A systemwide approach, January 29, 2025 

15 

 
 
interoperable digital infrastructure is vital to increase technological resilience, reduce dependencies 
and  reliance  on  high-risk  third-countries  suppliers  and  ensure  European  businesses  can  compete 
globally, upholding EU strategic autonomy. Despite this, according to the World Economic Forum, 
European companies’ underinvestment in advanced technologies has created strategic dependencies 
and has threatened to leave between EUR 2 and 4 trillion of foregone GDP by 204037. The WEF’s 
analysis  reveals  that  Europe  lags  behind  major  competitors  in  10  out  of  14  technology  domains, 
including digital trust and cybersecurity38. 

2.2.2.  Increasing  cross-border  business  transactions  amplify  the  costs  and 
inefficiencies  of  fragmented  compliance  processes  across  the  Single 
Market 

The  share  of  economic  operators  engaged  in  cross-border  activities  within  the  EU  is  growing 
steadily, as the figure below shows: 

Figure 2 – Number of enterprises operating intra EU cross-border over time 

Number of enterprises operating intra EU cross border over time 

s
n
o

i
l
l
i

M

5

4

3

2

1

0

12,5%

12,42%

11,99%

12,0%

11,88%

i

s
e
n
a
p
m
o
c

l

a
t
o
t

f
o
e
g
a
t
n
e
c
r
e
P

2017

2018

2019

2020

2021

2022

2023

Fewer than 10 employees

From 10 to 49 employees

From 50 to 249 employees

250 employees or more

Unknown

Total

Percentage of companies

11,5%

As  these  operations  expand,  compliance  requirements  across  jurisdictions  become  increasingly 
resource-intensive, requiring substantial time, staff, and financial investment to prepare, verify, and 
submit documentation across multiple authorities and jurisdictions. The table below summarises the 
average  EU  score  for  business  start-ups  and  regular  business  operations  in  the  eGovernment 
benchmark report 2025: the yawning gap between national and cross-border availability of digital 
public services and the possibility to use eID for identification and authentication is striking. 

37 World Economic Forum. Europe in the Intelligent Age: From Ideas to Action, January 2025, p.4 
38 Ibid., p.7 

16 

 
 
 
 
 
 
17 

 
 
 
Table 1 – Average scores for two Life Events in eGovernment benchmark survey 

EU average scores 

Life event 

Digital public services 

eID 

Business start up 

Regular business operations 

Source: eGovernment benchmark 202539 

National 

Cross-border 

National 

Cross-border 

98.43 

98.98 

71.17 

76.35 

92.76 

91.49 

51.50 

47.73 

Public  sector  bodies  face  constraints  when  managing  cross-border  administrative  procedures,  as 
they  must  process,  verify,  and  store  economic  operators’  data  originating  from  multiple 
jurisdictions,  each  governed  by  distinct  technical  standards.  The  absence  of  harmonised  digital 
identity and trust mechanisms means that authorities  often cannot automatically retrieve or verify 
official evidence from foreign registries, forcing them to rely on manual validation. 

Inefficiencies  absorb  valuable  human  resources:  much  administrative  time  in  transnational  public 
service delivery can be spent on document verification, manual re-entry of data, or case follow-up 
with foreign counterparts. PSBs bear not only higher administrative costs but also reputational and 
opportunity  costs,  as  slow  or  inconsistent  service  delivery  undermines  trust  in  the  digital  Single 
Market and may prevent economic operators from entering into specific interactions on account of 
these hindrances. 

The  ongoing  prevalence  of  non-standardised  and  unstructured  digital  communication 
processes as well as paper-based systems and manual verification procedures not only results 
in higher costs, increased administrative burdens, delays, but also in heightened risks of human 
error and fraud40 for both EOs and PSBs. For example, many documents have file formats that are 
not  easily  or  accurately  convertible,  such  as  images  resulting  from  scans,  making  text  extraction 
and archiving difficult. This prevents a seamless digital exchange because it necessitates additional 
processing steps that result in inefficiencies and reduced legal reliability: for many businesses, these 
obligations, especially when compliance is needed across borders, involve repetitive tasks, such as 
providing the same information to different authorities in different formats.  

The cost of compliance in Sustainability Reporting 

Stakeholder  interviews  highlighted  that  the  implementation  of  sustainability  reporting  obligations 
can  impose  a  burden  on  companies  of  all  sizes.  One  medium-sized  company  reported  hiring  two 
full-time employees dedicated solely to reporting obligations. Others stressed that adapting systems 
and engaging specialised consultants can cost over €100 000 annually. 

39 Results of the eGovernment benchmark - Capgemini 
40  For  example,  in  the  Staff  Working  Document  accompanying  the  IVth  Omnibus  package,  the  overall  savings  for 
companies  related  to digitalisation  of  Declarations  of  Conformity  are  estimated  at  around  €300 million  per  year;  see 
SWD(2025) 130 final 

18 

 
 
Several businesses estimated that around 20% of staff time is absorbed by sustainability reporting 
tasks, including data collection, verification, and document preparation. 

The  Omnibus  I  Package  –  which  simplifies  rules  on  sustainability  reporting,  sustainable 
finance  and  related  requirements  to  reduce  administrative  burden  (notably  for  SMEs  and 
small mid-caps) – is a major step forward in streamlining obligations and helping companies 
focus resources on growth and innovation. However, as these simplification efforts are being 
implemented,  the  practical  processes  required  to  gather,  validate  and  present  information 
across  different  procedures  and  jurisdictions  still  impose  significant  operational  costs  and 
hurdles on businesses. 

These  findings  point  out  the  challenges  companies  face  in  practical  compliance  and  the  risk  of 
disproportionate  impacts  on  smaller  economic  operators.  The  resources  devoted  to  implement 
certain  obligations  could  otherwise  be  channelled  into  innovation,  productivity,  and  market 
expansion, particularly in cross-border contexts. 

Among EOs, costs fall disproportionately on SMEs and micro-enterprises – the latter often run 
by a single individual – which frequently lack dedicated legal, IT, or compliance departments, and 
must divert limited resources away from more high-value tasks to meet these obligations41. As the 
Draghi report points out, regulatory burdens are especially costly for SMEs and self-defeating for 
those in the digital sector, with more than half of SMEs in Europe flagging regulatory obstacles and 
the  administrative  burden  as  their  greatest  challenge  in  remaining  competitive.  55%  of  SMEs 
flagged administrative burden as their greatest challenge to remaining competitive42. The European 
Investment  Bank  has  estimated  that  regulatory  compliance  costs  account  for  about  1.8%  of 
turnover for firms and 2.5% for small and mid-size companies43. In the EIB survey, 60% of 
EU  exporters  reported  needing  to  comply  with  various  standards  and  consumer  protection 
rules  from  one  Member  State  to  another44.  Such  fragmentation  –  including  additional  ‘gold 
plating’  discourages  smaller,  younger  companies,  from  participating  fully  in  the  Single  Market 
compared to their larger peers, who can better shoulder the costs of regulatory burdens. 

While  initiatives  such  as  the  Omnibus  simplification  packages  and  the  Once-Only  Technical 
System  (OOTS)  (supporting  direct  evidence  exchange  between  authorities)  are  expected  to 
substantially  reduce  red  tape,  practical  challenges  in  securely  communicating  and  presenting 
information  to  different  public  sector  bodies  across  the  EU  remain,  particularly  for  smaller  firms 
expanding cross-border. 

Finnish Example: administrative burden on SMEs in cross-border contexts  

41 Stakeholder feedback confirms that 30–50% of an SME’s time can be consumed by administrative tasks, including 
identity verification, validation of legal representation, and repeated submission of documents to different authorities. 
42  REDUCING  REGULATORY  BURDEN  TO  RESTORE  THE  EU’S  COMPETITIVE  EDGE 
BUSINESSEUROPE2025 
43  EIB  Investment  Report  2024/2025  “Innovation,  integration  and  simplification  in  Europe”.  According  to  the  EIB, 
about 86% of EU firms employ staff specifically to deal with regulatory compliance, and 28% of EU SMEs indicated 
that over 10% of their staff are employed to manage regulatory compliance. 
44 Ibid. 

-

19 

 
 
 
A Finnish pilot project revealed the challenges SMEs face in cross-border interactions. Opening a 
bank  account  abroad  required  submitting  a  Finnish  tax  debt  certificate.  While  Finnish  company 
representatives could obtain this digitally, foreign applicants had to request it manually, calling the 
tax authority and receiving the document by post. With around 2,000 foreign cases annually (out of 
84,000  total  requests),  this  manual  process  imposed  high  mailing  and  customer  service  costs, 
highlighting  how  the  lack  of  secure  digital  channels  disproportionately  burdens  smaller  firms 
seeking to expand cross-border45. 

Differences  in  national  rules  furthermore  create  the  conditions  for  complexity,  but  the  real 
limitation lies in the absence of a common, EU-wide means to ensure that business documents and 
credentials  retain  their  legal  validity  when  exchanged  across  borders.  Today,  the  storage  and 
exchange  of  such  documents  depend  on  fragmented  systems  –  from  eInvoicing  platforms  to 
mandates  and  powers  of  attorney  –  that  in  some  cases  still  require  paper  formalities.  These 
inconsistencies  do  not  challenge  the  content  of  national  legislation  as  such,  but  they  create 
uncertainty over how documents are recognised and trusted in cross-border interactions.  

Cross-border  exchanges  often  involve  sensitive  data,  including  financial,  regulatory,  and 
contractual  information.  Fraudulent  practices  such  as  invoice  scams  already  generate  over  €26 
million  annually  in  illicit  profits,  according  to  Europol  and  EUIPO.  These  schemes  exploit  the 
absence  of  standardised,  verifiable  channels  by  mimicking  legitimate  correspondence,  leading 
many  businesses  to  unknowingly  pay  false  fees  for  services  such  as  trademark  renewals  or 
registrations. The dependency on proprietary identity solutions and high-risk suppliers can increase 
security risks. 

Large-Scale Pilots – WeBuild 

The  widespread  participation  in  the  Large-Scale  Pilots  (LSPs),  funded  by  the  Digital  Europe 
Programme,  reflects  the  strong  interest  and  demand  from  both  public  and  private  sectors  for 
interoperable  identity  solutions  that  work  across  borders.  The  LSPs  involve  over  550  businesses 
from across the EU and public authorities from 26 Member States as well as Norway, Iceland and 
Ukraine, and include specific B2G and B2B use cases46. One of the most recent Large-Scale Pilots, 
WeBuild,  brings  together  more  than  180  public  authorities,  private  companies,  academic 
institutions and technology providers from 26 countries to develop 13 use cases across the domains 
of business, supply chain and payments47. 

for  example:  https://urldefense.com/v3/__https:/yrityksendigitalous.fi/en/blogs/digital-wallet-streamlines-

45  See 
opening-a-companys-bank-
account/__;!!DOxrgLBm!DQDfWrS5M7k4wE3QS6lhr400t1XPX4FQtiJO3wAYeDpEyeMNaNq6AEsGY4Z_o-
apKG6m4IP0SSNnY0eBpDdARKJUWrVj_02xXZQZLBPefA$ 
46 See Large Scale Pilots 
47  WeBuild  (EU  contribution  13.4m  euro;  total  budget  26.8m  euro)  is  coordinated  by  the  Netherlands’  Kamer  van 
Koophandel (KVK) and Ministry of Economic Affairs (MinEZ) and the Swedish Bolagsverket, and will enable cross-
sectoral  and  cross-border  collaboration,  ensuring  that  both  the  technical  infrastructure  and  policy  alignment  are 
addressed cohesively and inclusively. Use cases include: cross-border business registration; tax declaration; signing on 
behalf of a company; verifying drivers, trucks, and transport companies; securely verifying buyer-supplier relationships 
to  prevent  invoice  fraud;  AML-compliant  onboarding  and  accessing  online  banking  services;  corporate  banking  and 
payments. 

20 

 
 
Finally,  stakeholders  highlighted  that  international  business  opportunities  extend  to  cooperation 
with partner third countries, yet the lack of reliable mutual recognition mechanisms can discourage 
firms from seizing these further opportunities. 

2.2.3.  Non-interoperable 

systems  hinder  PSBs 

in 

identifying  and 

communicating in a secure and efficient manner with EOs 

The EU still faces major challenges to harnessing the digital transformation for its productivity and 
competitiveness48.  From  the  perspective  of  public  sector  bodies,  limitations  in  current 
identification  and  credential  exchange  systems  hinder  progress  towards  a  seamless  EU 
administrative space for business interactions. Despite ongoing digitalisation of public services, 
existing  systems  are  generally  designed  for  domestic  use  and  do  not  always  support  secure 
cross-border interoperability for communication with economic operators.  

The  eGovernment  Benchmark  2024  shows  substantial  differences  across  Member  States  in  the 
digital  availability  and  usability  of  key  public  services:  the  average  overall  score  of  the  10  top-
performers within the EU27 is 87 points, compared to 64 points for the 10 bottom-performers – a 
gap that highlights persistent disparities in business-facing digitalisation. These disparities translate 
into different  compliance costs:  the Commission’s Tax Compliance Costs for SMEs Final Report 
(2022)  finds  that  for  example  electronic  filing  and  one-stop-shop  solutions  reduce  administrative 
burdens, while less digitalised systems lead to proportionally higher costs for businesses. 

The eGovernment Benchmark 2024 shows that while 88 % of public services are available online 
to  national  users,  cross-border  users  can  access  only  56  %  of  those  services  digitally. 
Interoperability barriers  remain among the top obstacles to efficient e-government. Fragmentation 
concerning  legal  persons  identifiers  affects  how  PSBs  and  EOs  communicate  and  exchange: 
while  Member  States  are  developing  national  digital  identity  schemes  for  EOs,  as  well  as 
foundational  digital  services  like  e-invoicing  platforms,  these  solutions  still  rely  on  different 
technical standards, formats, and protocols. The result is fragmented systems that do not “speak” to 
one another, forcing economic operators to resubmit information or undergo manual checks when 
trading  or  expanding  across  borders.  Both  EOs  and  PSBs  emphasised  the  importance  of  an  EU-
wide harmonised  solution enabling interoperability. This  request  goes beyond agreeing  on the 
definition  and  harmonisation  of  standards  and  protocols:  stakeholders  called  for  an  interoperable 
framework that allows different technical and economic models to coexist. Interoperability between 
the  European  Digital  Identity  Wallets  and  the  European  Business  Wallets  was  also  mentioned 
frequently so as to avoid duplication.  

There are additional constraints related to cybersecurity and the resilience of Europe’s digital public 
infrastructure. One example comes from the implementation of eInvoicing49. Stakeholder evidence 
and recent reports underline that current fragmentation of identifiers creates serious obstacles for 
the security of businesses. 

48  Communication  from  the  Commission:  State  of  the  Digital  Decade  2025:  Keep  building  the  EU's  sovereignty and 
digital future, COM(2025) 290 final 
49  The VAT in the Digital Age (ViDA) package requires all VAT-registered businesses engaged in cross-border B2B 
and B2G supplies to issue structured eInvoices in a standardised EU format by 2030. This reform aims to decrease the 
VAT gap and reduce fraud losses, estimated at EUR 11 billion per year. 

21 

 
 
 
3.  WHY SHOULD THE EU ACT? 

Despite  advances  in  the  digitalisation  of  public  services50  and  national  business  registers,  and 
notwithstanding  the  changes  made  to  the  legal  framework  for  trust  services  introduced  by 
Regulation  2024/1183  amending  Regulation  910/2014,  several  structural  challenges  continue  to 
hinder  effective  cross-border  transactions,  which  increases  costs  and  prevents  the  reaping  of  the 
benefits  offered  by  the  Single  Market.  Businesses  continue  to  face  a  fragmented  landscape  of 
national  portals,  differing  proprietary  formats,  and  paper-based  procedures  for  identification, 
compliance and reporting.  

As  elaborated  below,  these  divergences  translate  into  two  core  challenges.  First,  they  may  create 
obstacles  to  the  freedoms  of  establishment  and  service  provision,  while  also  creating  practical 
barriers  to  the  free  movement  of  goods  and  capital.  Second,  they  generate  distortions  of 
competition  within  the  Single  Market.  Economic  operators  established  in  Member  States  with 
more  advanced  public  digital  infrastructures  benefit  from  faster  and  cheaper  compliance 
procedures, while those operating in Member States with less mature digital channels face higher 
costs and delays51.  

Stakeholders  call  for  secure,  interoperable  and  legally  valid  digital  identity  solutions  to  establish 
themselves,  access  public  services  and  meet  regulatory  obligations  simpler  and  faster  across  the 
Union in ways that avoid unnecessary administrative costs and duplication. EU action complements 
national frameworks and builds on the EU Digital Identity Framework to further unlock the Single 
Market’s potential.   

3.1.  Legal basis 

The  proposed  initiative  builds  directly  on  the  foundations  established  by  the  EU  Digital  Identity 
Framework  and  provides  a  complementary,  tailored  solution  to  economic  operators  and  public 
sector bodies. Its underlying rationale – that secure identity, trust services, and the seamless sharing 
of  electronic  attestations  of  attributes  are  essential  for  enabling  digital  public  services  and 
supporting cross-border market participation – applies equally to legal persons. 

Accordingly, as with the EU Digital Identity Framework, the appropriate legal basis identified for 
this initiative is Article 114 TFEU. Article 114 justifies EU intervention where disparities between 
Member  States  obstruct  fundamental  freedoms  or  cause  significant  distortions  of  competition.  It 
also  works  preventively  by  avoiding  likely  future  obstacles  from  arising  as  a  result  of  divergent 
national laws. 

A  dedicated  instrument  addressing  economic  operators’  and  public  sector  authorities’  specific 
functional  and  legal  needs  is  necessary.  The  proposed  European  Business  Wallets  will  promote 

50 See European Commission, Digital Economy and Society Index (DESI) – Digital Public Services, part of the State of 
the  Digital  Decade  monitoring  framework.  The  EU-27  scored  81/100  in  2025,  up  from  75.8/100  in  2023: 
https://www.capgemini.com/insights/research-library/results-of-the-egov-benchmark/.  
51 The eGovernment Benchmark 2024 Insight Report shows substantial differences across Member States in the digital 
availability and usability of key public services: the average overall score of the 10 top-performers within the EU27 is 
87 points, compared to 64 points for the 10 bottom-performers - a 23-point gap that highlights persistent disparities in 
the  digitalisation  of  public  services.  These  disparities  also  translate  into  compliance  costs:  according  to  the 
Commission’s Tax Compliance Costs for SMEs Final Report (January – 2022) finds that for example electronic filing 
and one-stop-shop solutions reduce administrative burdens, while less digitalised systems lead to proportionally higher 
costs for businesses.  

22 

 
 
competitiveness  as  well  as  establish  an  EU-wide  trust  ecosystem  for  economic  operators. 
Transactions  carried  out  through  the  European  Business  Wallets  will  be  secure  and  legally  valid, 
with credentials whose origin and integrity can be verified, giving companies and public authorities 
confidence in their reliability. 

3.2. 

Subsidiarity: Necessity of EU action 

To  take  full  advantage  of  the  Single  Market,  all  economic  operators  and  public  administrations 
should  be  able  to  benefit  from  highly  secure  and  trustworthy  digital  identity  solutions  across  the 
EU, including the portability of electronic attestations of attributes linked to identity.  These needs 
cannot be sufficiently met by Member States acting individually. 

As  the  2021  Impact  Assessment52  accompanying  the  proposal  for  Regulation  (EU)  2024/1183 
found, without clear EU-level rules and incentives, the uptake and cross-border usability of trusted 
digital identity solutions would remain limited53. The same holds for economic operators and public 
sector bodies: without a common, harmonised EU framework tailored to their needs, cross-border 
business  opportunities  are  lost,  especially  for  SMEs  and  sole  proprietors  and  professionals  who 
cannot easily expand beyond national markets.  

Current  divergences  and  fragmentation  undermine  equal  treatment  between  domestic  and 
operators from other EU countries and generate barriers to EU market access. National initiatives to 
digitalise  businesses’  interactions  with  public  administrations  differ  considerably  in  legal  effect, 
scope, and technical architecture, as they are conceived primarily for national, regional, or local use 
and  are  not  designed  natively  for  pan-European  use  cases.  The  status  quo  leads  to  legal 
uncertainty, higher  costs,  and  duplication of effort, leaving economic  operators  active  in  more 
than  one  Member  State  with  disproportionate  administrative  burdens  and  inconsistent  access  to 
public  and  private  services,  weakening  the  Single  Market  and,  in  turn,  the  EU’s  international 
competitiveness.  

Consequently, obstacles may persist to the full exercise of the freedom of establishment and the 
freedom  to  provide  services,  both  dependent  in  practice  on  interactions  with  public  sector 
bodies. The absence of  a trusted EU-wide solution  means that attestations issued  digitally  in  one 
country cannot always be securely exchanged or relied upon in another.  

Fragmentation is also responsible for distortions of competition: economic operators offering the 
same  category  of  goods  or  services,  and  so  competing  in  the  internal  market,  face  unequal 
conditions  when  meeting  national  compliance  obligations.  Where  national  procedures  are 
digitalised,  economic  operators  can  often  establish  subsidiaries,  register  for  VAT,  or  provide 
attestations  in  days  at  minimal  cost.  Where  such  channels  are  absent,  the  same  process  can  take 
weeks, involve courier fees, and require dedicating staff time to compliance rather than high-value 
productive activities.  

PSBs  play  a  pivotal  role  in  the  efforts  to  overcome  both  obstacles  of  fundamental  freedoms  and 
distortions  of  competition  that  could  be  caused  by  national  divergencies.  Public  sector  bodies 
determine if in practice economic operators are able to exercise their rights in the Single Market on 
equal terms: as “gatekeepers” of procedures such as licensing, taxation and procurement, they are 

52  Commission  Staff  Working  Document  Impact  Assessment  Report,  SWD(2021) 124,  accompanying  the  proposal 
amending Regulation (EU) n° 910/2014 as regards establishing a framework for a European Digital Identity 
53 See SWD (2021) 124, Part 1, pp. 21-22. 

23 

 
 
responsible for how EU rules materialise. By streamlining the way to comply with procedures and 
enabling seamlessly the use of one harmonised tool EU-wide, valid for all EOs, they are pivotal in 
achieving  these  common  objectives  of  removing  administrative  barriers,  restoring  a  level  playing 
field and fully unlocking the Single Market’s smooth functioning. smooth functioning.  

The same applies to the EUIBAs: having important supervisory and regulatory roles, these actors 
need  to  be  included  in  the  scope  of  the  European  Business  Wallets.  At  present,  EUIBAs,  when 
interacting  with  EOs,  manage  different  IT  solutions  and  systems  that  meet  the  varying  sectorial 
objectives  for  which  they  are  responsible.  This  fragmentation  creates  administrative  burdens  and 
increases compliance costs for operators active in several sectors. By bringing EUIBAs within the 
scope  of  this  Regulation,  these  approaches  can  be  streamlined  and  harmonised,  creating  a 
consistent regulatory environment and falling in line with the objectives of Article 114 TFEU. 
Were  the  EUIBAs  to  be  excluded  from  scope,  the  way  EOs  meet  obligations  or  carry  out 
administrative  procedures  at  Union  level  compared  to  the  national  level  would  result  in 
divergences, creating an asymmetry and be in direct contrast with the very harmonisation objective 
of EU intervention under Article 114.  

In  addition,  there  is  also  a  security  dimension  to  consider.  As  recognised  in  the  proposed 
Regulation for a European Competitiveness Fund54 (as part of the MFF 2028-2034), dependency on 
high-risk  suppliers  in  critical  sectors  threaten  the  Union’s  security,  resilience  and  sovereignty. 
Divergent  approaches  to  providers’  eligibility  would  exacerbate  legal  uncertainty,  reduce  trust  in 
cross-border digital infrastructures, and weaken the resilience of the Single Market.  

National  measures  cannot  by  themselves  overcome  these  common  risks,  whereas  EU  action  can 
provide  consistent  and  coordinated  protection  of  the  Union’s  security  interests.  Without  EU 
intervention, fragmentation could further deepen. Divergent incompatible systems will continue to 
coexist,  and  new  ones  may  emerge:  Member  States  will  continue  to  invest  in  existing  digital 
identity solutions designed for domestic use only and systems that may not communicate with one 
another  will  proliferate  without  certainty  about  broader  and  concrete  operational  use  across  the 
Single Market. This will make it harder for companies to establish themselves or provide services 
abroad,  reinforce  distortions  of  competition  between  firms  depending  on  where  they  are 
established, and perpetuate mistrust in the validity of documents exchanged across borders. 

3.3. 

Subsidiarity: Added value of EU action 

By  establishing  a  harmonised  legal  and  technical  framework  for  the  digital  interaction  between 
economic operators and public sector bodies, EU action will deliver added value in  the following 
areas: 

Trust and legal certainty. Action at  EU-level will enable  credentials  and  documents  of  economic 
operators  to  be  stored  and  exchanged  through  a  secure  channel  recognised  across  borders.  This 

54 Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on establishing the 
European  Competitiveness  Fund  ('ECF’),  including  the  specific  programme  for  defence  research  and  innovation 
activities  recital  (30):  “Europe  must  protect  its  security  interest  against  suppliers  which  could  represent  a  persistent 
security risk due to the potential interference from third countries as well as their security, notably cybersecurity. It is 
therefore necessary to reduce the risk of persisting dependency on high-risk suppliers in the internal market, including 
in the ICT supply chain, as they could have potentially serious negative impacts on security for users and companies 
across the  Union and the Union’s critical infrastructure in terms of the integrity of data and services as  well as the 
availability of service. This restriction should be based on a proportionate risk assessment and associated mitigation 
measures as defined in the Union policies and laws”. 

24 

 
 
guarantees  that  public  authorities  and  businesses  can  rely  on  the  authenticity  of  the  origin  of  the 
documents received. By simplifying the way credentials are transmitted, presented and verified, the 
Business Wallets strengthen mutual trust in cross-border interactions and increase predictability for 
economic  operators.  Also,  by  securing  and  standardising  B2G  and  B2B  interactions  and 
information  exchange  across  the  Single  Market,  the  initiative  yields  better  data  quality,  which 
improves accuracy of information, and in turn transparency. Transparency increases trust in public 
administrations and businesses, as well as confidence in digital transactions and services55. 

Competitiveness  and  growth.  Stronger  trust  drives  higher  participation  in  the  Single  Market  and 
opens new economic opportunities. The European Business Wallets can support economic growth 
and development in two specific ways: 

o  For the trust services’ market, the European Business Wallets will act as a catalyst.  
By  making  economic  transactions  simpler  and  more  reliable,  the  initiative  will 
increase  the  practical  utility  of  secure  and  interoperable  trust  services,  thereby 
driving  their  demand.  As  adoption  by  economic  operators  and  public  authorities 
grows,  the  resulting  expansion  in  transaction  volumes  will  open  new  business 
opportunities for European providers and strengthen their competitiveness. 

o  For EOs, especially SMEs, it will reduce administrative burdens and remove barriers 
both to cross-border and domestic transactions, allowing them to scale faster in the 
Single Market. The time saved can redirect  resources to more strategic, high-value 
activities, such as innovation, productivity and international expansion. 

EU’s digital sovereignty and security. As illustrated in the 2021 Impact Assessment for the EUDIF, 
harmonisation  is  essential  to  avoid  dependence  on  non-European  solutions56  and  to  foster  a 
competitive  EU  ecosystem  for  identity  and  trust  services.  Extending  this  logic  through  the 
European  Business  Wallets  contributes  to  the  EU’s  goal  of  digital  sovereignty  by  reducing 
dependency on proprietary identity solutions and enabling European providers to compete globally 
on a level playing field57. In addition, common application of cybersecurity rules ensure that only 
trusted providers operate the Business Wallets’ infrastructures, reducing  dependency on high-risk 
suppliers and aligning with EU-wide supply-chain risk assessments.  

External  trade  incentive.  By  providing  a  trusted  channel  for  the  exchange  of  credentials,  the 
Business Wallets can facilitate smoother recognition and verification processes also in international 
trade,  both  for  European  economic  operators  operating  abroad  and  for  third-country  businesses 
interacting with the EU market. Beyond facilitating trade, the Wallet positions the EU as a global 
standard-setter for trusted digital infrastructures, reinforcing the Union’s regulatory influence. 

Alignment with strategic digitalisation initiatives. The Business Wallets will also ensure coherence 
with  key  legislative  and  political  EU  initiatives,  such  as  eIDAS  Regulation  910/2014,  the  Single 
Digital  Gateway  (SDG),  the  Digital  Product  Passport  (DPP),  the  Interoperable  Europe  Act,  EU 
Company Law, the 28th Regime, and the VAT in the Digital Age (ViDA). By integrating with these 
frameworks,  the  European  Business  Wallets  can  contribute  to  a  cohesive  digital  ecosystem  that 
supports  the  goals  of  the  Single  Market  in  the  Digital  Decade,  and  the  SME  Strategy  for  a 
sustainable and digital Europe. 

55 Mentioned in an in-depth interview with an Association of Economic Operators. 
56 See SWD(2021) 124, Part 1, p. 25. 
57 Mission letter to EVP-designate for Tech Sovereignty, Security and Democracy, 17 September 2024 

25 

 
 
4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1.  General objectives 

The initiatives seek to address the problems outlined in section 2 and reflect the political mandate 
formulated by the President of the Commission58 and by the European Council Conclusions59. They 
also build on the findings of the Letta and Draghi reports, and take into account the joint non-paper 
sent by 12 Member States to the Commission in summer 2024, which called for measures to “make 
the  process  of  complying  with  reporting  obligations  easier  for  businesses”  as  well  as  the  draft 
Council  Conclusions  on  European  Competitiveness  in  the  Digital  Decade  which  expect  the 
European  Business  Wallets  to  harness  the  full  potential  of  digital  tools  in  its  efforts  to  reach  the 
25% burden reduction target for all companies and the 35% burden reduction target for SMEs by 
the end of 2029. Additionally, the 2021 Impact Assessment for the EU Digital Identity Framework 
highlighted the importance of a common European approach to digital identity as a precondition for 
an effective Digital Single Market. 

The general  objective of the  European Business  Wallets  is  to  promote the proper functioning  of 
the  internal  market  by  addressing  the  need  to  reduce  administrative  burdens  for  businesses  and 
public  administrations  by  means  of  digital  identification,  authentication  and  legally  valid  data 
exchange, thereby enhancing competitiveness and digitalisation across the EU.  

The following sections translate this general objective into two specific objectives. 

4.2. 

Specific objectives 

Specific  Objective  1:  Reduce  administrative  burdens,  streamline  compliance  processes,  and 
improve service delivery  

The initiative will establish a harmonised framework enabling economic operators and public sector 
bodies  to  identify  themselves,  authenticate  and  exchange  electronic  attestations  of  attributes  and 
electronic  data  with  full  legal  effect  across  the  Union.  Its  aim  is  to  cut  administrative  costs, 
requiring that formal notifications and documents transmitted via the European Business Wallets to 
meet  regulatory  and  compliance  requirements  are  legally  valid  and  recognised  in  all  Member 
States. 

In  doing  so,  the  initiative  will  strengthen  European  competitiveness  by  directly  generating  cost 
savings through streamlining manual processes and administrative burdens. EOs, especially SMEs 
and microenterprises, will be able to focus their resources towards strategic, higher-value activities 
such  as  innovation  and  cross-border  expansion,  instead  of  repetitive,  time-consuming  and  costly 
compliance tasks.  

The initiative will allow EOs to meet reporting and compliance obligations digitally, thereby more 
effectively and efficiently. Public authorities, in turn, will benefit from more efficient and reliable 
exchanges, reducing delays and improving service delivery. In this way, the initiative will support 

58 The European Business Wallet is part of the Competitiveness Compass as “the cornerstone of doing business simply 
and digitally in the EU”. Additionally, it is included as a priority in the Commission work programme 2025. 
59 European Council Conclusions of 20 March 2025, EUCO 1/25, and of 26 June 2025, EUCO 12/25 

26 

 
 
 
the  simplification  agenda60  and  remove  barriers  to  scaling  up  in  the  Single  Market61,  by  helping 
economic operators navigate compliance complexities more effectively. 

In addition, the initiative will support the further development of the European digital identification 
and trust services internal market to match the growing demand in  an ever-increasing digital-first 
environment. In doing so, this will contribute to Europe’s broader competitiveness objectives.  

This  objective  responds  to  the  drivers  2  and  3:  “Increasing  cross-border  business  transactions 
amplify the costs and inefficiencies of fragmented compliance processes across the Single Market ” 
and  “Non-interoperable  systems  hinder  PSBs  in  identifying  and  communicating  in  a  secure  and 
efficient manner with EOs ” 

Specific  Objective  2:  To  ensure  economic  operators  and  public  sector  bodies  have  access  to 
secure and trusted digital identification across borders, meeting user needs and market demand. 

The  initiative  will  uniformly  implement  a  minimum  set  of  core  functionalities  tailored  to  the 
professional context of economic operators and public sector bodies. At the same time, authorised 
providers will be able to build on this common layer by offering additional features as part of their 
commercial offering, creating space for innovation solutions meeting diverse market needs. Such an 
approach  combining  harmonisation  and  flexibility  is  expected  to  amplify  network  effects,  drive 
adoption,  and  allow  the  internal  market  to  respond  dynamically  to  evolving  needs  of  economic 
operators and public sector bodies.  

The core functionalities of the initiative reflect concrete needs identified by stakeholders. A legally 
valid  communication  channel  will  ensure  that  documents,  notifications,  and  data  exchanges  have 
the same legal effect as  traditional methods, thereby simplifying processes and increasing trust in 
B2G/G2B  exchanges,  likely  driving  further  adoption  in  B2B  contexts.  A  European  Digital 
Directory  (EDD)  will  provide  for  a  secure,  centralised  way  for  users  to  connect  with  trusted 
counterparts  across  the  Union,  supporting  cooperation,  cross-border  operations,  and  new  market 
opportunities.  Furthermore,  the  ability  to  delegate  mandates  digitally  will  allow  organisations  to 
manage representation rights in a transparent and flexible manner, ensuring that multiple authorised 
representatives can act on behalf of a business or authority digitally in a secure and auditable way. 

Together,  these  features  will  meet  current  demand  for  secure  digital  identification  and  attribute 
exchange, and at the same time they will also create the conditions for innovation, scalability, and 
new business models.  

This objective responds to the drivers 1 and 3: “Market and technological developments give rise to 
new  and specific needs in relation to trust services for EOs and PSBs ” and “Non-interoperable 
systems hinder PSBs in identifying and communicating in a secure and efficient manner with EOs.” 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

The  2021  Impact  Assessment62  accompanying  the  proposal  establishing  the  European  Digital 
Identity Framework  

60 See Chapter Error! Reference source not found.1 
61 Regulatory friction is hindering growth for scaleups, as reported in the Sage Startup and Scaleup reports, mentioning 
that 62% of scaleups call for simpler, more harmonised EU Regulation. 

27 

 
 
 
supported proposal for a personal digital identity wallet with legal requirements, common standards 
and/or technical references for the Wallet App. The Wallet App would allow the user to integrate a 
notified  national  eID  and  various  credentials  obtained  from  private  and  public  providers.  Policy 
option  3  incorporated  policy  options  1  and  2  to  strengthen  the  legal  framework  for  cross-border 
recognition of national eIDs and trust services, as well as creating a market for the secure exchange 
of  data  linked  to  identity.  However,  policy  option  3  went  further  by  linking  the  Digital  Identity 
Wallet  to  national  eID  or  eID  credentials  so  as  to  guarantee  a  high  level  of  trustworthiness, 
allowing the user to receive and exchange qualified electronic attestations attributes and credentials 
related  to  their  identity.  The  European  Digital  Identity  Wallets  will  be  provided  directly  by  a 
Member  State;  under  a  mandate  from  a  Member  State;  or  independently  of  a  Member  State  but 
recognised by that Member State63. 

With  the  entry  into  force  of  the  Regulation  and  the  adoption  of  subsequent  implementing 
regulations,  the  current  EU  Digital  Identity  Framework  has  addressed  many  of  the  legal  and 
technical challenges identified in the 2021 Impact Assessment through the ongoing implementation 
of  the  foundational  technical  architecture  and  the  inclusion  of  trust  services  in  its  scope.  The 
Regulation  (and  its  implementing  acts)  have  already  defined  the  foundational  architecture  for  the 
EUDI for natural persons. The digital-identity wallets model policy option is the only viable fit to 
ensure the maximum level  of coherence, consistency and interoperability between the EU Digital 
Identity Wallets and the European Business Wallets.  The two should be understood as a coherent 
extension, not a separate framework. For these reasons, Policy Option 3 is still relevant today in the 
context of the European Business Wallets. Interoperability between the EU Digital Identity Wallets 
and  the  European  Business  Wallets  is  a  defining  principle.  One  of  the  most  consistent 
recommendations from stakeholders was the need for close alignment and interoperability between 
the two frameworks. The European Business Wallets and the EU Digital  Identity  Wallets will be 
seamlessly  interoperable,  enabling  the  exchange  of  identification  data  and  EAAs  for  onboarding 
purposes,  the  management  of  mandates,  and  secure  interactions  across  both  ecosystems.  This 
interoperability  ensures  coherence  and  user-friendly  experiences,  while  recognising  that  the 
Business Wallets are primarily suited for B2G/G2B and B2B contexts, complementing the citizen-
focused scope of the EUDIW.  

The  present  analytical  Staff  Working  Document  builds  on  the  earlier  analysis  and  the  wallets 
design,  providing  a  proportionate,  complementary  analysis  to  support  the  framework’s  extension 
over to B2B and G2B interactions.   

5.1.  What is the baseline from which options are assessed? 

The European Business  Wallets  Regulation  will build directly on the foundation of the European 
Digital  Identity  Framework.  In  the  period  since  the  previous  impact  assessment,  other  relevant 
initiatives  have  accelerated  the  push  towards  greater  regulatory  simplification  and  reduction  of 
administrative burdens, including the Omnibus Packages and the Upgrading Digital Company Law 
Directive. However, the main reference framework for digital identification remains the European 
Digital Identity Framework. Policy option 3 serves therefore as both baseline and the only policy 

62 Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) n° 910/2014 as 
regards establishing a framework for a European Digital Identity; SWD(2021) 124 final; Part 1, pp. 30-45. 
63 Article 5a(2), Regulation 910/2014 

28 

 
 
 
option to be considered in this Staff Working Document, tailored to the European Business Wallets 
context to address the specific needs of its targeted stakeholders. 

5.2.  Description of the policy option 

As  stated  above,  the  policy  choice  builds  on  the  chosen  design  of  the  EUDI  adapted  for  the 
European  Business  Wallets,  integrating  the  specific  problems  identified  in  chapter  2  and  taking 
account of the specific objectives outlined in chapter 4. 

Proposed minimum  requirements  will not in  any way prevent  the emergence and development  of 
additional market-driven features as part of the European Business Wallets’ providers’ commercial 
offering to foster innovation and to meet diverse market needs. 

Against the backdrop of the two specific objectives of reducing administrative burdens, streamline 
compliance  processes,  and  improve  service  delivery  and  ensuring  economic  operators  and  public 
sector bodies have access to  secure and trusted digital identification across borders, meeting user 
needs and market demand - as described in chapter 4 (see section 4.2), the policy option set out in 
the box below is identified for the European Business Wallets. 

This  proposed  Regulation  aims  to  ensure  that  public  sector  bodies  and  economic  operators  in 
Europe can obtain European Business Wallets, a digital tool to securely identify, authenticate and 
exchange data with full legal effect across EU borders. To take full advantage of their benefits and 
encourage  widespread  uptake,  public  sector  bodies  will  be  required  to  enable  the  use  of  the 
minimum  core  functionalities  of  European  Business  Wallets  by  economic  operators.  These 
functionalities include: identification and authentication; the use of qualified electronic signatures 
and seals; the secure issuance, submission, sharing and storing electronic attestations of attributes; 
receiving official notifications. In this way, the wallets would empower users to securely share data 
related  to  their  identity,  licences,  certificates,  and  other  business-relevant  credentials  with  public 
sector bodies and economic operators through market-driven solutions. 

The  European  Business  Wallets  initiative  builds  on  the  EU  Digital  Identity  Framework  and 
complements  the  key  benefits  of  the  European  Digital  Identity  Wallets  for  natural  persons.  The 
European Business Wallets would allow the users to integrate a digital identity issued following the 
legal and technical framework established by the eIDAS Regulation, relying on  authentic sources 
such  as  business  registries  or  other  official  records,  to  interact  in  a  secure  and  efficient  manner. 
Hence,  the  measures  establishing  the  European  Business  Wallets  ecosystem  builds  on  the 
framework  for  EU  Digital  Identity  Framework,  indispensable  for  the  trustworthiness  of  its  cross-
border  use  and  on  trust  services  for  electronic  attestation  of  attributes  enabling  a  multitude  of 
B2G/G2B and B2B use cases across the EU. 

The  EUBW  will  provide  a  legally  valid  and  secure  communication  channel  between  economic 
operators  and  public  sector  bodies  through  the  use  of  qualified  electronic  registered  delivery 
services,  combined  with  a  common  dashboard  for  the  storage  and  verification  of  exchanges.  A 
further feature would allow to link different attestations together so that once an economic operator 
provides  certain  documentation,  it  can  be  reused  across  several  procedures  without  the  need  for 
resubmission.  This  guarantees  that  information  remains  reliable  and  trusted  while  sparing 
businesses and public authorities repetitive checks. 

To  ensure  flexibility,  affordability  and  accessibility  for  certain  groups  of  stakeholders,  like  sole 
traders and the self-employed, it will be possible for them to use their EU Digital Identity Wallets 
to have access to existing standalone trust services such as electronic signatures and timestamps as 

29 

 
well  as  the  newly  created  communications  channel  without  needing  to  purchase  a  fully-fledged 
Business Wallet. 

A central principle established under this policy option is that actions and transactions carried out 
through the European Business Wallets’ minimum core functionalities carry equivalent legal effect 
as if carried out in person or in paper form. 

To guarantee a high level of trustworthiness, and therefore to ensure that the user can receive and 
exchange qualified electronic attestations of attributes and credentials related to their identity, the 
European Business Wallets should be interoperable. 

A central element of this policy option is ensuring that the European Business Wallets are not just 
available on the market  but also  widely used in practice. Economic operators will  have a strong 
incentive  to  adopt  the  wallet  if  they  can  see  concrete  improvements  and  simplifications  in  their 
business processes and exchanges with partners and counterparties, as well as being able to rely on 
it  to  meet  their  day-to-day  compliance  and  reporting  obligations.  For  this  reason,  public  sector 
bodies play a crucial role in creating the conditions for uptake of the European Business Wallets. 
They  can  create  the  demand  pull  to  allow  economic  operators  to  turn  to  a  single  trusted  channel 
instead of navigating multiple fragmented national solutions. By doing so, the European Business 
Wallets  will  be  the  recognised  and  trusted  pathway  through  which  essential  commercial  and 
administrative  interactions  take  place.  This  approach  directly  responds  to  the  demand  from 
economic  operators  for  simplification  and  reduces  the  cost  and  complexity  of  cross-border 
compliance. 

The  overall  direction  is  clear:  the  European  Business  Wallets  are  intended  to  support  economic 
operators and  become the standard tool for secure and efficient exchanges between  the latter  and 
public  sector  bodies  across  the  EU.  Stakeholder  consultations  conducted  as  part  of  the 
accompanying study reveal strong interest in the initiative, with 86% of surveyed EOs and PSBs 
indicating a willingness to adopt the Wallet64. 

The EUBW will complement the EUDI Wallets’ digital identity capabilities by tailoring the ability 
to handle digital Powers of Attorney (PoA) for business use cases specifically. A digital PoA will 
enhance security and trust in legal representation. Legal entities will be able to issue, revoke, and 
track PoAs digitally through the EUBW, ensuring that only authorised individuals can act on their 
behalf.  This  reduces  the  risk  of  abuse  and  potential  fraud  as  well  as,  and  administrative  errors, 
while also providing a legally binding audit trail. The verification of PoAs will also be simplified, 
as  this  is  often  a  time-consuming  and  manual  process.  The  EUBW  will  aid  in  automating  these 
processes  by  providing  digitally  signed,  EAAs  that  instantly  confirm  the  identity,  legal  capacity, 
and representation rights of the assignor, thus significantly reducing the administrative burden for 
notaries, registries, and economic operators. The Business Wallets would also be compatible with 
EU Digital Power of Attorney introduced by the Upgrading Digital Company Law Directive (EU) 
2025/25.  The  EUBW  will  incorporate  a  mandate-,  role-  and  attribute-based  authorisation 
mechanism  allowing  businesses  to  delegate  rights  and  permissions  securely  and  flexibly  to 
representatives. This can be particularly beneficial for SMEs. 

64 Nearly all (95%) of EOs replied positively whether they were willing to adopt the EUBW and more than two-third of 
PSBs (68%) voiced similar support. The survey gathered responses from 65 participants across 20 different countries. 
Of  these,  35%  represented  public  administrations,  while  the  remaining  65%  were  Economic  Operators,  including 
business associations and educational institutions. 

30 

 
 
The EUBW will include features like traceability and system integration (ERPs, CRMs and other 
core business applications through secure APIs65), directly tackling three key problems: fragmented 
national portals, inefficient administrative processes, and cumbersome compliance obligations. The 
framework will further guarantee the portability of data in a structured, machine-readable format, 
ensuring interoperability and avoiding vendor lock-in. To remain future-proof, minimum technical 
requirements  will  be  defined  in  legislation  so  that  the  system  can  integrate  emerging  technology 
applications such as agentic AI or digital identity for assets. 

Finally,  the proposed European Business Wallets Regulation  will be  use-case-agnostic:  that is  to 
say, specific use cases will not be prioritised in the legislation itself. This approach ensures that the 
initiative  provides a horizontal foundation that enables a wide variety  of use cases, while leaving 
room  for  the  market  to  develop  innovative  applications  over  time.  In  doing  so,  the  European 
Business Wallets can serve as a flexible and future-proof solution, capable of adapting to evolving 
needs  across  sectors.  Nevertheless,  to  demonstrate  the  practicality  and  utility  of  the  European 
Business Wallets, and to illustrate how it can deliver on the specific objectives outlined in Chapter 
4,  the  table  below  presents  some  concrete  use  cases  identified  by  stakeholders  where  its  use  can 
streamline processes and reduces burdens for economic operators and public sector bodies: 

Table 2 – Illustrative use cases to streamline processes and reduce burdens as identified by stakeholders 

Use case 

Current challenges 

How the EUBW 
streamlines the process 

Illustrative effect  

Onboarding & Due 
Diligence – KYC  

Manual document 
collection, costly 
compliance checks, long 
processing times (up to 
50 days). 

Provides verified digital 
credentials, real-time 
confirmation of identities, 
and cross-border 
interoperability. 

Reduces onboarding 
time from weeks to 
days; potential 30–
50% cost reduction. 

Legal Representation -
PoA 

Time-consuming and 
expensive manual 
verification of mandates; 
apostilles. 

Issues, revokes, and tracks 
PoAs digitally; provides 
audit trails and cross-
border recognition. 

SMEs can delegate 
tasks securely without 
travelling or 
duplicating paperwork. 

Public Procurement 

Lengthy procedures (96 
days avg. to award); 
extensive documentation 
burdens for SMEs. 

Pre-qualified credentials 
stored in EUBW; 
automatic validation; 
digital tender participation. 

Running a Business- 
especially cross-border 

Repeated submissions, 
need for physical 
presence, inconsistent 
national procedures. 

Secure digital submission 
of verified credentials 
across Member States; 
machine-readable format. 

Faster contract awards; 
higher SME 
participation; potential 
€20 billion/year 
savings from 1% 
efficiency gain. 

Obtaining permits 
across borders 
completed remotely in 
days instead of 
months. 

65  Enterprise  Resource  Planning  (ERP),  Customer  Relationship  Management  (CRM),  Application  Programming 
Interface  (API).  ERPs  and  CRMs  are  core  business  applications  that  manage  key  organisational  processes  -  ERPs 
handle  internal  operations  such  as  finance,  supply  chain,  and  human  resources,  while  CRMs  manage  customer 
interactions  and  sales.  Connecting  these  and  other  core  business  tools  through  secure  APIs  means  enabling  safe, 
standardised data exchange between systems, ensuring interoperability and data protection. 

31 

 
 
Use case 

Current challenges 

How the EUBW 
streamlines the process 

Illustrative effect  

Tax Management - 
eInvoicing  

Supply Chain (KYS, 
DPP)66 

Fragmented systems; 
diverse national formats; 
invoice fraud; SME 
compliance costs 1–2% 
of turnover. VAT fraud 
losses currently ~€11 
billion/year. 

Lack of transparency; 
multiple identifiers.; 
weak cross-border 
recognition. 

Provides trusted identifiers 
and secure channels; 
verifies VAT credentials; 
streamlines reporting. 

Cuts fraud risk; 
reduces SME burden. 

Links verified supplier 
data and product 
credentials to EUBW; 
supports traceability and 
sustainability reporting. 

Easier compliance with 
EU sustainability 
requirements; lower 
risk of supplier fraud. 

6. 

IMPACTS OF THE POLICY OPTION  

This  chapter  presents  the  main  expected  economic  impacts  (costs  and  benefits)  of  the  European 
Business  Wallets,  as  presented  in  Chapter  5.  Costs  and  benefits  are  summarised  by  stakeholder 
group,  public  sector  bodies  (PSBs)  and  different  categories  of  economic  operators  (EOs)  and  are 
further detailed in Annex 3. 

A cost-benefit analysis (CBA) based on the Standard Cost Model67 was carried out to quantify the 
costs and benefits in monetary units of four theoretical ranges (10%; 33%; 50% and 75%, presented 
in more detail in section 7.1) reflecting different levels of adoption of the EUBW by EOs, and to 
identify the most efficient range, i.e. the one with the highest net benefits (i.e. benefits less costs). 
The estimates quoted in this chapter are based on mixed-method research including quantitative and 
qualitative  analysis  of  public  sources,  survey  data  and  interview  data  combined  with  secondary 
sources. Details on the methodology used to derive the estimates are provided in Annex 4. 

6.1.  Costs 

Owners68 of the European Business Wallets will incur annual costs for its use. There will be one-off 
costs in the first year of use and then recurring annual costs going forward. While the scale of these 
costs will vary depending on the type and size of the entity, they represent the necessary investment 

66  For  example,  SMEs  can  save  approximately  5%  of  one  full-time  employee  (FTE)  annually  by  optimising  supply 
chain  management,  onboarding,  and  supplier  monitoring.  These  efficiency  gains  can  translate  into  a  global  annual 
saving  of  around  $61.9  billion  for  SMEs  engaged  in  international  trade.  Additionally,  by  reducing  the  cost  and 
complexity  of  client  onboarding,  these  tools  enhance  SMEs’  access  to  financial  services,  further  supporting  their 
growth and competitiveness in global markets. 
67  The  main  aim  of  the  model is  to  assess  the  net  cost  of  administrative  obligations  imposed  by  EU  legislation:  Net 
costs = costs introduced by a proposal if adopted, minus the costs it eliminates at EU and/or (sub)national level. See: 
Better Regulation guidelines, Chapter 8 – Methodologies for analysing impacts in impact assessments, evaluations, and 
fitness checks 
68  For  the  purposes  of  European  Business  Wallets,  “owner”  refers  to  the  Public  Sector  Body  (PSB)  or  Economic 
Operator  (EO)  to  whom  the  Business  Wallet  is  issued.  “Users”  are  natural  persons  (e.g.  employees,  authorised 
representatives, or third parties) who are granted rights to use the functionalities of the wallet on behalf of the owner. 

32 

 
 
 
to  access  a  harmonised,  trusted  instrument  for  identification,  authentication  and  secure  data 
exchange across the Union tailored to the need of EOs and PSBs. 

One-off costs include: 

•  Training and onboarding, which primarily reflect the expenses associated with staff training, 
change  management,  and  the  preparation  of  documentation  required  to  ensure  that 
employees can  implement  and operate  the European Business Wallets effectively69. These 
costs  may  vary  in  function  of  the  proportion  of  employees  dedicated  to  administrative 
activities, and in function of the type and structure of the entity. 

•  Activation  and  IT  implementation,  including  installation  of  software,  database  setup  and 
management, integration with proprietary systems. For larger organisations, these costs may 
also include audit, security, or general expenses linked to system configuration. These costs 
do not include the decommissioning of existing non-digital processes. 

•  Procurement70, consisting of the administrative effort required for contract management and 
for  selecting  and  contracting  European  Business  Wallet  Providers.  This  step  may  involve 
tendering  procedures  for  public  sector  bodies  and  contracting  or  legal  expenses  for 
economic operators. 

Recurring costs include: 

•  Licensing  fees  covering  the  use  of  European  Business  Wallets’  services  provided  by 
authorised  Wallet  Providers.  These  fees  also  include  access  to  maintenance  services 
provided by Wallet Providers to ensure reliability, compliance with evolving standards, and 
the continuity of service.  

This section explores the costs borne by EOs and PSBs in more detail. In addition, at the end of the 
section, costs to be incurred at the EU level are also examined. 

6.1.1.  Costs borne by public sector bodies 

The  scenario  of  100%  adoption  by  PSBs  is  used  as  the  reference  for  cost  estimations,  given  that 
PSBs  in  the  EU  must  be  able  to  accept  the  European  Business  Wallets  in  their  interactions  with 
EOs  for  purposes  such  as  identification  and  authentication,  signing  or  sealing  documents, 
submitting documents, and sending or receiving notifications. Assuming 100% adoption by PSBs 
also ensures that costs are not underestimated. Consequently, the costs borne by PSBs will not vary 
in function of the examined ranges of EO adoption71. 

69 See Business Wallet Study, NTT Data, October 2025, Section 3.1.1, and Annex 3, 7.1.2. 
70 This cost category is called “procurement costs” for PSBs, and “contracting costs” for EOs. 
71  The  underlying  assumption  is  that  100%  of  PSBs  will  adopt  the  European  Business  Wallets,  and  that  the 
corresponding  share  of  usage  will  depend  on  the  level  of adoption  by  economic operators.  PSBs  will  incur  adoption 
costs irrespective of use because they will need to adopt the EUBW to be ready for any given level of adoption by EOs. 
For example, even if the EUBW was not widely used  by EOs at a given point in time, the PSBs would still need to 
make the necessary preparations to ensure that EOs can benefit from using the core functionalities of the EUBW. The 
estimation  of  licencing  fees  and  maintenance  costs  assumes  that  EUBW  will  not  price  for  PSBs  the  instrument  in 
function of intensity of use. This does not prejudge the fact that licencing fees may vary in function of the PSB size and 
related operations complexity (e.g. bigger entities will need a higher number of EUBW accounts). 

33 

 
 
The total number of PSBs in the EU (including the European Union institutions, agencies, offices 
and bodies) is estimated at a representative set of 95,82572. The table below highlights average one-
off and recurring costs per PSB individual entity, calculated as a weighted average, both for the first 
year of adoption (Y1) and the following year (Y2). In Y2 only recurring costs apply and therefore 
costs are significantly reduced.  

Table 3 – Weighted average annual costs for PSBs 

Weighted average costs for Public Sector Bodies (PSBs) 

COSTS 

ONE-OFF COSTS 

Training and onboarding costs 

Activation and IT implementation costs 

Procurement costs 

TOTAL ONE-OFF COSTS 

RECURRING COSTS 

Licensing fee and maintenance costs 

TOTAL RECURRING COSTS 

Y1 TOTAL COSTS 

Y2 TOTAL COSTS 

€ 

€28,531 

€26,890 

€9,121 

€64,542 

€11,956 

€11,956 

€76,497 

€11,956 

Small local authorities (i.e. defined as local administrations in municipalities with fewer than 5,000 
inhabitants)  constitute  76.7%  of  total  public  administrations  (see  table  19).  While  the  other 
categories of public administrations (mid-large local authorities, i.e. with a population of more than 
5,000  inhabitants;  and  regional/central  authorities)  exhibit  higher  costs,  these  represent  a  much 
smaller proportion of the total population73. The average cost for the most prevalent administration, 
i.e. small local authorities, is €17,820, which provides a more typical benchmark. 

When taking into account the total number of PSBs, the total estimated costs for all PSBs74 in the 
case of 100% adoption of the European Business Wallets by EOs amounts to around €7.33 billion 
annually in  year 1, split between  around €6.18 billion of one-off costs and  about €1.15  billion of 
recurring costs. 

72  The  purpose  was  to  establish  a  stable  and  reliable  estimate  of  PSBs  in  the  EU  considered  most  relevant  for 
interactions with economic operators under the European Business Wallets framework.  The figure of 95,825 PSBs is 
derived by aggregating different administrative level and sizes with a bottom-up approach: 95,068 municipalities, 757 
central administrations (regional, national and EU, including 244 regional authorities, 434 ministries, and 79 European 
Union institutions, agencies, offices and bodies). See Business Wallet Study, NTT Data, October 2025, Annex 3, Table 
21: Distribution of Public Administrations by size. 
73 For public sector bodies, weighted averages are used for both costs and benefits to allow for the calculation of net 
benefits.  While it has been possible to segment the costs by size  of PSB on the basis of headcount into national and 
regional administrations, large municipalities, and small municipalities, the benefits (see Section 6.2) are segmented by 
efficiency levels, as size-based data is unavailable and efficiency is the key differentiating factor. Because it was not 
possible to have more granular data about PSB’s benefits by size, the presentation of the costs and benefits is limited to 
the weighted average to ensure comparability. Limitations to the analytical model are set out further in Annex 4. 
74 Calculated by adding, for of each category of PSB, the average costs of that category multiplied by the total number 
of PSBs in that category. 

34 

 
  
 
 
 
 
Table 4 – Annual costs PSBs: total 

ALL Public Sector Bodies (PSBs) 

COSTS 

TOTAL 

ONE-OFF COSTS 

Training and onboarding costs 

Activation and IT implementation costs 

Procurement costs 

TOTAL ONE-OFF COSTS 

RECURRING COSTS 

Licensing fee and maintenance costs 

TOTAL RECURRING COSTS 

Y1 TOTAL COSTS 

Y2 TOTAL COSTS 

€2.73bn 

€2.58bn 

€0.88bn 

€6,19bn 

€1,15bn 

€1,15bn 

€7,34bn 

€1,15bn 

6.1.2.  Costs borne by economic operators 

For EOs75, the split of one-off and recurring costs for different types of EO category76 are reported 
at an individual, average entity level in the table below for both years Y1 and Y2.  

Table 5 – Annual costs per EO: individual entities 

INDIVIDUAL Economic Operators (EOs) 

COSTS 

ONE-OFF COSTS 

Training and onboarding costs 

Activation and IT implementation costs 

Contracting costs 

TOTAL ONE-OFF COSTS 

Microenterprises77 
<10 employees 

SMEs 
10-250 employees 

Corporates 
> 250 employees 

€520 

€100 

€0 

€620 

€1,400 

€800 

€400 

€14,000 

€150,000 

€16,000 

€2,600 

€180,000 

75  For  the  purposes  of  the  costs  and  benefits  calculations,  economic  operators  include  both  enterprises  and  natural 
persons operating as sole traders. For enterprises,  the Eurostat definition was used.  An enterprise is an organisational 
unit producing goods or services which has a certain degree of autonomy in decision-making, and can carry out more 
than one  economic activity and be situated at more  than one  location.  It may consist out of one or more legal units: 
these include legal persons whose existence is recognised by law independently of the individuals or institutions which 
may  own  them  or  are  members  of  them,  such  as  general  partnerships,  private  limited  partnerships,  limited  liability 
companies,  incorporated  companies  etc.  Legal  units  also  include  natural  persons  who  are  engaged  in  an  economic 
activity  in  their  own  right,  such  as  the  owner  and  operator  of  a  shop  or  a  garage,  a  lawyer  or  a  self-employed 
handicrafts-man. 
76  The  category  of  Corporate  with  250+  employees  is  particularly  heterogeneous,  and  a  corporate  of  around  1,000 
employees was used as a reference for the estimate. See Annex 4 for more details. 
77 As noted in the previous footnote this includes the self-employed This includes natural persons who are engaged in 
economic  activities  who  are  both  incorporated  as  legal  units  (see  footnote  above  that  includes  the  definition  of 
enterprises) and who are unincorporated and trade in their own name as natural persons. 

35 

 
  
 
 
 
 
RECURRING COSTS 

Licensing fee and maintenance costs 

TOTAL RECURRING COSTS 

Y1 TOTAL COSTS 

Y2 TOTAL COSTS 

€500 

€500 

€1,120 

€500 

€5,000 

€5,000 

€7,600 

€5,000 

€50,000 

€50,000 

€230,000 

€50,000 

Assuming 75% adoption, the maximum level of adoption as estimated in the ranges presented in 
section 7.1, of the European Business Wallet, the total estimated costs for all EOs amounts to 
over €45 billion in the first year, split between around €25 billion of one-off costs and around €21 
billion of recurring costs. In subsequent years, the total estimated annual costs for EOs will be 
about €21 billion. The total number of EOs in the EU is 32,721,957, of which 30,836,373 (94,2%) 
are microenterprises with less than 10 employees, 1,832,523 (5.6%) are SMEs with at least 10 
employees, and 53,061 (0.2%) are corporates with at least 250 employees78. The table below shows 
further details regarding the sum of all EOs. 

Table 6 – Annual costs EOs: total 

COSTS 

ONE-OFF COSTS 

ALL Economic Operators (EOs) at 75% adoption 

Microenterprises 
<10 employees 

SMEs 
10-250 
employees 

Corporates 
> 250 employees 

TOTAL 

Training and onboarding costs 

€12.03bn 

€1.92bn 

€0.56bn 

€14.51bn 

Activation and IT implementation costs 

€2.31bn 

€1.10bn 

€5.97bn 

€9.38bn 

Contracting costs 

€0 

€0.55bn 

€0.64bn 

€1.19bn 

TOTAL ONE-OFF COSTS 

€14.34bn 

€3.57bn 

€7.17bn 

€25.08bn 

RECURRING COSTS 

Licensing fee and maintenance costs 

€11.56bn 

€6.87bn 

€1.99bn 

€20.42bn 

TOTAL RECURRING COSTS 

€11.56bn 

€6.87bn 

€1.99bn 

€20.42bn 

Y1 TOTAL COSTS 

Y2 TOTAL COSTS 

€25.90bn 

€10.44bn 

€9.16bn 

€45.50bn 

€11.56bn 

€6.87bn 

€1.99bn 

€25.08bn 

In the theoretical scenario of 100% adoption of the European Business Wallet, the total estimated 
costs for all EOs amounts to nearly €61 billion in the first year, split between around €34 billion 
of one-off costs and around €27 billion of recurring costs, including in subsequent years. 

78 See segmentation in Business Wallet Study, NTT Data, October 2025, Annex 3, Table 23: Overview of the Economic 
Operators’ landscape in terms of trade engagement levels and digitalisation. 

36 

 
  
 
 
  
 
 
 
  
 
 
 
  
 
 
 
 
 
 
 
Microenterprises – Considerations on self-employed and sole traders  

The  cost-benefit  analysis  applies  to  all  microenterprises  using  the  European  Business  Wallets, 
including  self-employed  individuals  and  sole  traders—who  represent  approximately  63%  of 
microenterprises  when  considering  one-person  businesses79.  According  to  the  Cost  Table  on 
Individual  Economic  Operators,  microenterprises  are  expected  to  incur  a  one-off  cost  of  €620  in 
Year 1, followed by annual recurring costs of €500 to adopt the European Business Wallet80. 

Self-employed  individuals  and  sole  traders  could  use  their  EU  Digital  Identity  Wallets  to  access 
existing  business-related  trust  services—such  as  electronic  signatures,  timestamps,  and  seals—as 
well  as  the  newly  introduced  communications  channel  to  interact  with  the  Business  Wallet 
ecosystem.  These  services  can  be  accessed  as  standalone  offerings,  as  a  possible  alternative  to 
purchasing  a  fully-fledged  Business  Wallet.  Based  on  current  market  prices  across  the  EU, 
estimated annual recurring costs for such standalone services are: 

•  €45 for the new communications channel 
•  €150–200 for electronic signatures 
•  €350–400 for seals 
•  €235–285 for timestamps81 

This  suggests  that  self-employed  individuals  and  sole  traders  could  access  the  Business  Wallets 
ecosystem starting at a relatively low cost (starting at €45). For those who make more extensive use 
of trust services, opting for a fully-fledged Business Wallet may be more cost-effective. 

6.2.  Direct benefits 

Measuring the impact of reducing administrative burdens remains complex. As noted in the Draghi 
Report82,  there  is  no  common  EU  methodology83  or  coordinated  approach  for  assessing  such 
impacts. As a result, aggregate quantifications of regulatory burdens in the EU are fragmented, and 
available estimates often stem from private-sector initiatives84. 

For the purpose of this Staff Working Document, the analysis of the cost-savings potential focuses 
on  the  improvements  that  the  European  Business  Wallets  can  bring  to  EOs  by  facilitating 
compliance  and  reporting  obligations  through  the  automation  of  processes,  and  to  PSBs  by 
streamlining  related  interactions.  For  the  purposes  of  this  SWD,  direct  benefits  represent  the 
potential maximum annual savings that could be realised by PSBs and EOs through the reduction or 
elimination of manual processes in administrative activities, enabled by digitisation and automation 
following  adoption  of  the  wallets.  These  annual  benefits  have  been  estimated  through  the  cost-
benefits analysis. Nevertheless, the estimation of these maximum direct benefits for the purpose of 
the CBA is conservative in that it is limited to direct benefits as cost savings. Additional benefits 

79 Based on 2023 Eurostat figures for Self-employed persons without employees (own-account workers), accounting for 
19.3M in the EU and compared to the 30.8M of microenterprises in scope. 
80  These  costs  at  entity  level  for  microenterprises  have  been  used  to  calculate  the  total  costs  as  reflected  in  the  Cost 
Table on “All Economic Operators”; see also Annex 4. 
81 The average estimated yearly costs refer to the purchase of about 100 electronic signatures, seals and timestamps 
82 Draghi report, Part A, chapter 6: p. 68. 
83 The Commission has developed a methodology (the Standard Cost Model) to calculate regulatory burdens. 
84 Draghi report, Part B, chapter 1, p. 11; Part B, chapter 5, p. 317. 

37 

 
 
 
 
that do not fall under the category of cost savings are analysed, together with indirect benefits, in 
chapter 8. 

The  supporting  European  Business  Wallets  study85  has  selected  for  its  purposes  six  categories  of 
administrative  activities  expected  to  be  impacted  by  the  EUBW,  which  constitute  the  estimated 
direct  benefits  as  cost-savings  opportunities  that  could  be  realised  by  PSBs  and  EOs,  including 
examples of such activities: 

Table 7 – Categories of administrative activities where cost-savings are expected 

Category 

PSBs 

EOs 

Identification  & 
authorisation 

•  Verifying the legitimacy of EOs, including 
conducting anti-fraud and security checks 

•  Verifying the legitimacy of other 

EOs 

•  Confirming identities of the company’s 

representatives or applicants (e.g., checking 
eID, mandates) 

Exchange 
of 
documents  and 
information 

•  Receiving and processing documentation 
and information (e.g., application files, 
certificates, declarations) 

•  Ensuring secure exchange channels for 

receiving documents and data, and sending 
acknowledgments or requests for further 
information 

•  Presenting proof of the company 
representative’s identity and 
authorisation (e.g. providing 
mandates or using qualified digital 
signatures on documents) 

•  Preparing required documentation 

(e.g., certificates, permits) 
•  Securely submitting or sharing 
documents, attributes, and 
attestations 

•  Providing self-declarations or 

statements (e.g., responsible 
statements attesting compliance) 
and producing any required 
product or service information 

Compliance and 
verification 

Record  keeping 
and 
data 
management 

•  Verifying authenticity of documents and 

•  Complying with verification 

checking that the EO meets all 
requirements 

•  Performing compliance checks and due 

diligence (including cross-checking across 
databases and conducting 
inspections/audits). 

•  Keeping detailed records of data and 
documents received (e.g., filing 
applications, storing certificates and 
correspondence). 

•  Updating and managing data over time, 
ensuring information remains current in 
government systems 

requests by providing additional 
evidence or clarification 
•  Confirming that submitted 
materials meet formality 
requirements 

•  Maintaining internal records of 

specific business or administrative 
process (e.g., a repository of 
credentials, permits, actions made 
or persons represented through the 
Power of Attorney) and ensuring 
they are up to date (e.g. tracking 
expiration dates of certificates and 
renewing them on time). 

•  Updating information previously 

given to authorities where changes 
occurred 

Permissions and  •  Providing requested credentials and 

•  Applying for and obtaining 

85 Business Wallet Study, NTT Data, October 2025, Annex 2, Table 11: Identified relevant and administrative activities. 

38 

 
 
Category 

certification 

Cross-border 
coordination 
and recognition 

PSBs 

EOs 

certificates 
Issuing identification numbers 

• 
•  Facilitating applications for permissions 

and certifications 

•  Verifying documents issued by other PSBs 

• 

across borders within the EU 

necessary credentials, licenses, or 
certificates to operate in specific 
sectors or locations 

Identifying the correct authority in 
another Member State, and 
adapting to specific requirements 
and procedures. 

The  impact  of  the  European  Business  Wallets  will  largely  depend  on  their  adoption  by  EOs  and 
PSBs  in  their  respective  interactions  (B2G,  G2B)86.  For  other  types  of  interactions  (i.e.  B2B), 
network effects are expected to generate a positive spillover, for example from B2G/G2B into the 
B2B  domain.  Accordingly,  the  estimation  of  the  direct  benefits  takes  into  account  these  different 
types of interaction and varies in function of the adoption rate of EOs in particular. 

Direct  benefits,  defined  for  the  purpose  of  this  analysis  as  cost-savings  resulting  from  the 
digitalisation  or  automation  of  administrative  activities  for  both  PSBs  and  EOs,  have  been 
estimated  using  the  EU  Standard  Cost  Model.  The  estimation  builds  on  the  categories  of 
administrative  activities  listed  in  Table  7  and  is  based  on  a  calculation  of  administrative  costs, 
taking into account the following variables87: 

• 

time  spent  on  each  administrative  activity  and  its  frequency,  calculated  on  the  basis  of 
primary data collected through the survey conducted by the Business Wallet study; 

•  hourly labour costs per employee, based on official statistical data; 
•  number of employees per entity and the share of staff involved in administrative activities; 
• 

total number of entities concerned. 

The  calculation  formulas  applied  for  PSBs  and  EOs,  together  with  additional  methodological 
details, are set out in Annex 4. 

At an individual entity level, the direct benefits per PSB are estimated at about €199,60088. It was 
not possible to disaggregate this amount per category of PSBs, as the underlying data point used for 
the  calculation  is  not  available  in  a  disaggregated  form89.  For  EOs  the  direct  benefits  are  broken 
down as follows: 

86  This  concerns  the  acceptance  and  use  of  the  minimum  EUBW  functionalities  for  the  purposes  of  identification, 
authentication,  the  submission  of  documents,  and  the  sending  and  receiving  of  notifications  within  the  context  of 
meeting reporting obligations or fulfilling administrative procedures. 
87 See Business Wallet Study, NTT Data, October 2025, Section 7.1.3 Estimating benefits. 
88  See  Business  Wallet  Study,  NTT  Data,  October  2025,  Section  7.1.3,  Table  29  Annual  benefits  by  category  for  an 
average Public Sector Body. 
89 The calculation is based on a tariff approach using a weighted average of labour costs for civil servants across the 
EU.  This  data  is  not  available  in  a  form  segregated  by  PSB  administrative  level  or  size,  which  prevents  further 
disaggregation. See Business Wallet Study, NTT Data, October 2025, Section 7.1.3, Table 29 and Annex 3, 7.1.5. 

39 

 
 
 
 
 
Table 8 – Annual direct benefits EOs 

INDIVIDUAL Economic Operators (EOs) 

BENEFITS 

DIRECT BENEFITS 

Microenterprises 
<10 employees 

SMEs 
10-250 employees 

Corporates 
> 250 employees 

€4,000 

€42,250 

€97,300 

Assuming a 75% level of adoption, the total direct benefits were estimated at around €169 billion, 
split  into  approximatively  €14  billion  for  PSBs  and  €155  billion  for  EOs90.  These  estimates 
therefore  represent  the  estimated  upper  bound  of  potential  benefits,  corresponding  to  the  gains 
that could result from replacing all manual processes with streamlined digital processes enabled by 
the European Business Wallets, in case of 100% adoption by PSBs and 75% by EOs91. 

To  estimate  the  minimum  expected  direct  benefits  in  relation  to  the  75%  adoption  scenario, 
survey replies were taken into account92. Respondents were asked: “To what extent do you believe 
that digitalising the previously listed activities with a unified European framework could reduce the 
cost of performing them?93”. 

•  Among 24 PSB respondents94, 48% expected a very large or large reduction (above 30%), 
and  35%  a  moderate  reduction  (10%-30%).  Assigning  a  minimum  value  to  each  range95 
resulted in a weighted average minimum reduction of 22%. 

•  Among  38  EO  respondents96,  79%  expected  a  very  large97  or  large  extent  (above  30%) 
reduction,  and  16%  a  moderate  reduction  (10%-30%).  The  weighted  average  minimum 
reduction was 36%. 

Survey replies were also further validated in in-depth interviews with selected survey respondents. 
See Annex 4 for further details. 

Applying these percentages to the direct benefit estimates for each category of stakeholder resulted 
in a total minimum direct benefit of €58.42 billion for PSBs and EOs combined. The overview of 
minimum and maximum benefit estimates is presented in the table below. 

90 See Business Wallet Study, NTT Data, October 2025, Section 7.1.3. 
91 This corresponds to range 4 as examined in the following sections. In the theoretical scenario of 100% adoption by 
both PSBs and EOs, the total direct benefits would be estimated at around €225 billion, split into approximatively €19 
billion for PSBs and €206 billion for EOs 
92 The minimum benefits are not explicitly referred to in the support study, but they result from a further elaboration of 
replies to the survey conducted in the context of the same Business Wallet Study. 
93 The reply options were: “I don’t know”; “Not at all”; “To a small extent (up to 10% reduction)”; “To a very large 
extent (more than 50% reduction); “To a large extent (30-50% reduction)”; “To a moderate extent (10-30% reduction)”. 
94 Excluding the “I don’t know” option, which amounted to 1 reply. 
95 Assigned value were: 0% for “Not at all”; 1% for “To  a small extent (up to 10% reduction)”; 51% for “To a very 
large  extent  (more  than  50%  reduction);  30%  for  “To  a  large  extent  (30-50%  reduction)”;  10%  for  “To  a  moderate 
extent (10-30% reduction)”. 
95 Excluding the “I don’t know” option, which amounted to 1 reply. 
96 Excluding the “I don’t know” option, which amounted to 2 replies. 
97 50% of the EO respondents expected a very large reduction (more than 50% reduction). 

40 

 
 
 
 
Table 9 – Annual minimum and maximum direct benefits: PSBs and EOs 

Min direct benefits 

Max direct benefits 

€3.10bn 

€55.32bn 

€58.42bn 

€14.34bn 

€154.45bn 

€168.79bn 

PSB 

EO 

6.3.  Net benefits 

Taking into account the cost and direct benefits  presented in the previous sections,  and under the 
scenario  where  75%  of  PSBs  and  EOs  adopt  the  European  Business  Wallets,  the  table  below 
provides  an  overview  of  the  maximum  total net  direct  benefits  for  the  first  year98,  estimated  at 
€115.97  billion.  Once  the  one-off  costs  have  been  absorbed,  the  maximum  net  direct  benefits 
increase to €147.22 billion in the second year. 

Table 10 – Overview of maximum net benefits year 1 and year 2: total 

Stakeholder  No. in the EU 

Benefits 

Costs 

Net 
benefits 

Benefits 

Costs 

Year 1 (€bn) 

Year 2 (€bn) 

Public 
bodies 

sector 

Economic 
operators 

Total 

95,825 

14.32  

7.32 

7.02 

19.13 

1.14 

32,721,957  154.45 

45.50 

108.95 

154.45 

20.43 

  168.79 

52.82 

115.97 

168.79 

21.57 

Net 
benefits 

13.20 

134.02 

147.22 

7.  ANALYSIS OF DIFFERENT USAGE RATES 

7.1.  Ranges of adoption by economic operators 

As  mentioned  in  section  6.2,  the  direct  benefits  are  estimated  as  a  function  of  adoption  rates  by 
EOs. This chapter presents an overview of the variation of benefits on a progressive scale of usage 
of the EUBW in function of the adoption by EOs.  

For the purpose of the cost-benefit analysis, the following definitions were used99: 

•  Adoption  rate:  the  share  of  stakeholders  that  will  have  adopted  the  EUBW.  Adoption 
automatically generates costs regardless of whether the tool is actively used in interactions 
with other EUBW owners. 

•  Usage rate: the effective use of the EUBW in practice, derived from the engagement EOs 
have with PSBs. It is calculated by multiplying the different levels of EO adoption rates by 

98 Counting both one-off and recurring costs. 
99 The definition of “engagement rate” has been incorporated into the definition of “usage rate”.  See Business Wallet 
Study, NTT Data, October 2025, Annex 4. 

41 

 
 
 
 
 
 
the  PSB  adoption  rate.  Usage,  rather  than  adoption  alone,  determines  the  extent  to  which 
stakeholders can realise benefits, since adoption without actual use yields no cost savings. 

The adoption rate for PSBs is assumed to be at 100%, reflecting the requirement for PSBs to enable 
the  use  of  the  core  functionalities  of  European  Business  Wallets  by  EOs  (i.e.,  proving  identity, 
signing/sealing,  submitting  documents,  or  receiving  official  notifications).  For  EOs,  a  set  of 
adoption  ranges  has  been  defined  to  capture  progressively  higher  potential  levels  of  adoption,  as 
summarised below100. 

•  Range  1  (10.43%)  represents  the  estimated  share  of  EOs  whose  readiness  to  adopt  the 
EUBW is based on a combination of two factors: activity across-borders in the EU and high 
digital intensity101 

•  Range 2 (33%) represents the assumption that one third of EOs will adopt the EUBW. This 
range  is  consistent  with  the  threshold  used  to  estimate  adoption  in  the  2021  Impact 
Assessment102 

•  Range 3 (50%) represents the assumption that one half of EOs will adopt the EUBW. 

•  Range 4 (75%) represents a realistic upper bound adoption target of the EUBW by EOs, and 
is  also  in  line  with  industry  ambitions  as  derived  from  the  DigitalEurope  KPI  for  use  of 
business wallets by 2030103 

Finally, the total achievable level of benefits is a theoretical scenario of 100% adoption by all 
EOs. 

7.2.  Net direct benefits across ranges 

For each adoption range by EOs, both the costs incurred and direct benefits for PSBs and EOs have 
been  analysed.  Costs  –  both  one-off  and  recurring  –  vary  in  proportion  to  the  adoption  rate.  In 
practice, 100% of the PSBs will incur costs, as will those EOs that take up the instrument104. Direct 
benefits105  –  estimated  as  annual  savings  that  could  potentially  be  realised  by  PSBs  and  EOs 
through  the  reduction  or  elimination  of  manual  processes  in  administrative  activities  –  vary  in 

100 The ranges used in the accompanying study provided a basis for further analysis as reflected above. 
101  Calculation  based  on  readiness  index  combining  rates  of  highly  digitised  companies  and  of  companies  operating 
across borders within the EU. See Business Wallet Study, NTT Data, October 2025, Annex 3, Table 23 (Overview of 
the Economic Operators’ landscape in terms of trade engagement levels and digitalisation) 
102  The 2021 Impact  Assessment  had  three  intermediary ranges:  20%,  33%,  67%.  The  range  of  20%  was  substituted 
with the 10.43% resulting from the analysis of the support study, and the range of 67% was substituted with  the 50% 
representing  a  near  midpoint  between  33%  and  the  maximum  threshold  of  75%.  Regarding  the  2021  Impact 
Assessment, see the section on economic impacts of the Study to support the impact assessment for the revision of the 
eIDAS regulation, PWC and DLA Piper, 2021, pages 135 and following. https://data.europa.eu/doi/10.2759/671740 
103 Derived from the proposed DigitalEurope target KPI for business wallet use in cross-border legal, administrative and 
commercial  interactions  by  EU  businesses  by  2030;  see:  https://www.digitaleurope.org/public-administration/.  See 
more in Annex 4. 
104 All PSBs are considered for the purpose of estimating costs. PSBs are classified in different size categories, namely 
European Union institutions, agencies, offices and bodies, Central administrations (national and regional governments), 
Mid-Large  Local  Administrative  Units  (municipalities  with  5.000+  inhabitants  and  other  LAUs),  and  Small  Local 
Administrative Units (municipalities with < 5.000 inhabitants). 
105 Direct benefits have  been presented in Chapter 6.  For further details on how direct benefits are calculated, please 
refer to Annex 4. 

42 

 
 
 
function of the estimated usage rate106, which reflects the interaction dynamics between EOs and 
PSBs.  The  resulting  net  direct  benefits  are  calculated  for  the  first  year  (Y1)  by  considering  both 
one-off  and  recurring  costs,  and  for  the  second  year  (Y2)  by  only  keeping  recurring  costs.  An 
overview is presented in the table below. 

Table 11 – Annual net direct benefits: overview by ranges of usage 

Annual net direct benefits 
(€ bn) 

Adoption rate EOs 
(PSBs are 100%) 

Usage rate PSBs / EOs 
(same value for PSBs and EOs) 

Gross direct benefits 

Costs (one-off) – incurred in Y1 only 

Costs (recurring) 

Y1 net direct benefits 

Y2 net direct benefits 

1 

10.43% 

10.43% 

23.47 

9.66 

3.98 

9.83 

19.49 

2 

33% 

33% 

74.27 

17.21 

10.13 

46.93 

64.14 

3 

50% 

50% 

4 

75% 

75% 

112.53 

168.79 

22.89 

14.76 

74.88 

97.77 

31.25 

21.57 

115.97 

147.22 

This  results  in  net  direct  benefits  for  each  of  the  four  ranges  as  summarised  in  the  overview 
below107. The ranges refer to the EO usage rate, and the direct benefits reflect the actual savings by 
different categories of stakeholders corresponding to different levels of usage. For an explanation of 
the minimum and maximum bounds, please see section 6.2. 

Table 12 – Annual net direct benefits: split PSBs and EOs by ranges of usage 

Net benefits per 
adoption range 
(€ bn ) 

Range 1 –  
~ 10% 

Range 2 –  
33% 

Range 3 –  
50% 

Range 4 – 
75% 

PSBs 

EOs 

PSBs 

EOs 

PSBs 

EOs 

PSBs 

EOs 

Y1 net benefits 

Min 

-6.89 

1.37 

-5.96 

4.32 

-5.25 

6.54 

-4.22 

9.82 

Max 

-5.33 

15.15 

-1.01 

47.94 

2.24 

72.63 

7.02 

108.95 

106 See Business Wallet Study, NTT Data, October 2025, Section 7.1.1. 
107 Further details on the figures of net direct benefits for PSBs and EOs in function of EO adoption ranges are provided 
in Annex 4. 

43 

 
 
 
Y2 net benefits 

Min 

-0.71 

4.85 

0.22 

15.35 

0.92 

23.26 

1.96 

34.89 

Max 

0.85 

18.64 

5.17 

58.97 

8.42 

89.35 

13.20 

134.02 

The scale of these gains is  evident when comparing  the  total direct  benefits  in  year one  and year 
two across the ranges. The span of outcomes from the most conservative ~10% usage of range 1 to 
75%  usage  in  range  4  is  illustrated  in  the  graph  below,  which  shows  net  direct  benefits  –  both 
maximum and minimum – in relation to usage. 

Figure 3 – Evolution of minimum and maximum annual net direct benefits by usage rate in years 1 and 2 

Minimum  direct  benefits  are  slightly  negative  at  around  -€6  billion  in  the  most  conservative 
adoption scenario (range 1, year one), to become then positive at around €4 billion in year two of 
the  same  range  1.  Minimum  benefits  reach  their  highest  value  in  range  4.  In  this  case,  range  4 
delivers around €6 billion minimum benefits in year one and around €37 billion in year two. 

Maximum  direct  benefits  are  already  positive  at  around  €10  billion  in  the  most  conservative 
scenario (range 1, year one), to further increase at around €19 billion in year two of the same range 
1. Maximum benefits peak in range 4, reaching around €116 billion in year one and around €147 
billion in year two. 

This confirms that 75% adoption and usage by both PSBs and EOs enables the EUBW to realise its 
full potential in terms of efficiency gains. Range 4 is therefore the most effective and efficient way 
to  achieve  the  policy  objectives  while  maximising  overall  minimum  net  benefits  for  the  EU 
economy.  Existing  Union  initiatives  for  digital  transformation  and  capacity-building,  which  can 

44 

 
 
 
help  alleviate  training  and  adaptation  costs,  could  support  the  attainment  of  the  highest  levels  of 
adoption and usage of the EUBW, thus reinforcing the maximisation of the benefits. 

In the next chapter, direct benefits to other stakeholders (e.g. European Business Wallet Providers) 
will  be  presented,  as  well  assessing  the  indirect  benefits  resulting  from  the  introduction  of  the 
EUBW,  such  as  increased  market  competitiveness,  stronger  trust  in  digital  services,  and 
environmental gains (see Chapter 8). 

8.  ADDITIONAL AND INDIRECT BENEFITS 

Chapters  6  and  7  have  outlined  the  net  direct  benefits  that  the  European  Business  Wallets  are 
expected  to  bring  to  their  immediate  users,  PSBs  and  EOs.  These  maximum  direct  benefits  were 
calculated conservatively, focusing exclusively on cost savings from the reduction or elimination of 
manual  administrative  activities.  Beyond  these  effects,  the  EUBWs  are  expected  to  generate 
additional  benefits  for  both  PSBs  and  EOs,  which  go  beyond  the  scope  of  direct  cost  savings. 
Further  gains  are  also  anticipated  for  other  stakeholders,  notably  the  specialised  companies  that 
may become authorised providers  of the European Business Wallet. These additional benefits are 
discussed in the first part of this chapter. Finally, the widespread adoption of the European Business 
Wallet is expected to deliver broader systemic impacts at EU level. These indirect benefits, which 
include  economic,  social,  and  environmental  dimensions,  are  described  in  the  second  part  of  this 
chapter. 

8.1.  Additional benefits 

8.1.1.  Benefits for European Business Wallet users: PSBs and EOs 

The  adoption  of  the  European  Business  Wallets  will  generate  benefits  for  its  users  that  are  not 
limited to cost-savings resulting from the reduction or elimination of existing processes. These were 
not  however  included  in  the  cost-benefit  analysis.  These  additional  gains  relate  to  areas  such  as: 
improvements  in  IT  integration  and  system  consolidation,  cybersecurity  and  digital  sovereignty, 
operational efficiency, and improved interactions for regulatory purposes. 

For  both  PSBs  and  EOs,  the  EUBWs  can  enable  the  replacement  or  integration  of  multiple, 
fragmented  identity  verification  and  authentication  systems  into  fewer,  or  even  single,  unified 
solution.  Such  consolidation  of  IT  systems  creates  opportunities  to  leverage  synergies  in  the  IT 
architecture to increase economies of scale, ensure greater consistency between them and to unlock 
opportunities  associated  with  increased  operational  performance.  For  PSBs  in  particular,  this  can 
translate into simplification and costs reduction in the maintenance and operation of IT systems. At 
the  same  time,  for  EOs,  the  same  consolidation  can  enable  efficiency  gains  in  data  management: 
businesses will be able to store their identity attributes locally or in secure, decentralised manners 
rather  than  centralised  cloud  databases.  This  can  result  in  lower  storage  costs  and  reduced  data 
management  overhead,  and  only  necessary  attributes  need  to  be  shared  for  each  transaction  thus 
reducing the amount of redundant data to be stored in corporate systems. 

The EUBWs can also enhance the cyber resilience of both EOs and PSBs by providing them with a 
framework  for  trusted  interactions  that  considers  the  core  pillars  of  cybersecurity  by  design.  The 
EUBW guarantees confidentiality, integrity and authenticity of documents, attributes and messages 
and  ensures  availability  of  trust  services,  hardening  essential  and  shared  digital  infrastructure 
against  varied  cyberattacks.  Moreover,  for  PSBs  in  particular,  the  harmonisation  of  technical 
requirements for EUBW solutions via standards and specifications is in line with the objectives of 
increasing  digital  sovereignty,  as  it  enables  continuous  monitoring,  common  risk  assessment  and 
coordinated  updates  of  criteria  across  the  Union,  in  the  face  of  an  evolving  threat  landscape. 

45 

 
Conformity  assessment of EUBW solutions  ensures adequate implementation of security controls 
to certify a high common level of cybersecurity for all provided solutions, which is inherited by all 
applications built on top of EUBW. All these safeguards and actions counterbalance the increased 
cyberattack surface derived from digitising manual/paper-based activities.  

In  addition  to  the  IT  and  security  benefits,  the  European  Business  Wallets  are  expected  to  lower 
operational  costs  for both EOs  and  PSBs.  For example,  EOs can leverage the European Business 
Wallets to reduce operational costs related to customer/supplier reach, acquisition and onboarding, 
customer/supplier management (including master data management and contract management) and 
customer/supplier retention and support. These benefits for EOs include for instance the automation 
and optimisation of internal business processes as well as the transformation of customer/supplier 
touchpoints and interactions. In this regard, some stakeholders have carried out research limited to 
specific  geographical  markets  and/or  use  cases,  or  empirical  research  regarding  sectors.  For 
example,  a  study  on  organisational  digital  identities  in  Germany  shows  that  the  optimisation  of 
suppliers dataset management could unlock potential savings of up to €85 billion for companies in 
B2B contexts108. In a separate example concerning financial services, banks could use the Wallets 
(e.g.  leveraging  identification  and  signature  functionalities  of  the  Wallets)  to  facilitate  KYC 
processes in terms of document validity and collection, screening and final approvals, thus reducing 
costs.  The  potential  is  significantly  high,  considering  that  today  banks  experience  KYC  costs  for 
each corporate customer of about €275 and face lengthy duties that take banks’ employees between 
18.5h and 62h to complete each KYC process109.  

For PSBs, the European Business Wallets are expected to generate significant efficiency gains by 
simplifying  and  automating  internal  procedures.  Routine  and  manual  tasks  such  as  document 
handling and data entry can be increasingly digitalised, reducing reliance on manual processes and 
thereby  lowering  the  risk  of  human  error110.  This  will  enhance  the  accuracy  and  reliability  of 
information  exchanges,  while  accelerating  decision-making  and  service  delivery,  bringing 
efficiency gains resulting from reduced back-office processing times. 

The  European  Business  Wallets  can  also  improve  regulatory  interactions  between  PSBs  and 
economic operators. Many PSBs at EU, national and regional levels act  as competent authorities, 
supervisors  or  regulators,  and  therefore  maintain  regular  exchanges  with  supervised/regulated 
entities.  For  these  authorities,  secure,  efficient  and  legally  certain  communication  channels  are 
essential to ensure timely information exchange, compliance monitoring and enforcement.  Insofar 
as it provides a harmonised digital framework for the transmission of verified data and documents, 
the EUBWs can strengthen the quality and reliability of supervision while reducing administrative 
friction on both sides. This will enable PSBs to better fulfil their regulatory mandates and to make 
more  effective  use  of  RegTech  solutions,  further  increasing  transparency  and  accountability  in 
oversight activities. From the perspective of EOs, the EUBWs can facilitate faster, more proactive 
and constructive engagement with authorities, as it makes it easier to establish or maintain contact 
with regulators and to clarify obligations at an early stage. This can also encourage participation in 
regulatory  sandboxes  and  similar  controlled  environments,  where  new  technology  can  be  tested 

108  See  Organisational  digital  identities:  Cost  saving  estimation  for  the  Use  Case  „Know  your  Supplier”  based  on 
automated  master  data  management  with  EUDI  wallets  for  legal  entities¸  European  School  of  Management  and 
Technology 
at: 
https://cdn.table.media/assets/europe/20241216_bmwk_kys_savings_final_v2.pdf. 
109 Perpetual KYC: A new approach to periodic reviews, PwC. 
110 See European Business Wallet Study, NTT Data, October 2025, Sections 2.3.3 and 3.2.3.  

December 

Available 

(ESMT), 

Berlin. 

GmbH 

2024, 

46 

 
 
under dedicated supervision, and accelerate the exploration, compliant deployment, and consequent 
uptake of innovative products and services.  

Finally,  direct  and  indirect  benefits  identified  for  PSBs  include  European  Union  institutions, 
agencies,  offices  and  bodies  (EUIBAs)  which  are  expected  to  be  EUBW  users.  As  large 
administrative entities  handling significant  volumes of exchanges with  EOs, EUBIAs can use the 
EUBW  to  improve  efficiency,  data  accuracy,  security,  auditability,  and  responsiveness  in  their 
operations. 

EUIBAs  act  as  regulatory  or  supervisory  authorities  across  multiple  policy  areas.  In  these  roles, 
they  would  particularly  benefit  from  the  simplification  and  cost  reductions  resulting  from  the 
consolidation  and  modernisation  of  IT  systems.  The  EUBW  could  facilitate  secure  and  traceable 
exchanges  of  official  documents  and  data.  The  availability  of  a  legally  recognised,  standardised 
communication  channel  will  help  reduce  fragmentation  between  IT  systems  currently  used  and 
strengthen the overall quality of supervision and coordination with national competent authorities. 
enabling greater efficiency in document management and administrative processes. 

8.1.2.  Benefits for future European Business Wallet providers 

The market for digital identity and trust services in the EU is already expanding rapidly,  and this 
growth will accelerate even more when the EU Digital Identity Wallets under the European Digital 
Identity Framework will be available across Member States by end of 2026. Over the coming years, 
a  significant  increase  in  demand  is  expected  for  functionalities  such  as  identification  and 
authentication,  issuance,  storage  and  exchange  of  electronic  attestations  of  attributes,  and  trust 
services.  

The  total  market  value  of  these  functionalities  that  relates  directly  to  businesses,  and  is  therefore 
relevant  for  the  European  Business  Wallets,  is  estimated  at  €1.0  –  €1.7  billion  in  2024  with  an 
expected  rise  to  €4.8  –  €10.3  billion  by  2030111.  This  trend  creates  a  favourable  environment  for 
wallet providers, as the user base of digital wallets expands steadily. 

Beyond  the  impact  that  the  EUBW  has  on  potentially  growing  direct  revenues,  it  also  creates 
indirect opportunities for innovation. Providers will be able to design commercial offers that bundle 
the  minimum  core  functionalities  with  value-added  services  tailored  to  sector-specific  or  entity-
specific needs. This flexibility will enable the emergence of new business models. In this way, the 
EUBW Regulation will not only consolidate existing markets but also establish the conditions for 
providers  to  capture  the  full  growth  potential  of  digital  trust  services  and  other  functionalities 
enabled by the future European Business Wallets. 

8.2. 

Indirect benefits  

Indirect benefits are positive outcomes that arise not directly from the introduction of the European 
that  enhance  economic,  societal  and 
Business  Wallets,  but  represent  secondary  effects 
environmental conditions more broadly. They can be assessed by considering the EU market as a 
whole, going beyond the selected administrative activities considered for the direct benefits and the 
additional benefits discussed in the first part of this chapter.  

111 Estimates based on internal research, using publicly available sources and expert input.  

47 

 
 
Indirect  benefits  are  not  attributed  according  to  specific  categories  of  economic  operators  and 
public sector bodies, or even other groups of specific stakeholders, but are considered collectively. 
Indirect  benefits  have  been  assessed  in  relation  to  75%  usage  of  the  EUBW  by  stakeholders 
corresponding  to  range  4.  Indirect  benefits  are  often  challenging  to  quantify,  as  they  are  less 
tangible  and  longer-term  than  direct  benefits.  Therefore,  where  it  was  possible  to  make  an 
estimation,  taking  into  account  these  challenges,  the  calculations  were  based  on  conservative 
assumptions and the lower bound estimates from the European Business Wallets supporting study. 
Where  no  quantified  estimate  was  provided,  this  was  either  due  to  the  absence  of  granular  data 
points  or  baseline  data,  or  because  the  scope  was  too  broad  o  be  translated  into  measurable, 
quantitative metrics. 

The  indirect  benefits  of  the  European  Business  Wallets  have  been  assessed  according  to  the 
following three categories: 

Table 13 – Categories of indirect benefits 

Categories 

Sub-categories 

I. 

Economic opportunities 
and market competitiveness 

II. 

Trust and resilience 

III. 

Environmental 
sustainability 

a. 

b. 
c. 

a. 
b. 

a. 
b. 

Reallocation  of  resources  and  cross-border  service 
expansion 
Fraud reduction 
Data transparency 

Trust in digital transactions and services 
Crisis resilience and continuity 

Reducing emissions 
Facilitate sustainability compliance and reporting 

8.2.1.  Economic opportunities and market competitiveness 

In the category of economic opportunities and market competitiveness, three sub-categories of 
indirect  benefits  have  been  identified.  Firstly,  the  EUBW,  PSB  and  EO  users  can  reallocate 
resources freed up from repetitive administrative activities through the EUBW towards added-value 
activities service improvement, (product) innovation, and the expansion of the scope or quality of 
their operations. For PSBs, wide usage of the EUBW could contribute to a significant increase in 
the level of available public services online, estimated at 42% for cross-border and 8% for national 
services112. The expected time gains due to increased administrative efficiencies and the subsequent 
reallocation  of  resources  are  not  limited  to  the  availability  of  public  services  but  extend  to  the 
overall  quality  of  public  service  delivery,  for  instance  in  terms  of  accuracy  and  timeliness  of 
response, not only vis à vis businesses but also citizens. For EOs, these developments are expected 
to  result in  increased business opportunities.  The reduced time  and effort  spent  on administrative 

112 This figure is based on the current  share of public services that are fully online: 58% of cross-border and 92% of 
national  public  services.  See European  Business  Wallet  Study,  NTT  Data,  October 2025,  Annex 4.  See  in  particular 
European  Commission.  (2025).  E-government  Benchmark  2025.  Available  at:  https://op.europa.eu/en/publication-
detail/-/publication/5f3a75d9-4739-11f0-85ba-01aa75ed71a1/language-en 

48 

 
 
 
activities is expected to enable EOs to reallocate savings to improve products and services and to 
promote innovation in the EU market113.  

In addition, the EUBW drives service expansion and cross-border adoption of digital services more 
broadly  within digital economic sectors. By facilitating access  to  digital infrastructure and digital 
services,  and  by  supporting  the  standardisation  of  digital  processes  across  Member  States,  the 
EUBW  can  help  boosting  the  completion  of  the  EU  digital  Single  Market114.  According  to  the 
European Parliamentary Research Service115, “completing the digital single market could generate 
benefits  of  around  110  billion  euro  annually.  The  European  Business  Wallet  could  significantly 
contribute to this objective across several areas such as e-commerce, e-procurement, e-payments, e-
invoicing, e-government, cloud computing.  However, the exact contribution of the EUBW to this 
benefit cannot be isolated, given the numerous initiatives and exogenous effects coming into play. 
Even though the contribution the EUBW would bring to this benefit is difficult to estimate, even a 
conservative estimate would suggest a significant positive contribution. Furthermore, the European 
Business  Wallets  are  expected  to  positively  influence  digital  government  key  enablers  (which 
includes  eID,  eDocuments,  digital  post,  eSafe,  and  single  sign-on),  for  which  empirical  research 
shows  a  positive  correlation  with  entrepreneurship116.  Simplified  procedures  for  proving  legal 
status, ownership, and compliance attributes, including across borders within the EU, will make it 
easier and quicker for entrepreneurs to set up new companies. Widespread EUBW adoption could 
contribute  to  increase  entrepreneurship  density  (number  of  active  businesses  per  capita)  by 
2,09%117, corresponding to an estimated creation of around 680,000 new firms annually. These new 
companies  would  benefit  from  faster  entry  into  the  market  EU-wide,  as  their  digital  credentials 
would  be  valid  and  reusable  across  the  Union.  The  indirect  benefits  of  this  increased  business 
formation  can  be  quantified  in  terms  of  avoided  entry  and  compliance  costs.  Assuming  that  the 
compliance costs of starting a business in the EU are around €1,857 per economic operator118 and 
considering the  conservative  approach used for  minimum  direct  benefits  calculation  for EOs (see 
section 6.2 with the 36% multiplier for  administrative cost savings that  can be achieved by using 
the EUBW), this would result in indirect benefits related to avoided entry and compliance costs of 
up to €0.45 billion.  

- 

the 

(110 

digital 

billion 

market 

Completing 

113 See European Business Wallet Study, NTT Data, October 2025, Annex 4. 
114 Mentioned in in-depth interviews with Public Administrations and in a Call for Evidence (DigitalTrade4.eu) 
115 
euro) 
single 
https://www.europarl.europa.eu/RegData/etudes/STUD/2019/631745/EPRS_STU(2019)631745_EN.pdf 
116  Relationship  supported  by  the  paper  “Is  e-government  a  driver  to  enhance  entrepreneurship?  An  empirical 
investigation  of  European  countries”,  Entrepreneurship  Research  Journal,  August  2022.  See  See  Business  Wallet 
support study, table indirect benefits. 
117 This figure represents how much the increase of entrepreneurship density can be influenced by the  adoption of the 
EBW. It is derived from the percentage increase, 12.38% (from 71.1% to 79.9%), in the average score for business life 
events in the e-Government Benchmark for business life events. This measures whether services are available online, 
easy to use, transparent, accessible across borders, and supported by key digital tools like eIDs and online payments. 
This percentage is multiplied by 0.68, which is the average of two statistically  significant coefficients obtained from 
different econometric models measuring the impact of digital public service key enablers on entrepreneurship density, 
and then corrected by a 25% adjustment factor to take account of the fact that in the eGovernment Benchmark, 5 of 20 
Business Life Events relate to starting a business. This translates a 2.09% growth rate which, when multiplied by the 
total number of enterprises (32,721,957) in the EU, results in approximately 680,000 new businesses. 
118  Word  Bank  data  suggests  that  an  entrepreneur  in  a  high-income  economy  typically  spends  4.2%  of  the  country’s 
per-capita income to launch a business. See Doing Business 2020. Comparing Business Regulation in 190 Economies, 
World  Bank  Group,  2020.  https://documents1.worldbank.org/curated/en/688761571934946384/pdf/Doing-Business-
2020-Comparing-Business-Regulation-in-190-Economies.pdf  Assuming  an  average  nominal  GDP  per  capita  for  the 
European Union to be €44,220, this would mean a cost of €1,857 per business. 

49 

 
 
Secondly,  the  European  Business  Wallets  will  secure,  digitise  and  standardise  B2B  and  B2G 
interactions and information exchanges across Member States, streamlining processes.. Better data 
transparency  improves  accuracy  of  information  ,  which  in  turn  facilitates  the  streamlining  of 
processes  and  policy  enforcement  while  allowing  for  better  fraud  reduction.  It  is  estimated  the 
European Business Wallets could generate savings derived by fraud reduction by €4.96 billion119. 
This would also lead to an increase in citizens’ trust in public sector bodies. Moreover, standardised 
data also creates the conditions for AI-driven automation120, by providing more consistent datasets 
for training and deployment. The specific contribution of AI-driven automation to indirect benefits 
was not quantified, because it is assumed to be captured across other sub-categories. 

Finally,  by  improving  access,  transparency  and  quality  of  company  data,  the  European  Business 
Wallets  are  expected  to  centralise  company  information  and  facilitate  automation  of  different 
business  activities.  For  example,  this  can  have  an  indirect  impact  on  the  business  information 
market, with expected increased revenues for specialised data providers’ companies as compared to 
a  scenario  where  the  European  Business  Wallets  were  not  introduced.  The  resulting  indirect 
benefits  calculated  as  the  corrected  growth  –  due  to  the  arrival  in  the  market  of  the  European 
Business Wallets – of the company information market value is estimated at €1.35 billion. 

8.2.2.  Trust and resilience 

Central to the proposal for European Business Wallets is a strategic extension of trust. With regard 
to the category of trust and resilience, two sub-categories of indirect benefits have been identified. 
As far as trust in digital transactions and services is concerned, the European Business Wallet will 
facilitate  the  harmonisation  of  digital  structures  and  mandate  management,  increasing  trust  in 
public administrations and businesses, as well as confidence in digital transactions and services. For 
example,  the  EUBWs  can  streamline  public  procurement  by  automating  the  submission  of 
administrative documents and enabling digital participation in eProcurement and tendering. It can 
also contribute to the Public Procurement Data Space, supporting greater transparency, efficiency, 
innovation,  and  evidence-based  policymaking121.  Based  on  the  “The  digital  trust  index”  global 
report122 and adjusting the analysis to consider EU- and Euro-using countries only, an increase of 
1% in a country’s prevalence of digital trust drives a €509 increase in GDP per capita while a 5% 
increase in a country’s prevalence of digital trust drives a €2,547 increase in GDP per capita. Based 
on  the  1%  estimated  increase  that  can  be  conservatively  applied  by  considering  the  European 
positive trend in digital trust growth and the significant contribution of the EUBW in digital trust, 
this translates to an impact of €16.66 billion123. 

The  EUBW  can  play  a  pivotal  role  in  resilience,  crisis  management,  and  business  continuity  by 
enabling interoperable, cloud-based systems that enhance data governance, optimise the allocation 
of scarce resources, and accelerate responsiveness to urgent needs. In particular, the EUBW could 

119 The estimated savings are aligned with the 2021 Impact Assessment by including all industries rather than limiting 
to the four sectors considered in 2021. To calculate the savings potential, the baseline of €24.8 billion has been used, 
representing the 2024 estimated fraud damage to the EU budget as shown in the latest Annual Report of the European 
Public  Prosecutor’s  Office  (EPPO).  https://www.eppo.europa.eu/en/media/news/2024-annual-report-eppo-leading-
charge-against-eu-fraud 
120  See  Moreira,  S.,  Mamede,  H.S.,  &  Santos,  A.  (2024).  Business  Process  Automation  in  SMEs:  A  Systematic 
Literature Review. IEEE Access, 12, 75832-75864. https://ieeexplore.ieee.org/ielx7/6287639/6514899/10540093.pdf 
121 See Business Wallet Study, NTT Data, October 2025, Section 3.2.3. 
122https://programs.callsign.com/hubfs/digital-trust-
index/Callsign%20%E2%80%93%20The%20digital%20trust%20index.pdf 
123 See Business Wallet Study, NTT Data, October 2025, Annex 4 

50 

 
 
facilitate  the  secure  and  rapid  identification  and  onboarding  of  critical  suppliers  and  partners  — 
leveraging  Wallet  functionalities  such  as  Know  Your  Supplier  (KYS)  and  Procurement  —  to 
restore order  and  continuity during disruptive events.  Moreover,  advanced features  like delegated 
authority  (power  of  attorney),  cross-border  data  interoperability,  and  data  access  management 
empower  organisations  and  institutions  to  make  faster,  more  informed  decisions  and  execute 
operations  with  precision.  Nevertheless,  the  sub-category  crisis  resilience  and  continuity  was  not 
quantified to estimate the minimum indirect benefits. 

8.2.3.  Environmental sustainability 

In  the  category  of  environmental  sustainability,  two  sub-categories  have  been  identified.  First, 
regarding  emissions  reduction,  as  indicated  in  the  support  study124,  the  digitalisation  of 
administrative processes can reduce the use of paper, thereby lowering emissions  associated with 
both  paper  production  and  waste  management.  Moreover,  digitalisation  in  general  and  the 
application of specific use cases driven by the European Business Wallet (e.g. Power of Attorney) 
can help reducing the need of travel for PSBs and EOs representatives, thus reducing transportation 
emissions. However, this sub-category was not quantified for the purposes of estimating minimum 
indirect benefits. 

Second,  the  EUBW  could  play  a  role  in  facilitating  sustainability  compliance  and  reporting.  By 
digitalising exchanges with public sector bodies and facilitating access to environmental data, the 
EUBW  could  simplify  sustainability  reporting,  increase  product  traceability,  and  support  the 
adoption  of  sustainability  measures.  These  developments  would  also  strengthen  access  to  green 
finance, encourage the issuance of instruments such as green bonds, and promote broader uptake of 
Environmental, Social, and Governance (ESG) standards. Despite this potential, it was decided to 
leave this sub-category not quantified. 

Overall,  the  minimum  quantifiable  indirect  benefits  for  society  and  the  wider  economy  are 
estimated at €26.81 billion. An overview of the contribution of each item is provided in the table 
below. 

Table 14 – Overview of minimum quantifiable indirect benefits 

Description 

MINIMUM indirect benefits (€) 

I. Economic 
opportunities and 
market competitiveness 

SUB-TOTAL  

II. Trust and resilience 

SUB-TOTAL 

a)  Reallocation of resources and cross-border 

service expansion 

b)  Fraud reduction 

c)  Data quality 

a)  Trust in digital transactions and services 

b)  Crisis resilience and continuity 

III. Environmental 

a)  Reducing emissions 

124 See Business Wallet Study, NTT Data, October 2025, Annex 4. 

51 

€0.45 bn 

€4.96 bn 

€1.35 bn 

€6.76 bn 

€16.66 bn 

Not quantified 

€16.66 bn 

Not quantified 

 
 
Description 

sustainability 

TOTAL 

b)  Facilitate sustainability compliance and 

reporting 

MINIMUM indirect benefits (€) 

Not quantified 

€23.42 bn 

8.3.  Considerations on proportionality and costs 

The European Business Wallets initiative is proportionate to the objectives sought, as it limits PSBs 
obligations  to  a  set  of  core  functionalities  needed  to  guarantee  trust  and  interoperability  in 
interactions between EOs and PSBs: identification and authentication, electronic signing or sealing, 
submission  of  documents,  and  sending/receiving  notifications.  The  wide  acceptance  of  such  core 
functionalities, confirmed in stakeholder consultations as carrying a high level of support (see for 
example  section  5.2),  is  considered  essential  to  ensure  high  usage  which  can  unlock  direct  and 
indirect  benefits.  In  this  regard,  as  outlined  in  Chapter  3,  EU  action  is  then  limited  to  what  is 
necessary to achieve the objectives of reducing administrative burdens and eliminating disturbances 
in the Single Market that can undermine its proper functioning.  

As an additional safeguard, obligations are further balanced by transitional arrangements: flexible 
implementation periods allow public sector bodies sufficient time to adapt their administrative and 
IT systems and preventing disruption  

Beyond the requirement that PSBs accept the EUBW’s core functionalities in their interaction with 
EOs,  the  proposal  does  not  create  new  compliance  requirements  for  EOs  or  PSBs.  It  instead 
provides  a  harmonised  and  trusted  channel  to  meet  obligations  that  already  exist  under  Union  or 
national law. Further, the initiative encourages a market-driven approach, fostering competition and 
innovation, where providers retain flexibility to design cutting-edge solutions adapted to different 
sectors and user needs.  

The impact is also expected to remain proportionate. The costs incurred by PSBs are investments to 
catalyse wide adoption and usage of the instrument by providing EOs with the necessary certainty. 
This  is  a precondition  to allow, in  turn, PSBs to  reap the full potential  benefits  from  streamlined 
compliance,  reduced  duplication,  and  increased  legal  certainty,  thus  creating  a  virtuous  circle  for 
medium- and long-term efficiency gains. 

Notably,  the  proposal  does  not  impose  any  obligation  on  economic  operators.  It  requires  public 
sector bodies to enable their use for specified functionalities ensuring that economic operators like 
small  and  medium  enterprises  have  the  choice  to  adopt  the  Business  Wallets  and  to  benefit  from 
simplified  procedures.  This  approach  aligns  with  the  “Think  Small  First”  principle  by  avoiding 
unnecessary regulatory pressure on SMEs. Self-employed individuals and sole traders may also rely 
on  their  EU  Digital  Identity  Wallets  to  access  trust  services  offered  for  the  European  Business 
Wallets, including the secure communication channel or e-signatures, without the need to acquire a 
fully-fledged  Business  Wallet.  This  ensures  proportionate  treatment  of  smaller  operators  by 
preventing the imposition of an undue burden.  

SMEs, and in particular micro-enterprises, which currently face disproportionate compliance costs, 
will be the principal beneficiaries of the simplification, achieving significant savings in staff time 
and  economic  resources.  This  category  of  EOs  bear  the  highest  relative  burden  of  today’s 
fragmented  compliance  landscape,  as  they  lack  dedicated  resources  for  legal,  IT  or  compliance 
functions. By targeting simplification for the operators most affected by barriers to establishment, 

52 

 
 
cross-border  service  provision  and  uneven  competition  conditions,  the  initiative  ensures  that  EU 
intervention is proportionate to the problem it seeks to address. 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

This chapter describes how the impact of the proposed legislation will be monitored and evaluated 
in  light  of  its  stated  objectives,  the  indicators  that  will  be  used  and  the  data  collection  needed  to 
support  the  evaluation,  to  take  place  four  years  after  the  entry  into  force  of  the  Regulation.  As 
stated  in  Chapter  4,  the  general  objective  of  the  European  Business  Wallets  is  to  “promote  the 
proper functioning of the internal market by addressing the need to reduce administrative burdens 
for  businesses  and  public  administrations  by  means  of  digital  identification,  authentication  and 
legally valid data exchange, thereby enhancing competitiveness and digitalisation across the EU.” 

The Commission will monitor the implementation of the legislation with a view to generating the 
necessary  and  relevant  information  that  will  feed  into  a  future  evaluation  and  to  provide  solid 
evidence for policymaking. To ensure consistency and proportionality, the monitoring framework 
draws  on  the  three-pillar  structure  referenced  in  the  impact  assessment  for  the  revision  of  the 
eIDAS  Regulation,  implementation,  application,  and  contextual  indicators,  and  adapts  it  to  the 
specific  scope  of  the  European  Business  Wallets.  This  ensures  alignment  while  avoiding 
duplication  of  monitoring  obligations  and  respecting  Better  Regulation  principles,  including 
proportionality and re-use of existing data streams. 

Additionally,  a  set  of  additional  indicators,  specifically  linked  to  the  Specific  Objectives  will  be 
leveraged  to  assess  the  outcomes  of  the  initiative  via  proxy-indicators.  These  broader  macro-
economic  and  administrative-burden  trends  remain  contextual  and  will  be  interpreted  alongside 
eIDAS data to support statistical inference rather than implying direct causality. In particular, the 
Commission  shall  consider  in  what  ways  it  can  make  the  maximum  use  of  existing  monitoring 
frameworks to minimise any additional reporting burdens on Member States and, where necessary, 
economic  operators.  For  example,  the  proposal  will  require  certain  information  to  be  reported  by 
the relevant national competent authorities. Additionally, the Digital Decade Policy Programme has 
a mature and highly relevant process that has been developed to collect, process, store, analyse and 
disseminate data. Any additional data collection processes should be kept simple and streamlined. 

The table below presents the additional and non-exhaustive indicators that could be used to monitor 
the implementation of the legislation. 

Table 15 – Possible indicators for monitoring legislation implementation 

Monitoring and 
evaluation aspect and 
relevant objectives 

Indicator(s) 

Responsibility for 
collection 

Source(s) 

SO1: Reduce administrative burdens, streamline compliance processes, and improve service delivery 

To reduce the 
administrative burden 
of regulatory 

Quantifiable reduction in the burden 
of government regulation indicator 

(This is a contextual indicator to 

European Commission 

Single Market and 
Competitiveness 
Scoreboard125 

125  Plus  any  potential  KPI  on  administrative  burden  reduction  following  the  review  of  the  Digital  Decade  Policy 
Programme 

53 

 
 
 
Monitoring and 
evaluation aspect and 
relevant objectives 

compliance and 
reporting requirements 
on businesses through 
demonstrable 
economic benefits 

To improve public 
service delivery 

To enhance European 
competitiveness 

Indicator(s) 

Responsibility for 
collection 

Source(s) 

show whether the administrative 
burden is moving in the expected 
direction in parallel with EUBW 
deployment) 

Measured improvements in Digital 
Public Services for Business 
indicators under the eGov 
benchmark, particularly in respect of 
online service delivery and 
interoperability signifiers (specific 
indicators: (cross-border) online 
availability; (cross-border) eID; pre-
filled forms; OOTS) 

Measurable improvements in the 
exports of goods to other EU 
countries by SMEs in the industrial 
sector (% of SMEs) 

(This is a contextual indicator to 
show whether the administrative 
burden is moving in the expected 
direction in parallel with EUBW 
deployment) 

European Commission 

eGovernment benchmark 
study feeding the Digital 
Decade Policy 
Programme 

European Commission 

Single Market and 
Competitiveness 
Scoreboard 

SO2: To ensure economic operators and public sector bodies have access to secure and trusted digital 
identification across borders, meeting user needs and market demand 

To develop a market 
for secure digital 
identification and trust 
services between 
economic operators 
and public sector 
bodies 

Number of compliant and notified 
European Business Wallet 
providers, including Qualified Trust 
Service Providers 

National Competent 
Authorities 

Data reported to 
European Commission 

European Digital 
Directory 

National Competent 
Authorities 

Data reported to 
European Commission 

To ensure that 
available solutions are 
trusted and secure and 
comply with all 
requirements to 
provide European 
Business Wallets 

Number of withdrawn authorisations 
of notified European Business 
Wallet providers, excluding any 
providers who have voluntarily 
ceased their commercial provision 
of business wallets and related 
services 

Number and level of penalties 
imposed on European Business 
Wallet providers 

To stimulate adoption 
of the European 
Business Wallet across 

Number of European Business 
Wallets issued to economic 
operators and public sector bodies 

European Commission 

European Digital 
Directory 

54 

 
 
Monitoring and 
evaluation aspect and 
relevant objectives 

Indicator(s) 

Responsibility for 
collection 

Source(s) 

all sectors of the 
economy 

and registered in the European 
Digital Directory126 

Additional  in-depth  research  and  studies  may  be  necessary  to  determine  a  clear  baseline  for 
assessing improvements as a result of the introduction of the European Business Wallets. 

126  The  number  of  wallets  is  not  necessarily  equivalent  to  number  of  owners  because  one  owner  attributed  with  one 
unique identifier  may have multiple wallets registered to them, but  it will be a  good approximation to  determine the 
levels of usage 

55 

 
 
 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

1.  LEAD DG, DECIDE PLANNING/CWP REFERENCES 

The lead DG is the Directorate-General for Communications Networks, Content and Technology. 
The Commission Work Programme for 2025 provides, under the heading “A new plan for Europe’s 
sustainable  prosperity  and  competitiveness”,  the  policy  objective  of  a  European  Business  Wallet 
(legislative, incl. impact assessment, Article 114 TFEU, Q4 2025) 

2.  EVIDENCE, SOURCES AND QUALITY 

The  Commission  has  collected  feedback  from  stakeholders  both  in  the  context  of  the  formal 
meetings  with  the  Member  States  working  groups  (e.g.  European  Digital  Identity  Cooperation 
Group  meetings)  and  in  targeted  bilateral  meetings  held  with  various  private  and  public 
stakeholders (for details, please see ANNEX 2). 

In addition to above actions, the Commission also collected evidence via a Call for Evidence, desk 
research, expert interviews, and workshops with representatives of national authorities of Member 
States (European Digital Identity Cooperation Group meetings) and industry representatives. 

The Staff Working Document relied on available research in the field of eID and trust services as 
well as on statistics, mainly from Eurostat. 

The Staff Working Document  was  also  supported by a study to  support  the  analysis  for the  Cost 
and Benefit Analysis implemented by a consortium led by NTT Data. 

56 

 
 
ANNEX 2: STAKEHOLDER CONSULTATION 

1.  STAKEHOLDER CONSULTATION STRATEGY 

As  an  initiative  designed  to  facilitate  business-to-government  (B2G)  and  business-to-business 
(B2B), interactions, the European Business Wallets will differ from the EU Digital Identity Wallets 
in  that  it  is  tailored  to  the  needs  of  entities  acting  in  a  professional,  administrative  or  other  non-
private capacity, as opposed to citizens and residents acting in their private capacity . Nevertheless, 
it  will  build  on  the  EU  Digital  Identity  Framework  to  simplify  legal  entity  identification  and 
authorisation,  regulatory  compliance,  enable  secure  data  exchange  and  cross-border  transactions 
using  dedicated  communication  channels  which  operate  under  specific  established  industry 
standards. 

In  that  vein,  consultation  feedback  was  sought  on  specific  issues  relevant  to  economic  operators 
and  public  sector  bodies,  such  as  operational  requirements,  technical  integrations  (for  example, 
secure  data  exchange  protocols  and  interoperability  with  existing  business  systems),  workflow 
optimisations that directly impact professional use, and the integration of reporting obligations and 
notification  mechanisms  as  required  by  Union  or  Member  State  law.  The  topics  relevant  for 
consultation are specific to the stakeholder community and of a technical nature.  

The  public  consultation  conducted  in  preparation  for  the  amendment  of  the  eIDAS  Regulation  in 
2021 remains a valid foundation for understanding user expectations regarding digital identity and 
trust  services.  The  2021  public  consultation  gathered  a  wide  range  of  stakeholder  views  across 
Member  States,  highlighting  the  need  for  greater  cross-border  usability,  legal  certainty,  and 
interoperable  digital  identities.  To  complement  these  insights,  targeted  consultations  were  carried 
out  for  this  proposal  to  capture  the  specific  needs,  use  cases,  and  technical  requirements  of 
economic operators, public administrations and other non-private bodies. The combined approach 
of  relying  on  the  2021  public  consultation  and  the  consultation  strategy  underpinning  this  Staff 
Working Document ensures that the European Business Wallets are informed by both the general 
principles  established  through  the  2021  public  consultation  and  the  practical  realities  faced  by 
professional users today. 

The  consultation  strategy  supporting  this  proposal  for  a  Regulation  on  the  European  Business 
Wallets  included  a  Call  for  Evidence,  a  questionnaire  gathering  views  and  data  from  relevant 
stakeholders  to  gain  insights  into  the  costs  that  Economic  Operators  and  Public  Administrations 
currently incur, interviews, and numerous stakeholders' dialogues. The Commission also organised 
several  workshops  and  roundtable  discussions  with  stakeholders,  as  well  as  participating  in  a 
number  of  conferences  on  the  issues  covered  by  this  Staff  Working  Document.  In  addition,  DG 
CONNECT held a series of ad-hoc meetings with stakeholders to discuss specific issues and gather 
detailed  input  on  various  policy  options.  The  staff  Working  Document  largely  builds  on  the 
outcome  of  these  consultations  with  stakeholders,  as  well  a  study  carried  out  to  support  the 
evidence collection, assumptions and cost-benefit analyses in this Staff Working Document, which 
included a survey and structured interviews.  

As  the  proposal  follows  the  general  policy  lines  of  the  already  established  EU  Digital  Identity 
Framework  for  natural  persons,  and  the  studies  and  consultations  carried  out  under  the  eIDAS 
revision, the stakeholder consultations were targeted and technical. 

Meetings with stakeholders also sought to collect their experiences and real-world examples to help 
tailor  the  initiative  to  meet  the  specific  needs  of  users.  These  could  include  challenges  faced  in 

57 

 
regulatory compliance such as duplicative submissions of official documents, lack of interoperable 
formats, and fragmented access points, inefficiencies in cross-border operations due to inconsistent 
digital procedures and limited recognition of digital credentials, as well as testimonies from SMEs 
on the barriers posed by administrative complexity, including burdensome compliance, redundant 
reporting,  and  limited  access  to  digital  channels.  Stakeholders’  opinions  were  sought  to  collect 
qualitative insights on the perceived benefits and potential concerns regarding the implementation 
of the Business Wallet to help assess industry readiness and expectations. 

Stakeholders  were  selected  to  ensure  a  balanced  representation  of  relevant  interests,  as  well  as 
diversity in size, sector, and geographic coverage within the EU. Particular attention was given to 
the inclusion of SMEs, given their challenges in adopting digital tools. 

1.1.  Call for Evidence 

The  Commission  launched  a  Call  for  Evidence  to  collect  input  and  feedback  on  the  upcoming 
proposal for a Regulation on the European Business Wallets127. This targeted consultation, aimed at 
economic  operators,  professional  associations  and  registers,  as  well  as  public  administrations, 
aimed  to  collect  evidence  on  specific  challenges  related  to  identification,  authentication,  data 
sharing, compliance, and cross-border interactions faced by the stakeholders. This feedback could 
aid in understanding how the European Business Wallets solution can align to real-world business 
requirements and supports seamless digital interactions. 

The Call ran from 15 May 2025 until 12 June 2025.  

1.2.  Meetings and Consultations with Stakeholders 

The  Commission  met  with  stakeholders  that  covered  both  economic  operators  and  public 
authorities between February and October 2025. The purpose of these meetings was to understand 
the needs and challenges faced by stakeholders when engaging in cross-border, digital transactions 
with both  economic operators and public authorities, as well as to  follow up on the contributions 
received  through  the  Call  for  Evidence.  Stakeholders  included  representative  organisations  for 
SMEs and professionals; Chambers of Commerce and business registries; technology vendors & IT 
service  providers;  large  corporations  and  industry;  institutional  stakeholders;  Member  State 
authorities and bodies. 

In addition, both a survey as well as in-depth interviews with selected stakeholders were conducted 
to gather views of interested stakeholders—particularly economic operators, public administrations, 
associations,  and  solution  providers—on 
the  potential  benefits,  burdens,  and  adoption 
considerations of the EUBW initiative (i.e., use cases and business models). 

Survey  results  played  a  key  role  in  quantifying  the  benefits  of  the  EUBW.  They  were  primarily 
used to estimate the time currently spent on manual administrative tasks, helping to assess potential 
efficiency gains.  Additionally, the survey responses helped identify indirect  benefits  and new use 
cases that might not have been initially considered. 

Inputs  from  interviews  informed  the  use  cases  identification  and  the  feedback  from  solution 
providers led to a better understanding of the impact of business and revenue models in SMEs. 

127  For  further  details  concerning  this  Call  for  Evidence,  see  European  Business  Wallet:  digital  identity,  secure  data 
exchange and legal notifications for simple, digital business. 

58 

 
 
Survey: Open 19 May through 18 July 2025. 

In-depth interviews: Conducted during May, June, and July of 2025. 

1.3.  Workshops 

Workshops  were  organised  with  Member  States’  representatives  as  well  as  with  business 
representatives. 

Two separate workshops were organised jointly by the European Commission and Digital Europe, 
as  a  representative  organisation  of  digital  industries  across  Europe  on  5  and  12  June  2025  for 
potential  users  of  the  European  Business  Wallet  and  potential  providers,  respectively.  The  main 
issues  discussed  included  the  interaction  of  the  European  Business  Wallet  with  the  existing  EU 
Digital  Identity  Framework  and  existing  or  emerging  technical  systems;  business  use  cases;  the 
repartition of costs for the introduction of the European Business Wallet; and fragmentation. 

A dedicated workshop with Member States was organised on 3 July 2025 through the EU Digital 
Identity  Cooperation  Group.  The  Commission  presented  a  preliminary  analysis  of  the  responses 
received during the Call for Evidence on the European Business Wallets. Topics discussed included 
the  distinction  between  the  European  Business  Wallets  and  EU  Digital  Identity  Wallets  when 
relating to legal persons, as well as the role of self-employed individuals. Further issues discussed 
included  interoperability,  governance,  uses  cases,  the  appropriate  levels  of  assurance,  levels  of 
obligations, legally valid communication channels, business registry coverage for the self-employed 
and public entities, and the importance of SME and micro-enterprise participation. 

A  workshop  was  organised  with  representatives  of  business  registries  on  4  July  2025.  Topics 
discussed included the EU-wide directory to facilitate cross-border communication, the value of the 
Business Wallet for B2B interactions, levels of obligations, and the nature of business registries as 
authoritative sources of verified company data and trusted credential issuers. Structured discussions 
followed on specifically on the management, verification and updating of  time-sensitive data and 
sustainable business models for credential issuers; as well as legal person identification data distinct 
from  natural  person  identifiers,  and  the  importance  of  bridging  gaps  between  diverse  practices 
across Member States. 

The Commission participated further in a dedicated workshop on the European Business Wallets on 
the margins of the Digital Summit organised by the Polish Presidency in Gdansk on 16 June 2025. 

2.  SYNOPSIS OF THE CALL FOR EVIDENCE 

2.1. 

Introduction 

This synopsis summarises the key findings derived from the contributions submitted during the call 
for  evidence  launched  by  DG  CNECT  to  collect  insights  and  perspectives  on  the  EU  Business 
Wallets Regulation. The call for evidence was open for contributions between May and June 2025 
and counted 95 submissions upon its closing. 

Among  these,  one  same  position  paper  has  been  submitted  in  two  different  contributions  by  two 
different organisations that have elected to adopt a common position.  

Next  to  this,  16  contributions  were  processed  but  failed  to  produce  relevant  insights,  as  they 
consisted of spam or addressed unrelated topics. They were accounted for in the total figures of this 

59 

 
report  but  did  not  impact  the  analysis.  Amongst  these,  15  contributions  came  from  EU  citizens, 
whereas 1 was submitted by an EU company. 

Contributions were received from stakeholders originating from a total of 17 Member States, with 
the  highest  numbers  coming  from  France  (13),  Italy  (11),  and  Germany  (10).  These  were 
complemented  by  submissions  from  Switzerland,  Norway,  the  United  States,  and  the  United 
Kingdom. 

Figure 4– Geographical distribution of the contributions 

Most contributions were sent by companies and businesses (33), including national, European and 
international entities. The second category of contributors is EU citizens (22), followed by business 
associations and trade unions (19+1). The user category ‘Other’ was selected by nine respondents, 
although  the  provided  information  suggests  they are  actually  mostly  business  associations.  Seven 
self-identified public authority organisations contributed to the call.  

Figure 5– Types of contributors 

60 

 
 
More  than  half  (54%)  of  the  submissions  were  also  accompanied  by  an  attachment,  mostly 
consisting of a position paper.    

2.2.  Key Themes and Recommendations 

Each contribution has been examined and its content sorted in one of four types of content, as listed 
below.  This  report  hence  distinguishes  observations  pertaining  to  the  opportunities  opened  up  by 
future EU Business Wallets and observations on the challenges that could hinder its implementation 
and should be addressed. Where contributors provided recommendations, these elements were also 
regrouped as a category, as were direct suggestions of use cases to be onboarded or impacted by the 
EU Business Wallets.  

2.2.1.  Opportunities 

“The Wallet as a facilitator for cross-border business”  

A significant share of contributions (32%) discussed the potential of the Wallets to generate more 
cross-border business. If most of these contributions appeared to take into consideration EU-wide 
cross-border  business,  six  of  them  also  envisaged  it  as  a  tool  to  facilitate  business  beyond  EU 
borders,  mentioning  third  countries  such  as  the  US,  Armenia,  Azerbaijan,  Georgia,  Moldova  and 
Ukraine. The concrete opportunities that the Wallets open up were not systematically defined, and 
when  they  were,  it  revolved  mostly  around  the  positive  impact  of  trust  on  B2B  interactions  or 
around the gains obtained through administrative simplification. Several contributions also insisted 
heavily  on  the  comparative  relevance  of  the  Wallets  for  SMEs,  highlighting  how  they  are  a  vital 
component  of  the  EU  economy  and  how  they  should  hence  be  a  priority  beneficiary. 
Unsurprisingly, the opportunity for cross-border business was mainly relayed by the user category 
containing companies and businesses, with 39% of them mentioning it in their input.  

“The Wallet as an instrument to reduce administrative burden” 

Numerous  contributors  (28%)  also  highlighted  the  Wallets’  potential  to  streamline  compliance 
processes  and  reduce  the  administrative  burden  endured  by  businesses  and  companies,  especially 
amongst French responders. Business associations in particular have made it a point of their input, 
with  more  than  half  of  them  commenting  on  it.  The  fact  that  this  section  mostly  pertains  to 
administrative  simplification  from  the  perspective  of  private  actors  is  explained  by  the 
comparatively  low  amount  of  the  public  authorities  that  contributed  to  the  call  for  evidence,  but 

61 

 
 
they  would  undoubtedly  also  benefit  from  this  administrative  simplification.  Some  contributors 
emphasized  on  the  fact  that  the  compliance  burden  can  disproportionately  affect  SMEs,  hence 
making the Wallets  particularly  relevant  to  them, whereas other argued that  the Wallets  could  be 
useful to reduce the burden without having to compromise on compliance levels.  It could also be 
noted  that  some  contributors  expressed  that  idea  that  the  Wallets  should  be  paired  with  process 
simplification  to  truly  reduce  the  burden  for  companies  and  businesses,  and  that  if  they  were 
properly implemented, they could contribute to economic growth.  

“The Wallets as a tool to streamline B2B & B2G interactions” 

A  significant  share  of  responders  (24%)  also  highlighted  the  potential  of  the  Wallets  to  generate 
trust and to standardise and streamline B2G and B2B interactions. This is especially true for B2B 
interactions,  as  they  are  believed  to  constitute  the  overwhelming  majority  of  the  interactions  that 
take place in the EU. Interactions with customers were also mentioned, although they may be less 
of a priority. Here as  well, SMEs were put  forward as a priority beneficiary. It  may be remarked 
that 17 of the 23 responders that mentioned this opportunity were either representing a company or 
a business association.  

“The Wallets as a mechanism to promote and enable interoperability across the EU” 

Almost one in five contributors (18%) expressed their wish to see interoperability enabled by the 
Wallets ecosystem. For certain responders, this is simply limited to ensuring that a set of standards 
and protocols are properly defined and harmonised, but others went further and observed that the 
need  to  establish  an  interoperable  framework  does  not  only  aim  at  avoiding  excessive  market 
fragmentation, but should also be configured in a way that allows different technical and economic 
models  to  coexist.  Finally,  the  need  for  interoperability  and  synergies  with  the  natural  persons’ 
Wallet(s) was also mentioned. 

“The Wallets as an accelerator for the Digital Single Market” 

As mentioned above, numerous responders believed that the Wallets can support business growth, 
and in particular, 18% of them directly linked this with the realisation of the Digital Single Market, 
noting the impact of its implementation on the market’s overall success.  

“The Wallets as a fast-track for KYC and KYB processes” 

Finally,  11% of the responders (of which 70% companies) remarked the  complexity and costs of 
current KYC and KYB processes for private companies, and emphasized on how the Wallet could 
significantly reduce that burden for them while improving the levels of trust.  

2.2.2.  Challenges 

“MS  and  economic  operators  should  receive  clear  guidance,  technical  assistance,  and  user 
education resources to encourage adoption and prevent misuse” 

Amongst  the  respondents,  12%  deemed  that  a  key  challenge  for  the  implementation  would  be  to 
provide  an  unambiguous  framework  and  the  adequate  guidance  to  the  MS  and  providers,  and  to 
define a common vocabulary and legal framework for business roles and legal entities covered by 
the  EUBW.  To  address  this  challenge,  the  framework  should  clarify  the  relation  of  the  Wallet  to 
existing  frameworks  such  as  the  eIDAS  Regulation  (eIDAS)  and  the  Single  Digital  Gateway 
Regulation. Furthermore, 4% of the respondents in this context provided examples of their national 
distinctions and definitions for legal entities, hereby hinting at the larger context of disparate legal 

62 

 
definitions describing such entities across EU member states. The overall consensus  of responses 
further indicated a preference for simplifying the existing legal frameworks in this context. 

“Going for a digital-only ecosystem involves risks on different levels” 

Amongst  the  respondents,  9%  of  them  highlighted  that  a  digital-only  ecosystem  entails  several 
risks. First and foremost, small actors could face exclusion, either because of unbearable costs, gaps 
in skillsets, or insufficient digital fluency. But other contributors also questioned the environmental 
impact of a fully-digital ecosystem, given the current energetic cost of cloud services, while others 
also  noted  the  dependency  of  the  economy  on  such  an  ecosystem,  hence  resonating  with  the 
cybersecurity  concerns  expressed  in  the  following  paragraph.  These  concerns  should  hence  be 
addressed and mitigated in the chosen method of implementation.  

“Cybersecurity will be a vital challenge in the Wallet ecosystem”  

Across  the  involved  organisations,  7%  of  the  respondents  highlighted  their  concerns  regarding 
cybersecurity.  Particularly,  concerns  were  raised  around  the  risks  entailed  by  a  centralised 
implementation  model instead of distributed networks and infrastructure. Contributors insisted on 
the need to foresee sufficient access safeguards. Overall, there is consensus on the need for robust 
security  architecture  in  order  to  prevent  misuse,  breaches,  or  unauthorized  access  to  sensitive 
credentials and data. 

2.2.3.  Recommendations 

Technological neutrality, future-proof dimension and harmonised standards and protocols 

A  considerable  amount  of  contributors  (47%)  expressed  opinions  on  the  technology  and 
infrastructure that will be underlying to the future Wallet. More precisely, they often shared their 
belief  that  the  Wallets  should  be  technologically  neutral,  that  they  should  be  flexible  and  future-
proof,  and  that  they  should  rely  on  harmonised  standards  and  protocols  enabling  interoperability. 
One  aspect  that  seemed  to  particularly  require  harmonisation  in  the  eyes  of  many  respondents  is 
that of the identifiers used to recognise businesses. Throughout the contributions, the idea that one 
single (cross-border) identification convention and solution is needed is indeed heavily emphasized 
upon, and some contributors even made concrete suggestions in that sense, noting that the European 
Unique Identifier (EUID) or the Data Universal Numbering System (DUNS) could be relied upon 
for that purpose. In complement of this unique identifier approach, others also remarked that, from 
a data perspective, data exchange should be based on semantic models capable of supporting cross-
border  data  interoperability.  In  this  regard,  excessively  restrictive  data  models  and  formats 
preventing the effective sharing of trusted data should be avoided, as that data sharing is deemed to 
be one of the key potential added values of the Wallet. In the eyes of many contributors, the true 
key to successfully implement the Wallet will actually reside in defining the right framework rather 
than in providing the solution itself. Ensuring that the Wallet remains futureproof and sufficiently 
flexible  to  address  the  needs  of  its  users  would  require  a  sound  foundation  and  shared 
understanding,  and  the  MS  should  hence  not  directly  provide  the  solution  or  technical 
infrastructure, but focus on setting up the best conditions and guidelines.  

Lessons learned and existing pilots and frameworks 

The second most frequent (type of) recommendation shared by contributors pertains to experience 
and  learning.  Indeed,  as  highlighted  by  38%  of  the  actors,  of  which  50%  companies,  there  are 
various pilots ongoing around the globe, a plethora of frameworks have been established by various 
organisations, and  there  are countless  lessons learned that could  benefit to  the future Wallet.  The 

63 

 
most natural and necessary synergy concerns the EUDI Wallet (and the corresponding Regulation 
and ARF), as many contributors (17%) emphasised how the ecosystem, the infrastructure and the 
technical  architecture  supporting  the  EUBW  need  to  be  perfectly  aligned  and  integrated  with  the 
EUDIW to ensure interoperability between the two frameworks and to build on the successes of the 
latter.  Other  suggested  examples  include  UNCITRAL’s  model  laws  and  frameworks,  the  Data 
Universal  Numbering  System  (DUNS),  or  the  United  Nation  Transparency  Protocol.  Overall,  the 
initiative  should  integrate  the  lessons  learned  and  achievement  of  other  previous  pilots  and 
framework and  fit  in  the global ecosystem.  That  message was also  particularly  relayed by  Italian 
and German responders, and it may be remarked that it was put forward by five of the six non-EU 
MS contributors.  

Prioritisation of the adequate use cases and scope 

Many  contributors  (27%)  underlined  that  prioritisation  will  be  a  key  factor  to  ensure  that  the 
ecosystem will take off and scale up, whether that prioritisation pertained to use cases, focus areas 
or target audiences. A prominent example of use case focus is representation and power of attorney 
documents,  as  numerous  respondents  suggested  that  they  should  be  onboarded  in  priority  to 
demonstrate  the  usefulness  of  the  wallets  (and  to  build  initial  synergies  with  the  EUDIW). 
Regarding target audiences, some contributors insisted on the need to target not only companies but 
also  self-employed  persons,  NGOs  and  other  types  of  organisations,  while  others  conversely 
suggested onboarding self-employed persons’ use cases on the EUDI Wallet for natural persons.  

Access to business registers and other authentic sources 

For 20% of the contributors, the success of the Wallet will also depend of its capacity to connect 
and  interact  with  business  registries  and  other  relevant  authentic  sources  to  onboard  and  store 
credible  and  secure  attributes.  This  is  first  demonstrated  by  several  references  to  the  BRIS,  but 
some  contributors  go  further  by  suggesting  establishing  an  EU-wide  business  register  or,  as 
highlighted in other sections, by at least creating shared identifiers.  

Traceable, accountable, and auditable interactions  

Among the respondents, 19% of the entities emphasised that traceable, accountable, and auditable 
standards  within  the  Wallet  infrastructure  are  pivotal  to  efficiently  countering  various  risks, 
including  fraud and misidentification (e.g., impersonating businesses to  deceive trading  partners). 
This need for robust security measures must be properly balanced with businesses’ perceived need 
for flexibility, for example, allowing them to easily adjust representation rights. 

Market-Driven Deployment and Governance of the EUBW  

A  total  of  18%  of  the  respondents  (mostly  representing  companies  and  business  associations) 
shared  insights  on  the  dynamics  under  which  the  EUBW  should  be  deployed,  and  they  namely 
noted  that  the  Wallet  should  be  based  on  sustainable,  market-driven  models.  Unlike  the  EUDI 
Wallet, they remarked that it should not automatically be issued free of charge. A paying approach 
could indeed create market incentives to rapidly build the networks upon which widespread Wallet 
usage would depend, while allowing room for innovation and enabling market dynamics to shape 
the most effective solutions. The regulatory framework would also have to support such governance 
while  encouraging  market-led  development.  A  few  existing  trusted  service  providers  strongly 
advocated  against  marginalising  well-established  providers  by  creating  Wallet  governance  and 
operational frameworks accessible only to a small number of (public or semi-public) entities. Such 
an  approach  could  disrupt  the  market  by  creating  an  uneven  playing  field,  where  only  a  few 

64 

 
selected  actors  would  benefit  from  privileged  access  and  legitimacy.  Fair  competition  should 
remain at the heart of the Wallet deployment. 

Mandatory or voluntary adoption of the Wallet 

Based  on  the  analysis,  16%  of  the  respondents  (mostly  companies  and  business  associations) 
discussed whether the adoption of the Wallet should be mandatory or voluntary, and a number of 
them formulated clear recommendations. First,  six  respondents  suggested to  make the acceptance 
and usage of the EUBW mandatory to ensure harmonisation, to avoid fragmentation, and to enable 
a  streamlined  business  process  capable  of  reaching  its  full  potential.  On  the  other  hand,  four 
respondents questioned whether the adoption should be mandatory for businesses, especially from 
the perspective of small  economic operators which might  be overwhelmed by the introduction of 
additional  digital  complexity.  Finally,  two  respondents  advocated  for  a  completely  voluntary 
adoption, leaving it to economic operators and public sector bodies to decide whether to accept the 
Wallet. 

Financing and business approach of the EUBW 

Amongst  the  respondents,  in  direct  correlation  with  the  above  section  on  market-dynamics,  16% 
shared  their  thoughts  on  the  financing  and  business  approach  for  the  Wallet.  As  previously 
highlighted,  these  contributors  advocated  for  an  economically  sustainable  model  for  the  Wallet, 
meaning  that  services  should  not  be  free  of  charge  for  users  to  stimulate  growth  and  to  allow 
different providers to enter the market and expand the range of services related to the wallet.  

Appropriate Level of Assurance 

Finally,  12%  of  the  contributors  expressed  their  opinion  on  what  they  deemed  to  be  the  most 
appropriate baseline Level of Assurance for the EUBW.  They generally emphasised on the need 
for  a  Substantial  Level  of  Assurance  and  argued  in  favour  of  making  it  the  baseline  for  most 
EUBW use cases. The remainder of respondents suggested to rely on a High Level of Assurance for 
certain transactions and situations where a high level of trust is needed. Amongst the respondents, 
only businesses (9) and business associations (2) addressed this question. 

2.2.4.  Use cases 

Increasing trust in B2B relations 

For  20%  of  the  responders,  amongst  which  more  than  half  are  companies  and  businesses,  B2B 
interactions  should  be  a  priority  for  the  Wallet  and  it  should  hence  focus  on  use  cases  that 
contribute  to  increasing  trust  between  private  actors.  This  mostly  centres  on  the  notion  of 
identification and representation, with a distinct focus set on powers of attorney and mandates, but 
it could  also  be translated into building a standardised set  of  attributes  that together contribute to 
strengthening  a  company's  credibility,  and  can  for  example  have  a  limited  validity  in  time  to 
guarantee up-to-datedness.  

Facilitating KYC and AML processes  

Know-you-customer and anti-money laundering processes represent a heavy but necessary burden 
for  many  companies,  and  16%  of  the  responders  (of  which  a  vast  majority  of  businesses  and 
business associations) put a particular emphasis on them. This would not only save them time and 
be cost-efficient, but it could actually help them actively decrease their endured risks, which could 
have a considerable financial impact.  

65 

 
Exchanging business documents 

This fundamental functionality of the envisaged Wallet has been directly mentioned by 12% of the 
respondents, and it is worth noting that is it not only considered from the perspective of exchanging 
(Q)EAAs  issued  solely  by  authentic  sources,  but  also  to  allow  the  storage  and  presentation  of 
documents emanating from the companies themselves.  

Enabling banking and payment services 

For  12%  of  the  responders,  the  Wallet  will  serve  significant  use  cases  in  payments  and  banking 
services. This covers both the idea that financial sector actors should be a priority audience for the 
Wallet, given the complexity and high-assurance required in their processes, and also the idea that 
the  Wallet  will  streamline  actual  payments,  for  instance  by  enabling  automated  payments  upon 
reception of invoices.  

Others 

Various  other  use  cases  were  also  mentioned  by  the  respondents,  although  with  less  widespread 
support.  These  for  example  include  eArchiving  functionalities,  access  to  secure  inboxes  and 
messaging tools, or automated and secure e-invoicing services. 

2.3.  Conclusion 

Overall,  a  clear  majority  of  respondents  welcomed  the  introduction  of  the  EUBW  and  expressed 
enthusiasm in the opportunities that it will open up. This positive feedback was especially evident 
among public and private sector actors.   

The  first  key  observation  deriving  from  this  call  for  evidence  is  that  the  EUBW  is  decisively 
perceived as an accelerator of the Digital Single Market. This acceleration would mostly be a result 
of  the  reduction  of  the  administrative  burden  for  businesses  and  public  sector  bodies  and  of  an 
increased  trust  and  speed  in  B2B  interactions,  both  of  which  would  directly  or  indirectly  lead  to 
new business opportunities and economic growth.  

A second key observation is that in terms of use cases, the needs of the private sector are clearly set 
on  identification  and  representation  functionalities  that  would  facilitate  interactions  in  B2G  and 
B2B  settings  (and  particularly  KYC  and  KYB  processes).  An  incremental  implementation 
prioritising such use cases could hence be a promising pathway to unlock the full potential of the 
Wallet and maximise user adoption, before progressively extending functionalities and enabling an 
exponential number of use cases.  

The  third  key  observation  is  that  the  Wallet  should  not  be  approached  as  a  stand-alone  and 
monolithic tool to be delivered in the market by public actors, but rather as an ecosystem that will 
emerge  thanks  to  the  adequately  set  framework  and  infrastructure.  First,  the  EUBW  should 
perfectly  complement  the  EUDI  Wallet  ecosystem,  while  building  on  its  achievements  and 
integrating extensive synergies with it. It must secondly be part of a larger coherent harmonisation 
process  that  also  touches  upon  elements  such  as  unique  business  identifiers,  legal  definitions  of 
enterprises  or technical  standards.  Finally,  it should demonstrate overall flexibility  and be future-
proof, and unequivocal contributions advocate for a market-driven Wallet ecosystem that would be 
a reference in public-private cooperation.  

66 

 
 
3.  SYNOPSIS OF OTHER WORKSHOPS AND CONSULTATIONS 

This  synopsis  summarises positions on a variety  of topics taken at  varying consultation activities 
that  the  Commission  participated  in  or  organised    with  Member  State  representatives,  public 
authorities, industry and SMEs representatives. These include workshops, meetings, surveys and in-
depth  interviews  covering a broad range of topics relevant  to  the European Business Wallet. The 
consultation  activities  gather  views  of  interested  stakeholders—particularly  economic  operators, 
public administrations, associations, and solution providers—on the potential benefits, burdens, and 
adoption considerations of the EUBW initiative (i.e., use cases and business models). The details of 
the processes are described in section 1 to this Annex. 

Before  presenting  the  main  finding,  it  is  important  to  note  several  methodological  considerations 
and limitations. The EUBW initiative was still in its early stages, and its definition was evolving. 
This  situation  may  have  influenced  the  depth  and  specificity  of  the  stakeholders’  feedback. 
Responses to the consultation activities do not constitute a statistical sample of the EU population 
or the target population. Weighting techniques were not applied, as demographic data is insufficient 
for such adjustments. 

Stakeholder  credibility  was  considered  during  analysis,  including  factors  such  as  expertise, 
representativeness, track record, and relevance to the EUBW initiative. 

No  coordinated  campaigns  or  mass  identical  submissions  were  identified  during  the  consultation 
activities. 

This document should be regarded solely as a summary of the contributions made by stakeholders 
to  the  in-depth  interviews  on  the  European  Business  Wallet  initiative.  It  cannot  in  any 
circumstances be regarded as the official position of the Commission or its services. Responses to 
the consultation activities cannot be considered as a representative sample of the views of the EU 
population. 

Stakeholder  views  were  analysed  and  taken  into  account  to  the  extent  possible.  Their  input 
informed the refinement of the cost-benefit analysis, identification of use cases, and business model 
considerations. 

3.1.  Key challenges 

Industry representatives noted that the EU still lacks a unified legal and technical infrastructure to 
support  business  identity,  representation  and  regulatory  compliance.  Economic  operators  of  all 
sizes continue to face complex and fragmented procedures when interacting with public authorities 
or private-sector partners across borders. The absence of a harmonised approach to limits the digital 
single  market’s  effectiveness.  It  discourages  automation,  inhibits  trust  in  cross-border  exchanges 
and  slows  down  transactions  in  both  B2G  and  B2B  settings.  The  EUBW  has  the  potential  to 
address these issues by introducing a legally recognised, interoperable identity solution tailored to 
economic operators. However, to be effective, it must resolve these fragmentation issues at both the 
legal  and  technical  levels  –  and  be  rolled  out  in  a  way  that  ensures  universal  adoption  and  legal 
clarity across Member States. 

Reporting  and  administrative  obligations  are  time  consuming,  inconsistent  and  disproportionately 
burdensome  for  smaller  firms.  Many  Member  States  maintain  their  own  document  formats  and 
identity verification channels, resulting in limited mutual recognition and duplicated efforts. Where 
platforms  are  digital,  they  are  not  interoperable.  For  SMEs  in  particular,  the  administrative 
processes in obtaining cross-border permits and authorisations are burdensome. 

67 

 
SMEs struggle with multiple, non-integrated national tools. The EUBW can help by ensuring data 
interoperability  and  applying  the  once-only  principle  to  avoid  the  need  to  repeatedly  provide  the 
same information. 

Concerning the outcome of the conducted survey, as follows the key themes and findings:  

Market Landscape 

Public  administrations,  Associations  of  Economic  Operators,  and  trust  service  providers  across 
Europe face challenges due to fragmented national digital infrastructures and limited cross-border 
interoperability, despite strong national systems and a growing hybrid public-private service model. 

Burden of Administrative Activities 

Stakeholders identified several administrative activities as burdensome, particularly those involving 
document  exchange,  compliance,  and  verification  across  Member  States.  These  were  often 
described as time-consuming, repetitive, and prone to human error. 

Expected Benefits of the EUBW 

Respondents  anticipated  that  the  EUBW  could  significantly  reduce  the  cost  and  complexity  of 
administrative tasks. Benefits cited included faster services, improved data accuracy, and enhanced 
cross-border operations. 

Willingness to Adopt 

Many  stakeholders  expressed  openness  to  adopting  a  cloud-based  solution  like  the  EUBW, 
especially  if  it  streamlines  processes  and  reduces  costs.  However,  concerns  were  raised  about 
integration challenges and the need for clear guidance and support. 

In  the  context  of  the  interviews,  the  different  stakeholder  groups  highlighted  the  following  main 
administrative activities as burdensome:  

Public Administrations  

•  Cross-border  interoperability:  National  systems  are  often  automated,  but  verifying  foreign 
documents  still  requires  manual,  in-person  processes.  Cross-border  interoperability  is 
hindered  by  differing  regulations  and  documentation  standards,  increasing  fraud  risk. 
Manual  processes  persist  even 
in  advanced  systems  (e.g.,  fraud  checks,  police 
communications).  

Associations of Economic Operators  

•  General Issues: Economic Operators face high administrative burdens across sectors due to 
limited  digitalisation  (manual  paperwork  persists),  and  overregulation.  The  cumulative 
effect of administrative burdens is more problematic than a single issue or task.  

•  Key  Burdensome  Activities:  Economic  Operators  struggle  with  complex 

identity 
verification,  repetitive  compliance  documentation,  and  lengthy  business  setup  (often 
months).  Licensing,  VIES  registration  (requiring  physical  inspection),  and  annual  Social 
Security  regularisation  (e.g.,  40–45  mins  for  3.5M  self-employed  entrepreneurs)  are  time-
consuming.  Labour  compliance,  cross-border  admin,  and  tasks  like  record  keeping, 

68 

 
verification, and data management are especially challenging. Digitalisation is most needed 
in posting of workers, sustainability reporting, and taxation.  

•  SME-Specific  Challenges  &  Costs:  SMEs,  particularly  micro  Economic  Operators,  often 
lack  digital  tools  and  outsource  administrative  tasks,  raising  costs.  Externalisation  is 
expensive:  labour  compliance  (15–30%  of  income),  pension  applications  (e.g.,  ~€150  in 
Spain), and sustainability consultancies (up to €100,000). Time costs are high: 30–50% of 
time spent on administrative activities, 9 hours/week chasing payments, and 1.5 days/week 
on identity validation. Hidden costs include delays, fines, and manual processes due to poor 
infrastructure.  

Trust Service Providers  

•  Fragmented  Landscape  &  Verification  Gaps:  Europe’s  identity,  document  exchange,  and 
authorisation systems are fragmented, complicating cross-border operations. Reliable digital 
verification  of  Economic  Operators  and  their  representatives  is  lacking,  even  with  paper-
based methods. Most private services depend on public infrastructure.  

•  Core  Challenges  &  Cost-Saving  Potential:  Verifying  an  Economic  Operator  is  relatively 
easy,  but  confirming  an  individual’s  affiliation  is  difficult  without  tools  like  corporate 
emails or domain checks. KYC costs in Germany alone reach €2.3 billion annually. AML 
and  counter-terrorism  compliance  are  complex  and  resource-intensive.  SMEs  are  less 
attractive  to  providers  due  to  low  volume  and  purchasing  power.  SMEs  applying  for  EU 
funding often spend weeks on admin tasks; EUBW could reduce this to minutes.  

3.2. 

Support for concept of the business wallets 

Numerous  Member  States  voiced  their  support  for  the  business  wallets,  including  where  strong 
private sector interest has been expressed through the Large-Scale Pilots. The business wallets will 
be  a  valuable  addition  to  the  wallet  ecosystem.  The  pilot  was  a  good  illustration  that,  with 
organisations  varying  in  size  and  structure,  a  business  wallet  must  support  multi-user  access  and 
integration  into  existing  enterprise  systems,  in  comparison  to  a  natural  person  wallet,  and  that 
meaningful  wallet-to-wallet  communication  is  essential.  Member  States  also  suggested  that 
business wallets would not always require a high level of assurance, making implementation more 
flexible and practical. Additionally, current rules do not adequately cover key business needs like 
cross-border representation, liabilities, power of attorney, and automating supplier verification, and 
a business wallet can address these. 

Some Member States particularly wanted to understand how the business wallets would differ from 
the  EU  Digital  Identity  Wallets.  For  some  Member  States,  it  was  unclear  what  aspects  of  the 
business wallets truly represent new challenges requiring new legislation, and questioned why these 
cannot  be  integrated  into  the  existing  legal  and  technical  framework  of  the  EUDI  wallet.  Having 
clear,  well-documented  use  cases  could  help  identify  distinct  requirements  as  compared  from  the 
EUDI wallet thus justifying the need for a separate business wallet because otherwise developing 
and maintaining two wallets would be costly and complex.  

Industry representatives recommended that the European Business Wallets should be developed 
around high impact use cases: These include the ability to digitally prove a legal person’s identity, 

69 

 
 
 
share  verified  credentials,  attestations,  mandates  and  fulfil  legal  obligations  in  cross-border 
contexts. Priority should be given to functions such as onboarding, licensing, ESG (Environmental, 
Social  and  Governance)  disclosures  and  public  procurement.  Focusing  only  on  B2G  reporting 
would limit the wallet’s added value and adoption. The EUBW should also be clearly differentiated 
from the tools available under the Single Digital Gateway Regulation. 

For  SMEs,  the  lack  of  concrete  examples  and  actionable  use  cases  make  it  difficult  for  them  to 
envision the benefits of the business wallets. 

3.3. 

Scope of the European Business Wallets 

Some business registries emphasised the importance of the use of terminology to ensure precision 
in terms of who is and is not covered in the scope. The term “economic operators” is broad and may 
lack precision, and it is important to distinguish between companies and legal persons not covered 
in  business  registries:  this  distinction  is  important  for  understanding  who  exactly  would  use  the 
business wallet and how. 

Most participants agreed that natural persons acting as business operators (e.g. the self-employed) 
should  require  separate  business  wallets  –  and  hence  separate  legal  entity  identifiers  –  instead  of 
relying  on  their  existing  personal  identifiers.  Legal  and  regulatory  frameworks  are  key  factors  in 
shaping digital identity processes, not just technical capabilities; for example, using business data 
tied  to  self-employed  individuals  could  trigger  GDPR  obligations  and  having  distinct  business 
wallets  provides  clarity  and  better  separation  of  concerns  under  data  protection  rules.  Business 
registries  agreed  that  with  diverse  legal  frameworks  and  practical  realities  across  the  Union,  this 
makes harmonisation complex. 

For some Business registries the focus of the business wallets should be on B2B interactions, and 
not  only  B2G  use.  The  wallets’  main  value  and  bigger  impact  lies  in  the  B2B  domain,  and  this 
should be the emphasis going forward. 

Industry  representatives  recommend  that  where  existing  national  registries  are  incomplete  or 
fragmented,  the  Commission  should  establish  minimum  criteria  for  issuing  credentials  to  ensure 
full business coverage. 

As  regard  to  the  additional  insights  from  interviews,  stakeholders  highlighted  key  use  cases  and 
cost-saving opportunities as follows:  

Public Administrations 

•  Uncertainty on EUBW Impact: Public administrations generally lack specific financial data 
on current administrative burdens for Economic Operators and cannot yet provide clear cost 
estimates for EUBW implementation or potential savings due to ongoing development and 
unclear final requirements.  

•  Use Cases:  Automating identity verification and document validation;  Streamlining power 
of  attorney  processes  and  Economic  Operators’  authentication  for  online  platforms  and 
financial  services;  Simplifying  public  procurement,  grant  applications,  and  compliance 
checks;  Enabling  Economic  Operators  to  issue  their  own  credentials  (e.g.  employee 
verification);  Integrating  business  data  into  EU-wide  platforms  for  seamless  cross-border 
operations.  

70 

 
•  Cost-Saving  Opportunities:  Reducing  manual  data  entry  and  duplicative  administrative 
tasks;  Enhancing  fraud  detection  and  data  integrity  through  secure  digital  verification; 
Supporting SMEs with easier access to services and compliance tools; Achieving semantic 
and technical interoperability, lowering error rates and improving efficiency. 

Associations of Economic Operators  

•  Use  Cases:  Identity  &  legitimacy  verification of  partners  and  representatives;  Document 
submission for  compliance,  licensing,  and  tax  filings;  Cross-border  operations,  including 
VAT  registration  and  understanding  foreign  admin  structures;  Labour  compliance (e.g. 
equality  plans,  harassment  prevention);  GDPR  and  cybersecurity reporting;  Sustainability 
reporting and digital invoicing; Record keeping and data management, especially for micro- 
Economic Operators; Universal credential repository for verifying suppliers and partners.  

•  Cost-Saving  Opportunities:  Streamlined  identity  verification and  representation  checks; 
“Once-only”  principle to  eliminate  repetitive  data  submissions  across  authorities;  Unified 
EU  reporting  system to  replace  fragmented  national  tools;  Simplified  tax  justification  and 
document  provision;  Cross-border  navigation  support for  SMEs;  Lower  barriers  to  cross-
border expansion.   

Trust Service Providers  

•  Use  Cases:  Automating KYC/KYS,  AML  compliance,  and 

identity  verification; 
Streamlining representation  proofs,  digital  mandates,  and  onboarding  processes; 
reporting; 
Enabling digital  product  passports, 
Supporting eInvoicing,  contract  signing,  and  financial  reporting  (e.g.  VAT  reconciliation); 
Facilitating cross-border  Economic  Operators  registration,  access  to  funding,  and  public 
procurement;  Enhancing supply  chain  transparency,  Industry  4.0,  and  circular  economy 
applications;  Providing digital  credentials (e.g.  company  roles,  Chamber  IDs,  AI  agent 
permissions).  

third-party  certifications,  and  ESG 

•  Cost-Saving Opportunities: Eliminating duplicated processes and manual checks; Potential 
of  reducing  compliance  costs  by  up  to 50% in  finance  functions;  Unlocking billions  in 
savings through  automation  of  verification  and  reporting;  Lowering  barriers  for  SMEs  by 
simplifying  access  to  services  and  funding;  Strengthening  trust,  transparency,  and 
competitiveness in the EU digital market.  

•  KYC/KYS  as  Primary  Opportunity:  There  is  strong  consensus  that  the  EUBW's  most 
significant immediate value proposition and cost-saving opportunity lies in streamlining and 
automating  Know  Your  Customer  (KYC)  and  Know  Your  Supplier  (KYS)  processes,  by 
embedding them within the wallet's transaction layer.  

•  Dependence  on  EUBW  Clarity:  Providers  are  waiting  for  clearer  information  on  the 
EUBW's  final  regulatory  details  and  specific  obligations  to  fully  assess  its  potential  and 
business models.  

3.4.  Role of business registers and scope of registration 

Business  registries’  authorities  were  agreed  on  the  fundamental  role  of  business  registers  as  the 
unique, authoritative, legally mandated source of verified company data. Some saw the potential of 
the  business  wallets  to  facilitate  digital  transformation  in  preventing  data  fragmentation  and 

71 

 
multiple  competing  sources  of  company  information  by  consolidating  authoritative  data  by 
modernising how information is accessed and shared. 

Business registries noted the disparity between EU company law on business registries focusing on 
limited  companies  while  some  national  registries  include  many  other  legal  entities  that  conduct 
business  operations,  with  some  suggesting  that  published  information  and  credentials  should 
eventually cover in future these broader categories to include all relevant economic operators. 

The question of expanding registration to cover entities currently not included in the registries was, 
in the view of Business registries, a matter for regulation to ensure the appropriate legal basis is in 
place  for  newly  registered  entities.  In  addition,  the  primary  challenge  in  this  regard  lies  in 
establishing  the  appropriate  legal  basis  at  either  the  national  or  European  level  to  authorise  the 
issuance of unique identifiers for new economic operators. For public administrations or other new 
groups,  Business  registries  would  need  to  develop  mechanisms—such  as  databases  and  legal 
verification  processes—to  validate  these  entities  before  issuing  unique  identifiers,  including  the 
suggestion for a phased approach to this. 

Some  took  the  view  that  collaboration  between  business  registers  and  commercial  trust  service 
providers  is  already  possible  and  should  be  leveraged,  and  therefore  it  is  important  to  integrate 
existing  frameworks.  They  cautioned  against  creating  new  or  overlapping  regulatory  frameworks 
that complicate the ecosystem. 

3.5.  Power of Attorney and mandate management 

Industry  representatives  noted  that  there  is  currently  no  standardised  EU-wide  mechanism  for 
representing company mandates and delegated authority. This means that verifying who is legally 
authorised  to  act  on  behalf  of  a  company  remains  a  national  exercise,  often  reliant  on  manual 
checks,  power-of-attorney  paperwork  or  unverified  declarations.  As  a  result,  cross-border 
contractual  or  licensing  procedures  often  require  significant  additional  effort,  creating  delays  and 
compliance risks. 

They noted further that the European Business Wallets should be by a standardised approach to role 
and mandate management, allowing the designation of authorised representatives and linking them 
to clearly defined scopes of authority. By relying on EU-wide cross-border identity matching for all 
economic operators, leveraging existing business registries and solutions to provide flexibility and 
the avoidance of duplication, will provide legal certainty. 

3.6.  Obligations of use and acceptance 

Some  Business  registries  wanted  to  understand  the  balance  between  regulatory  obligations  and 
market incentives in fostering wallet adoption and availability 

Industry  representatives  call  for  clear  rules  to  define  how  digitally  signed,  machine-readable 
credentials  are  issued,  stored  and  used.  National  authorities  should  be  required  to  both  issue  and 
accept these credentials,  as the widespread availability of trusted public sector credentials will be 
key to encouraging private-sector adoption and support legal clarity. 

Industry representatives consider that the European Business Wallets should be mandatory for the 
public sector and for some specific use cases to ensure validity and scale but should also provide 
for flexibility in terms of deployment. 

72 

 
There  were  divergent  views  among  SMEs  in  whether  the  use  of  the  business  wallets  should  be 
voluntary or mandatory when it came to economic operators. Overall there was broad agreement on 
the need for mandatory acceptance of business wallets by public administrations and cross-border 
entities to ensure their widespread usability, as well as to benefit from the once-only principle. 

3.7.  Managing credential validity periods 

Business  registries  were  agreed  on  the  importance  of  business  registers  verifying  and  updating 
company  information,  and  that  digitalising  these  processes  would  maintain  or  improve  legal 
certainty.  As  a  digital  representation  of  register  data,  the  business  wallets  should  be  closely 
monitored and updated. Digital formats and eIDAS trust services, including temporary or revocable 
powers of attorney, enable real-time updates, revocation, and validation to address the challenge of 
avoiding the use of outdated and invalid credentials effectively. The business wallets  will require 
robust  mechanisms  to  monitor  credential  validity  and  be  able  to  handle  revocations:  either  the 
system  can  retrieve  credentials  in  real-time  from  registers  or  it  will  be  able  to  manage  validity 
periods efficiently. 

3.8. 

Interoperability, functionalities and technical implementation 

Industry representatives consider that integration with the EUDI Wallet and trust services under 
eIDAS should be a baseline requirement for the European Business Wallets.  

Industry representatives consider that the business wallets must support a variety of implementation 
models  –  including  mobile,  enterprise-integrated  and  cloud-based  solutions  –  and  allow 
participation by qualified public and private providers. They call for the technical specifications to 
be based on open, interoperable standards to  facilitate integration with  existing  business  systems, 
particularly for SMEs; the regulatory framework should avoid prescribing architecture or formats, 
focusing instead on legal effect and interoperability. 

They  consider  that  the  regulation  should  focus  on  the  trustworthiness  and  verifiable  credentials 
themselves, rather than on the design or implementation of wallets. This will allow wallet providers 
– whether apps, enterprise tools or cloud services – to compete on usability, innovation and features 
without being constrained by rigid regulatory requirements. 

Industry  calls  for  the  European  Business  Wallets  to  include  as  standard  features  authentication 
mechanisms,  access  controls  and  audit  logs  should  be  standard  features:  these  will  act  as 
appropriate safeguards to prevent fraud, ensure data integrity and ensure traceability. Linkability is 
important  to  ensure  accountability  by  having  credentials  and  actions  be  attributable  to  legal 
representatives and the legally represented person. 

Industry  considers  that  compatibility  with  global  identifiers  (e.g.  LEI),  standardised  interoperable 
data  formats  and  internationally  recognised  credentials  will  be  essential  to  ensure  long-term 
relevance and usability. The wallet should also support machine-readable, semantically aligned data 
to enable automation, analytics and cross-system integration. 

SMEs call for a digital identity integration that works across borders and complements or surpasses 
the SME ID. Offering lots of different digital tools is counterproductive. Either the business wallet 
and the SME ID must be connected, or consider having just one tool for SME digital identity. 

73 

 
3.9.  Legally valid communication channel 

Some Business registries agreed that the inclusion of a legally valid, cross-border communication 
channel  in  the business wallets  could  address  the legal  limitations of traditional email  for official 
communications as it would provide for an EU-wide valid channel. Currently only some Member 
States have a national communications channel, while others do not. 

Several Member States emphasised the importance of having unique identifiers as a foundation for 
communications channels for building further datasets and digital identities. 

3.10.  Business models and market development 

Some  Business  registries  emphasised  the  importance  of  balancing  free  data  provision  with  the 
sustainability  of  registers.  Broadening  data  scope  without  adequate  funding  could  strain  registers 
and  impact  data  quality.  The  suggestion  was  to  keep  the  wallet  data  scope  aligned  with  what’s 
already free of charge to avoid financial or operational burdens 

SMEs  call  for  hands-on  guidance  and  clear  information  on  how  to  implement  the  European 
Business Wallets and a concrete understanding of the benefits, calling for the EU to make an effort 
to support them every step of the way 

SMEs consider that free implementation is key to encouraging SMEs to use it: if they have to pay 
for it, they are unlikely to use it. 

3.11.  EUBW Market Landscape and Adoption Costs  

This section presents stakeholder views on the existing digital and regulatory landscape relevant to 
the  EUBW,  followed  by  insights  on  expected  adoption  costs  and  related  challenges  for  different 
stakeholder groups. 

Public Administrations  

•  Established  National  Digital  Infrastructures:  Many  countries  have  implemented  strong 
national  digital  identity  schemes  (e.g.,  Portugal's  Mobile  ID,  Netherlands'  eHerkenning, 
Finland's Suomi.fi e-authorisation, Spain's Cl@ve) and foundational digital services like e-
invoicing platforms or business registries.  

•  Cross-Border  Interoperability  Gap:  A  major  recurring  challenge 

limited 
interoperability between national systems, particularly for verifying documents, identifying 
foreign citizens, or validating Economic Operator’s information across borders. This often 
necessitates manual or face-to-face processes.  

the 

is 

•  Hybrid  Public/Private  Service  Provision:  While  governments  typically  provide  core 
infrastructure and set standards, Economic Operators frequently develop and offer services 
on  top  of  these  public  backbones  (e.g.,  eHerkenning  providers,  healthcare  applications  in 
Germany, e-invoicing operators in Finland, InfoCamere's services). There is an inclination 
towards market-driven solutions for business wallets. 

Associations of Economic Operators  

•  Fragmented  National  Solutions:  Existing  digital  tools  and  channels  for  administrative 
activities  are  highly  fragmented,  especially  for  cross-border  exchanges.  While  national 

74 

 
digital solutions exist, they often do not interlink, forcing Economic Operators and citizens 
to repeatedly provide the same information to different authorities.  

•  Dominance  of  Government  Identity:  Most  operational  digital  identity  solutions  are 
government-based initiatives, but their cross-border utility for Economic Operators is often 
limited.   

Trust Service Providers  

•  Market Fragmentation and Verification Challenges: Trust service providers observe a highly 
fragmented  regulatory  and  digital  landscape  across  Europe.  They  note  a  general  lack  of 
reliable government services for the digital verification of an Economic Operator's identity 
or an individual's affiliation with an Economic Operator.  

•  Hybrid  Public-Private  Model  Dominance:  Purely  Private  sector  services  without 
government involvement are "very rare"; private providers commonly operate on top of, or 
in partnership with, public infrastructure.  

With regard to the adoption costs, the following views were gathered:  

Public Administrations 

•  SMEs  &  Larger  Economic  Operators:  SMEs  face  minimal  costs  and  fewer  challenges  in 
adopting EUBW. However, for larger Economic Operators, the wallet  concept  is  complex 
and  requires  server-based  solutions  with  role-based  access.  In  Finland,  it's  suggested  that 
wallet provision for Economic Operators should be market-driven, not government-led. 

•  Adoption  Barriers:  The  implementation  of  EUBW  requires  regulatory  changes  to  replace 
existing professional identity systems, such as the smart cards widely used in countries like 
Germany.  Interview  participants  also  noted  that  adoption  could  face  challenges  if  the 
EUBW  fails  to  provide  access  to  non-public  information  or  if  equivalent  data  is  already 
accessible through other channels. Integration Challenges: A crucial adoption factor for the 
EUBW  is  seamless  system  integration  and  usability  with  minimal  user  interaction,  as 
exemplified by the current smart card system that creates a background connection requiring 
only  one-time  authentication,  whereas  a  solution  requiring  recurring  authentication  would 
likely face rejection. 

Associations of Economic Operators  

•  Adoption  Hurdles:  Adoption  costs  and  ecosystem-wide  acceptance  are  significant 
challenges.  SMEs  are  particularly  price-sensitive,  often  lack  digital  readiness,  and  prefer 
simple,  commodity  offerings,  whereas  larger  Economic  Operators  prioritise  integration 
capabilities with their existing systems.  

•  Difficulty  in  Estimating  Costs:  Several  sources  explicitly  state  that  it  is  "very  difficult  to 
estimate" or that "no comprehensive data or proxy is available" on the specific cost for an 
average  SME  to  adopt  a  solution  like  the  EUBW,  or  the  time  it  would  take  for  them  to 
familiarise themselves with it.  

•  SME  Scepticism  and  Digital  Readiness:  SMEs  are  generally  "sceptical"  of  new  digital 
initiatives due to concerns about cost and a perceived lack of skills. A significant percentage 
of SMEs are "not completely ready" for digital adoption, with readiness varying by size and 

75 

 
sector.  Some  small  Economic  Operators,  for  example,  "do  not  even  have  a  website".  The 
level of feasibility for adoption depends on the EUBW's technological sophistication.  

•  Basic  Digitalisation  as  a  Prerequisite:  A  prerequisite  for  this  type  of  tool  is  that  "many 
SMEs  already  possess  a  basic  level  of  digitalisation".  If  this  basic  digitalisation  is  not  in 
place, the adoption process will be longer, though the tool itself could serve as an incentive 
for micro- Economic Operators to begin digitalising.  

•  Support and Training Needs: Any new digital tool like the EUBW would need to come with 
"capacity  building  and  training".  This  training  should  ideally  be  provided  by  "local 
Economic  Operators"  that  are  "close  to  Economic  Operators,"  offering  adaptive  training 
sessions  (e.g.,  in  the  evenings)  that  consider  language  barriers  for  European  Economic 
Operators.  

Trust Service Providers  

•  Price  as  a  Barrier  for  SMEs:  Price  is  identified  as  a  "barrier  for  SMEs".  Some  solution 
providers  consider  SMEs  a  "less  attractive  market"  due  to  their  lower  operational  volume 
purchasing power.  

•  Preferred  Pricing  Models  for  SMEs:  Discussions  with  stakeholders  indicate  that  SMEs 
favour a "low per-usage fee model with minimal onboarding friction". They also express a 
preference for a "simple monthly subscription with embedded functionality". One provider 
is developing a "tiered subscription model" with a base tier designed to be "accessible for 
SMEs," offering essential functionality with transaction limits.  

•  Hurdles  from  Provider  Perspective:  From  the  perspective  of  trust  service  and  solution 
providers, key hurdles to EUBW implementation include the costs of adoption and the risk 
of insufficient ecosystem-wide uptake. While the EUBW offers significant savings potential 
through automation of compliance and identity checks, these benefits can only be realised if 
the ecosystem adoption is widespread. 

76 

 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1.  PRACTICAL IMPLICATIONS OF THE INITIATIVE 

The European Business Wallets, in the context of the European Digital Identity Framework, aim to 
provide a seamless environment for EOs of different sizes to interact with PSBs at different levels 
of government (B2G/G2B), and with one another (B2B). At the same time, the EUBW will enable 
PSBs to achieve greater efficiency and cost-savings and to create synergies by automating manual 
and administrative processes and by streamlining the digital tools used to interact with EOs. 

EOs will be able to adopt the European Business Wallet by entering into a commercial agreement 
with  an  authorised  provider  and  will  obtain,  a  platform  for  secure  digital  identification  and 
authentication, data sharing, and legally valid notifications. 

EOs  will  face  one-off  costs  (training  and  onboarding,  activation  and  IT  implementation  and 
contracting  costs)  to  adopt  the  Business  Wallet  as  well  as  recurring  costs  (licensing  fees  and 
maintenance  costs)  to  use  the  Business  Wallet  in  their  everyday  operations.  Leveraging  the 
Business  Wallet  will  generate  direct  benefits  for  EOs  through  digitalisation  and/or  automation  of 
administrative  and  manual  activities  related  to  identification  &  authorisation,  exchange  of 
documents  and  information,  compliance  and  verification,  record  keeping  and  data  management, 
permissions and certification and cross-border coordination and recognition. 

Assuming  100%  adoption  of  the  European  Business  Wallet,  the  total  estimated  costs  for  all  EOs 
amounts to around €60.67 billion per year, split between around €33.43 billion of one-off costs and 
around €27.24 billion of recurring costs. On the benefits side, the annual direct benefits for all EOs 
are expected to total €205.82 billion. 

However, the costs and benefits of adopting and using the Business Wallet will vary depending on 
the size and digital maturity of the EO. 

For  a  microenterprise  with  fewer  than  10  employees,  such  as  a  local  craftsperson  or  independent 
consultancy,  adopting  the  EUBW  will  require  implementing  and  activating  a  wallet  service  and 
familiarising  with  its  use,  also  through  dedicated  trainings  (one-off  costs  per  microenterprise  are 
estimated  at  €620).  Recurrent  actions  will  be  limited  to  updating  credentials  when  they  expire. 
Costs are therefore expected to be relatively low (€500). Benefits are likely to be substantial, with 
annual  direct  benefits  estimated  at  €4,000:  micro-enterprises  will  save  significant  time  and 
expenses otherwise spent on paper documentation, intermediaries (e.g. accountants, notaries), and 
repeated interactions with multiple administrations. 

For a Small-Medium Enterprise with 10 to 250 employees, implementing the EUBW would require 
the definition of the contractual arrangements with the authorised Wallet provider, the application 
installation and configuration, limited or no  system  customisations, access  management, trainings 
and  onboarding  for  the  employees  that  are  expected  to  use  the  Business  Wallets.  After  the 
implementation and adoption of the instrument, recurring activities (potentially) offered by Wallet 
Providers  could  include  maintenance  and  ad  hoc  technical  support.  Annual  licensing  fees  (fixed 
based on the number of accounts requested and/or volume-based depending on the consumption of 
the  solution)  would  be  paid  by  the  SME  to  use  the  EUBW  and  (optionally)  to  get  access  to 
technical support. For SMEs, one-off costs are estimated at €2,600 and recurring costs at €5,000. 
These costs come with significant benefits for SMEs derived from the reduction of administrative 

77 

 
burdens, lower compliance costs (that are proportionally more significant than for corporates), and 
enhanced cross-border interactions. Annual direct benefits for SMEs are expected at €42,250. 

For  a  Corporate  with  more  than  250  employees,  implementing  the  EUBW  will  require  extensive 
collaboration with the selected Wallet provider for the installation and configuration of desktop and 
mobile applications, customisation of systems, possible integration of the Wallet with the various 
ERPs, CRMs and other IT systems and tools of the organisation, data management and governance, 
account  creations  and  access  management,  trainings  and  onboarding  of  the  employees  that  are 
expected  to  use  the  Wallet.  Contract  management  and  risks  assessment  activities  will  also  be 
needed.  After  the  implementation  of  the  Wallet,  corporates  will  likely  need  significant  assistance 
from the Wallet provider or other intermediaries on maintenance and technical support based on the 
Service  Level  Agreements  and  Service  Level  Objectives  agreed  with  the  Wallet  provider,  plus 
potentially  new  software  developments/updates  based  on  the  organisation’s  needs.  As  mentioned 
for the SMEs, licensing fees will apply. For corporates, one-off costs are estimated at €180,000 and 
recurring costs at €50,000. These costs come with significant benefits for corporates derived from 
the  reduction  of  administrative  burdens,  lower  compliance  costs,  facilitated  processes  to  identify 
and authorise the multitude of suppliers and partners corporates work with, securing and storing the 
large  amount  of  data  held,  enhanced  cross-border  interactions,  etc.  Annual  direct  benefits  for 
corporates are expected at €97,300. 

PSBs at EU, national, regional and local levels will also be directly affected. The initiative will help 
reduce  fragmentation  between  national  systems,  facilitate  cross-border  cooperation,  and  generate 
efficiency  gains  allowing  PSBs  to  improve  the quality  and  consistency of public service delivery 
across the Union. To achieve such benefits, which also depend on wide EO adoption, PSPs will be 
incurring costs. 

For PSBs, one-off costs relate mainly to training and onboarding, activation and IT implementation 
and  procurement  costs,  whilst  recurring  cost  to  licensing  fees  and  maintenance  costs..  The  cost 
methodology accounts for the different sizes of PSBs, ensuring that each can participate efficiently 
and  proportionately  in  the  deployment  of  the  European  Business  Wallets.  To  provide  an  overall 
picture  of  the  expected  investment,  figures  are  presented  as  aggregated  values  for  the  purpose  of 
this assessment. Overall, total costs for all PSBs are expected to amount to €7.33 billion per year, 
split between €6.18 billion of one-off costs and €1.15 billion of recurring costs. In return, PSBs will 
benefit from faster processing of applications, fewer errors in submitted documentation, and more 
efficient cross-border cooperation. This will lead to annual direct benefits of, on average, €199,600 
per PSB and total annual direct benefits for all PSBs of €19.13 billion in the theoretical scenario of 
100% usage. 

Providers of European Business Wallets will be subject to certain administrative and establishment 
requirements.  They  are  required  to  be  established  in  the  Union,  they  will  need  to  undergo  a 
notification  process  and  be  listed  in  a  List  of  Providers.  They  will  be  subject  to  organisational 
requirements  as  they  will  need  to  ensure  the  uniform  implementation  of  technical  and 
organisational  measures,  cooperate  with  supervisory  authorities,  inform  and  notify  users.  These 
requirements  entail  compliance  and  operational  costs.  However,  providers  will  gain  access  to  a 
rapidly  expanding  EU-wide  market  (see  in  the  table  below)  and  will  retain  freedom  to  integrate 
innovative  and  additional  features  with  a  flexible  approach  as  part  of  their  commercial  offering 
tailored to specific business needs. 

78 

 
 
2.  SUMMARY OF COSTS AND BENEFITS 

Table 16 – Overview of benefits: preferred option 

Description 

Amount (min) 

Amount (max) 

Comments 

Overview of Benefits (total for all PSBs and EOs) – Preferred option 

€58.42 BLN 

Direct benefits 

€168.79 BLN 

Based  on  range  4,  with 
75% usage rate. 

€10.15 BLN 

Indirect benefits 

Indirect  benefits  assessed  at 
minimum potential only 

– 
or 
of 

Cost-savings 
reduction 
elimination 
manual 
processes 

Economic 
opportunities 
and 
competitiveness 

market 

Trust 
resilience 

and 

€16.66 BLN 

Environmental 
sustainability 

Not quantified 

Indirect  benefits  assessed  at 
minimum potential only 

Indirect  benefits  assessed  at 
minimum potential only 

Table 17 – Overview of costs: preferred option 

Overview of costs: preferred option 

Economic Operators 

Public Sector Bodies 

Micro 

Small-Medium 

Corporates 

Small LAUs 
Mid-Large LAUs 
Central administrations (regional/national/EU) 

€520 

€1,400 

€14,000 

€28,531 

€100 

€800 

€150,000 

€26,890 

€0 

€400 

€16,000 

€9,121 

€500 

€5,000 

€50,000 

€11,956 

One-off 
costs   

Recurring 

Training 
and 
onboarding 
costs  
Activation 
and 
IT 
implementa
tion costs  
Contracting
/Procureme
nt costs 

Licensing 
fees 
and 
maintenanc
e 

3.  RELEVANT SUSTAINABLE DEVELOPMENT GOALS 

Table 18 – Relevant Sustainable Development Goals: preferred option 

Overview of relevant Sustainable Development Goals – preferred option 
Relevant SDG 

Expected progress towards the Goal 

Comments 

79 

 
 
 
 
 
 
  
  
  
  
  
 
Positive 

Positive 

SDG 8 – Promote sustained, 
inclusive and sustainable 
economic growth, full and 
productive employment and 
decent work for all 

SDG 9 – Build resilient 
infrastructure, promote 
inclusive and sustainable 
industrialization and foster 
innovation 

SDG 12 – Ensure 
sustainable consumption and 
production patterns 

Positive 

Expected improvements in the business 
environment, particularly for SMEs and 
microenterprises. This would encourage 
entrepreneurship, scale-up and 
competitiveness. 

Advances digital public infrastructures, 
supporting cross-border digital identity 
solutions and innovation in trust services. 

Further digitalisation of compliance and 
reporting processes is expected to reduce 
paper use and waste. 

80 

 
 
 
 
 
 
ANNEX 4: ANALYTICAL METHODS 

1.  SCOPE 

The total number of entities in the EU, covering both PSBs and EOs, was estimated based on data 
from literature from multiple sources128. 

The  number  of  PSBs  in  the  EU  was  estimated  at  95,825  combining  Local  Administrative  Units 
(LAUs)  and  a  representative  set  of  central  administrations  consisting  of  regional  administrations, 
national administrations, and European Union institutions, agencies, offices and bodies (EUIBAs). 
Of  this  total  figure,  95,068  correspond  to  LAUs  as  defined  in  the  LAU  classification  in  the 
Nomenclature  of  Territorial  Units  for  Statistics  (NUTS)129.  LAUs  were  further  divided  into  two 
categories: small LAUs130 (76.6% of all PSBs), and mid-large LAUs131 (22.6%). For 188 LAUs, it 
was  not  possible  to  derive  population  data132.  The  figure  of  757  PSBs  (0.8%),  relates  to  a 
representative  set  of  central  administrations,  drawing  on  proxies  to  estimate  the  sum  of  national 
central administrations133, regional central administrations134, and 79 EUIBAs135. 

Table 19 – Scope: number of PSBs in the EU 

Public Sector Bodies 
Central administrations (regional, national, EU) 
Mid-Large LAUs 
Small LAUs (<5.000 inhabitants) 
Total 

No. in the EU 
757 
21,658  
73,410 
95,825  

For  EOs,  the  figure  of  32,721,957  was  derived  from  Eurostat  data  2023136  and  split  into  three 
categories: microenterprises with fewer than 10 employees, SMEs with 10 to 250 employees137, and 

128 See Business Wallet Study, NTT Data, October 2025, Annex 3, 7.1.1., Table 21 and Table 23. 
129 Local administrative units (LAU) - NUTS - Nomenclature of territorial units for statistics - Eurostat. The data were 
also verified against the Barometer of Local Institutional Reforms in Europe LOCAL AUTHORITIES | Barometre.  
130 Amounting to 73 410. Defined as local administrations in municipalities with fewer than 5 000 inhabitants. 
131 Amounting to 21 658. Defined as local administrations in municipalities with more than 5 000 inhabitants. 
132  See  Business  Wallet  Study,  NTT  Data,  October  2024,  Annex  3,  7.1.1,  Table  21:  Distribution  of  Public 
Administrations by size. The 188 municipalities with unknown population data were distributed proportionally: 145 to 
Small LAUs and 43 to Mid-Large LAUs. 
133  434  national  central  administrations,  based  on  the  proxy  of  the  number  of  ministries  by  Member  States.  Source: 
European Institute for Gender Equality, 2024. https://eige.europa.eu/sites/default/files/wmid_mapping_natadmin_1.pdf  
134 
Classification 
administrations. 
https://ec.europa.eu/eurostat/documents/345175/629341/NUTS2021-NUTS2024.xlsx/2b35915f-9c14-6841-8197-
353408c4522d?t=1717505289640. The level at which regions are defined as administrative units can vary by Member 
State. 
135  https://european-union.europa.eu/institutions-law-budget/institutions-and-bodies_en.  The  number  of  EUIBAs  has 
been included in  the number of the central administrations calculated in the context of the Business Wallet Study. 
136 Eurostat data from 2023 were used, rather than more recent data from 2024, to ensure consistency with the Business 
Wallet Study, which relied on 2023 figures due to the lack of more up-to-date information on the intra-EU cross-border 
activity of EOs. 

regional 

Source: 

central 

NUTS 

244 

2 

81 

 
 
 
large corporates with more than 250 employees.  Microenterprises accounted for by far the largest 
share,  with  30,836,  373  entities  (94.2%  of  all  EOs).  SMEs  with  at  least  10  employees  numbered 
1,832, 523 (5.6%), while large corporates represented 53,061 entities (0.2%). 

Table 20 – Scope: number of EOs in the EU 

Economic Operators 
Micro (<10) 
SME (10-249) 
Large (250+) 
Total 

No. in the EU 
30,836,373 
1,832,523 
53,061 
32,721,957 

2.  ESTIMATING THE ADOPTION RATE FOR PSBS AND EOS 

To  estimate  the  adoption  rate  of  European  Business  Wallets  by  PSBs,  which  are  expected  to 
enable  the  use  of  the  minimum  functionalities  of  the  European  Business  Wallets  by  EOs,  it  was 
assumed that adoption by PSBs is 100% irrespective of EO adoption ranges138.  

In  the  accompanying  study  to  this  Staff  Working  Document,  a  methodology  was  developed139 to 
assess the potential adoption of the EUBW by PSBs based on geography, maturity of digital public 
services  for  businesses  and  pre-filled  form  indicators  (as  scored  in  the  DESI  dashboard),  and 
whether  the  Member  State  in  question  is  an  early  adopter  of  the  EUDI  wallet.  However,  the 
resulting  classifications  were  not  used  further  but  have  been  retained  in  the  study  for  future 
reference on capturing the complexities may vary across Member States. 

The adoption rate of EOs was considered on a progressive scale of ranges, from a conservative low-
adoption case (range 1) to a universal adoption scenario (range 4), with intermediate cases (ranges 2 
and 3) reflecting progressively higher levels of uptake. 

A dedicated methodological approach is applied to estimating the adoption rate of EOs in the most 
conservative  scenario,  range  1,  based  on  a  readiness  index  of  EOs  designed  to  assess  the 
likelihood  of  voluntary  adoption  of  the  European  Business  Wallet.  This  readiness  index  is  a 
composite  indicator,  referring  to  different  categories  of  EOs,  and  built  around  two  drivers:  (i) 
whether  the  EO  operates  across  borders  within  the  EU140  and  (ii)  the  extent  to  which  the  EO  is 
digitalised141. Literature sources provided the data for all drivers and categories142 except one: the 

137 The new category of “SMEs with 10 to 250 employees” was created by merging two categories that are normally 
distinguished  in  Eurostat  classifications,  namely  “SMEs  with  10  to  49  employees”  and  “SMEs  with  50  to  250 
employees”. This aggregation was made for the purposes of the present analysis in order to simplify the assessment of 
costs and benefits for the European Business Wallets. 
138 See Business Wallet Study, NTT Data, October 2025, Annex 3, 7.1.1. 
139 See  Business Wallet Study, NTT Data, October 2025, Annex 3, 7.1.2., Box 6: Considerations on MS readiness to 
adopt the EUBW. 
140 Estimate based on the percentage of EOs with intra-EU cross border activities. Micro (<10 employees): 10%; Small 
(10-49): 41%; Medium (50-249): 64%; Large (≥250) 85%. https://doi.org/10.2908/EXT_TEC01  
141  Estimate  based  on  the  percentage  of  EOs  with  high  and  very  high  digital  intensity.  Micro  (<10  employees):  not 
available; Small (10-49): 28%; Medium (50-249): 58%; Large (≥250) 86%. https://doi.org/10.2908/ISOC_E_DII 

82 

 
 
 
percentage of highly digitalised microenterprises, for which no data were available. In this case, the 
figure  was  derived  by  projecting  the  ratio  between  driver  (ii)  and  driver  (i)143.  The  resulting 
readiness index ranges from 9% for microenterprises to 86% for large corporates. Applied across 
category, this corresponds an overall readiness rate of 10.43%144. for EOs. This figure was taken as 
a reference for range 1. 

If range 1 considers that only EOs with a combination of intra-EU cross-border activity and high 
levels of digitalisation would adopt the European Business Wallets, ranges 2  and 3 are set with a 
top-down approach reflecting progressive levels of adoption of the EUBW. 

Range  4  is  the  case  of  adoption  by  75%  of  the  32,721,957  EOs.  The  75%  threshold  represents  a 
realistic  estimate  of  expected  adoption  in  a  best-case  scenario.  It  is  also  consistent  with  industry 
expectations as taken from the DigitalEurope target KPI for the percentage of European businesses 
to be using business wallets for cross-border legal, administrative and commercial interactions by 
2030145. 

3.  ESTIMATING COSTS: OVERVIEW OF THE COST CATEGORIES 

The  annual  costs  for  PSBs  and  EOs  using  the  European  Business  Wallet  were  estimated  on  the 
basis of desk research of publicly available information, studies and reports from the literature, the 
European Business Wallet support study146, expert input, as well as internal studies147. They were 
then  grouped  into  one-off  costs  (training  and  onboarding,  activation  and  IT  implementation, 
procurement)  and  recurring  costs  (licensing  fees  and  maintenance).  For  PSBs,  the  size  of 
administrations was taken into account148 and for the cost estimations, obtained by desk research, 
the PSBs considered where those having EOs in their target audience. 

On training and onboarding costs, the analysis of the Business Wallet study149 focused on one-off 
expenditure associated with employee training and familiarisation. For PSBs, the following formula 

142  See  Business  Wallet  Study,  NTT  Data,  October  2025,  Annex  3,  7.1.1.,  Table  23:  Overview  of  the  Economic 
Operators’ landscape in terms of trade engagement levels and digitalisation. 
143 Eurostat data for micro enterprises is not available; the 7% figure is an estimate based on the digitalisation-to-cross-
border  activity  ratio  observed  in  small  enterprises  (0.68),  accounting  for  the  empirical  observation  that  the  ratio 
diminishes with the size of the EO. 
144  The readiness index is calculated an average between driver (i) and driver (ii). The categorisation of SMEs (10-250 
employees) is split into SMEs (10-49) with readiness index of 35%, and SMEs (50-250) with readiness index of 61%. 
See  Business  Wallet  Study,  NTT  Data,  October  2025,  Table  23:  Overview  of  the  Economic  Operators’  landscape  in 
terms of trade engagement levels and digitalisation. 
145  The  DigitalEurope  KPI  is  linked  to  one  of  a number  of  pan-European  scalable  tech  investment  projects  aimed  at 
different  sectors,  specifically  public  administration.  The  projects  are  part  of  a  European  AI  &  Tech  Declaration 
launched  in  September  2025  and  championed  by  DigitalEurope  to  spur  concrete  action  to  strengthen  Europe’s 
competitiveness, innovation capacity and digital sovereignty. This commitment is materialised in a letter signed by 41 
CEOs 
letter: 
https://www.digitaleurope.org/the-ceo-letter/.  The  initiative  calls  for  the  deployment  of  a  European  Digital  Business 
Wallet  under  the  EU  Digital  Identity  Framework;  the  mandatory  use  of  such  wallets  by  the  public  sector;  full 
integration  with  national  registries,  EUDI  wallet  infrastructure,  trust  services  and  sectoral  credential  authorities;  a 
standardised  EU-wide  mandate  management  system;  technical  integration  with  other  systems;  and  the  launch  of  a 
dedicated EU funding programme. 
146 Business Wallet Study, NTT Data, October 2025. 
147 Estimates based on internal research, using publicly available sources and expert input.  
148 Three categories were considered: Small Local Administrative Units (LAUs) corresponding to municipalities with 
fewer  than  5,000  inhabitants,  Mid-Large  LAUs,  and  central  administrations  corresponding  to  regional  and  national 
governmental authorities and administrations 
149 Business Wallet Study, NTT Data, October 2025, Section 7.1.3. 

leading  digitalising  companies  and 

trade  associations.  See  here 

from  Europe’s 

for 

83 

 
 
was  applied:  Training  Cost  =  Tariff  *  Time  *  Quantity,  where  the  Tariff  is  the  cost  per  hour  of 
training, Time is the average number of hours spent on training, and Quantity is the average number 
of employees per entity. 

On this basis, the weighted average training cost per PSB was estimated at €28,531, derived from 
an hourly salary of €19.55150 (Tariff) an average of 10 hours151 of training (Time) and a weighting 
based  on  the  number  of  civil  servants  per  type  of  PSB  entity  (ie  small  local  authority,  mid-large 
authorities and central administrations) 152. The total estimated training and onboarding costs for all 
PSBs  amounts  to  €2.73  billion.  For  EOs,  the  calculation  was  adjusted  by  applying  a  multiplier 
reflecting  the  share  of  employees  engaged  in  administrative  roles.  For  each  category  of  EOs,  the 
hourly  salary  was  assumed  to  be  €33.5153  (Tariff).  And  the  average  training  time  10  hours154 
(Time). Applying several parameters related to the EO category155 gave an estimated annual cost of 
€520  for  microenterprises,  €1,400  for  larger  SMEs  and  €14,000  for  large  corporates.  In  total, 
training and onboarding costs for EOs were estimated at €19.34 billion per year. 

With  regard  to  one-off  costs,  activation  and  IT  implementation  costs  were  assessed  through  an 
internal analysis156 that took into account a number of elements, not all of which are applicable to 
smaller  entities.  These  included  the  installation  of  desktop  and  mobile  applications,  options  for 
system  customisation,  creation  and  management  of  accounts,  integration  with  business  process 
automation  software  such  as  Enterprise  Resource  Planning  (ERP)  and  Customer  Relation 
Management  (CRM)  systems,  and  the  set-up  and  management  of  databases.  For  PSBs,  the 
activation  and  IT  implementation  costs  are  on  average  €26,890157.  For  EOs,  estimations  gave  an 
average of €382 per entity, divided into €100 per microenterprises158, €800 for larger SMEs159, and 
€150,000 for corporates160. 

150 Based on the European Public Administration Network (EUPAN) and with support of labour force data, the average 
hourly wage was estimated based on an average monthly remuneration for civil servants of  €3.170 per month in 2024 
distributed in 40 hours per week. 
151 From the survey conducted in the context of the Business Wallet Study. 
152  See  Business  Wallet  Study,  NTT  Data,  October  2025,  Annex  3,  7.1.1.,  Table  25:  Annual  costs  for  Public 
Administrations. 
153 Based on a 2018 survey conducted on 12.000 employees in Germany by PwC. 
154 Based on the annual report on European SME 2023/24, and on Eurostat. 
155 The average number of employees per entity was set at 1.54 for microenterprises, 59.62 for SMEs and 1 035.38 for 
large corporates. The proportion of staff involved in  administrative tasks was estimated at 100% for microenterprises, 
7% for SMEs and 4% for large corporates. See Business Wallet Study, NTT Data, Annex 3, 7.1.2., Table 27: Annual 
costs for Economic Operators. 
156 Estimates based on using publicly available sources and expert input.  
157 For each category of PSB the estimations were conducted based on the number of FTEs needed to work on all the 
aspects of IT implementation and integration 
158 On the assumption that most would rely on a web-based or mobile application requiring only minimal installation 
and configuration, without links to process automation tools. 
159  This  was  based  on  the  proxy  of  current  market  prices  charged  by  specialised  providers  for  identification  and 
authentication functionalities, with the lower bound representing a reduced set of onboarding and setup functionalities 
and assumed to be 1/5 of what could be charged for a wider set of services. Information obtained via desk research of 
publicly available information. Specialised providers considered (Aruba, eHerkenning, Intesi Group, Criipto, Namiral, 
DocuSign,  Infocert)  are  cited  solely  for  illustrative  purposes;  their  mention  does  not  imply  any  preference  or 
endorsement by the European Commission. 
160 For corporates, implementation is significantly more complex. Such organisations typically require coordinated roll-
outs  across  numerous  terminals,  tailor-made  configurations,  management  of  multiple  accounts  with  differentiated 
access  rights,  and  integrations  with  proprietary  IT  systems.  Multiple  databases  may  also  be  required,  supported  by 
dedicated  project  teams.  Based  on  external  benchmarks,  IT  set-up  and  integration  costs  were  estimated  based  on 
external evidence on the implementation of advanced digital signature and authentication solutions, where setup costs 

84 

 
 
 
Procurement  costs  cover  the  preparation  of  selection  procedures  for  identifying  the  European 
Business  Wallet  providers.  For  PSBs,  they  were  estimated  at  €9,062  per  entity.  For  EOs, 
contracting costs were considered to be negligible for microenterprises, and they were estimated at 
€400 for larger SMEs161, and at €16,000 for corporates162. 

Licensing  fees  represent  recurring  costs  for  the  use  of  EUBW  services,  and  they  include 
maintenance  cost.  For  PSBs,  annual  licensing  fees  were  estimated  at  an  average  of  €11,956  per 
entity.  For  EOs,  annual  licensing  fees  averaged  €832  per  entity  and  were  estimated  at:  €500  for 
microenterprises163, €5,000 for SMEs, and €50,000 for corporates. 

4.  ESTIMATING DIRECT BENEFITS 

As presented in section 6.2, direct benefits, for the purpose of the analysis of the Business Wallets 
study164,  are  defined  as  cost-savings  derived  from  the  digitisation  or  automation  of  manual 
administrative activities. Thes relate to a number of categories of administrative activities expected 
to be affected by the European Business Wallets165. 

The estimation  of  current  administrative costs  associated with  these activities, for both  PSBs and 
EOs, was based on the following formula used to quantify administrative burdens: 

Administrative Cost=∑(P×Q) 

Where: 

•  P (Price) = Tariff × Time 
•  Q (Quantity) = Number of entities × Frequency 

➔  Administrative Cost=∑(Tariff×Time×Nº of entities×Frequency) 

This  approach  was  applied  across  the  different  categories  of  administrative  activities.  The  tariff 
corresponds to the average hourly wage. For PSBs, it was estimated at €19.8 per hour, based on the 
weighted  average  hourly  labour  cost  for  civil  servants  across  all  EU  Member  States.  For  EOs,  it 
was estimated at €33.5 per hour, based Eurostat data for average hourly labour cost in the EU. Time 
refers  to  the  average  number  of  hours  required  to  complete  each  activity.  For  PSBs,  data  were 
obtained from the survey of the Business Wallet study166 and from secondary sources for EOs167. 

are reported around EUR 80 000, with significantly higher expenditure once integration and transaction-based licensing 
are considered. See, for example: Forrester Consulting, The Total Economic Impact™ of Adobe Acrobat Sign, 2022. 
161 Based on expected costs for preparation of the contracts and legal costs. 
162 Based on the expected costs of the legal or procurement departments. 
163 This estimate was based on existing 'off-the-shelf' subscription models available to professionals. A range between 
50  EUR  and  500  EUR  per  year  was  identified  assuming  basic  Wallet  functionalities  and  a  limited  volume  of 
transactions. However prices may vary in function of business needs and according to market dynamics. 
164 See Business Wallet Study, NTT Data, October 2025, Section 7.1.3 Estimating benefits. 
165 See Table 7 in Chapter 6, Section 2. 
166  From  responses  to  the  question:  “Approximately,  how  much  time  does  one  person  take  to  perform  this  activity 
once?”. See Business Wallet Study, NTT Data, October 2025, Section 7.1.3 Estimating benefits. 
167  Existing  literature  considered  by  the  Business  Wallet  study  included:  Directorate  General  for  Inter-Ministerial 
Coordination  Department  of  the  Presidency,  Government  of  Catalonia.  (2017).  The  Unit  Costs  System  for  the 
quantification 
at: 
way 
https://canalempresa.gencat.cat/web/.content/00_subhome_fue/transparencia-i-
qualitat/Documents_visita_estudi_bcn/PAULA-ORTI-i-DAVID-RAMOS-Quantification-administrative-burdens.pdf 

administrative 

Available 

measure. 

burdens: 

simple 

of 

to 

a 

85 

 
 
 
Frequency refers  to  the  average number of times  each activity  is  carried  out annually. Data  were 
obtained from the survey for both PSBs and EOs168. 

The  resulting  direct  benefits  were  calculated  as  a  weighted  average  of  €199,600  for  PSBs169  and 
€6,290  for  EOs.  For  EOs,  segmentation  by  enterprise  size  enabled  a  more  accurate  estimation  of 
costs  and  benefits  representative  of  the  European  context.  The  resulting  weighted  averages  were 
€4,000  for  microenterprises,  €42,250  for  other  SMEs,  €97,300  for  corporates  with  >250 
employees170. 

5.  RANGES OF ADOPTION FOR ECONOMIC OPERATORS AND NET DIRECT BENEFITS 

Chapter  7  described  the  approach  for  benefit  calculation,  according  to  different  adoption  ranges 
referred  to  economic  operators  taking  up  the  instrument.  If  the  adoption  rate  is  set  at  100%  for 
PSBs, EOs have four possible adoption ranges: 10%, 33%, 50%, and 75%. The direct benefits are 
estimated as a function of adoption rates by EOs. For the purpose of the cost-benefit analysis, the 
following definitions were used: 

•  Adoption  rate:  the  share  of  stakeholders  that  will  have  adopted  the  EUBW.  Adoption 
automatically generates costs regardless of whether the tool is actively used in interactions 
with other EUBW owners. 

•  Usage rate: the effective use of the EUBW in practice, derived from the engagement EOs 
have with PSBs. It is calculated by multiplying the different levels of EO adoption rates by 
the  PSB  adoption  rate.  Usage,  rather  than  adoption  alone,  determines  the  extent  to  which 
stakeholders can realise benefits, since adoption without actual use yields no cost savings. 

The adoption rate for PSBs is assumed to be at 100%, reflecting the requirement for PSBs to enable 
the  use  of  the  core  functionalities  of  European  Business  Wallets  by  EOs  (i.e.,  proving  identity, 
signing/sealing,  submitting  documents,  or  receiving  official  notifications).  For  EOs,  a  set  of 
adoption ranges has been defined to capture progressively higher potential levels of adoption: 

•  Range  1  (10.43%)  represents  the  estimated  share  of  EOs  whose  readiness  to  adopt  the 
EUBW is based on a combination of two factors: activity across-borders in the EU and high 
digital intensity171 

•  Range 2 (33%) represents the assumption that one third of EOs will adopt the EUBW. This 
range  is  consistent  with  the  threshold  used  to  estimate  adoption  in  the  2021  Impact 
Assessment172 

168  From  responses  to  the  question:  “How  frequently  is  this  activity  performed  in  your  organisation?”.  See  Business 
Wallet Study, NTT Data, October 2025, Section 7.1.3 Estimating benefits. 
169 See Business Wallet Study, NTT Data, October 2025, Section 7.1.3 Estimating benefits, Table 29: Annual benefits 
by category for an average Public Administration. 
170 See Business Wallet Study, NTT Data, October 2025, Section 7.1.3 Estimating benefits, Table 31: Annual benefits 
by category for Economic Operators 
171  Calculation  based  on  readiness  index  combining  rates  of  highly  digitised  companies  and  of  companies  operating 
across borders within the EU. See Business Wallet Study, NTT Data, October 2025, Annex 3, Table 23 (Overview of 
the Economic Operators’ landscape in terms of trade engagement levels and digitalisation) 
172  The  2021 Impact  Assessment  had  three  intermediary ranges:  20%,  33%,  67%.  The  range  of  20%  was  substituted 
with the 10.43% resulting from the analysis of the support study, and the range of 67% was substituted with the 50% 
representing  a  near  midpoint  between  33%  and  the  maximum  threshold  of  75%.  Regarding  the  2021  Impact 
Assessment, see the section on economic impacts of the Study to support the impact assessment for the revision of the 
eIDAS regulation, PWC and DLA Piper, 2021, pages 135 and following. https://data.europa.eu/doi/10.2759/671740 

86 

 
 
•  Range 3 (50%) represents the assumption that one half of EOs will adopt the EUBW. 

•  Range 4 (75%) represents a realistic upper bound adoption target of the EUBW by EOs, and 
is  also  in  line  with  industry  ambitions  as  derived  from  the  DigitalEurope  KPI  for  use  of 
business wallets by 2030173 

So, for example, where there would be a 75% adoption rate by EOs, the usage rate for PSBs would 
also  be  75%,  as  it  is  the  PSB  adoption  rate  of  100%  multiplied  by  the  75%  EO  adoption  rate. 
Finally, the total achievable level of benefits is a theoretical scenario of 100% adoption by all EOs. 

This  section  provides  an  overview  of  the  variation  of  annual  direct  benefits  as  the  EO  adoption 
scenario move progressively from the most conservative range 1 to range 4 of adoption by all EOs. 
For this  purpose, only  maximum  net  direct  benefits are considered.  A full  overview of all ranges 
and the with all information on the numbers of stakeholders and the respective average costs and 
benefits for EOs and PSBs is provided at the end of this Annex. 

Under  range  1,  where  only  10.43%  of  EOs  adopt  the  instruments,  total  net  direct  benefits  (i.e. 
benefits  less costs)  are positive (€9.82 billion) as of the first  year after adoption. However, PSBs 
record negative net benefits in the initial phase namely the first year after adoption (–€5.33 billion), 
as one-off adoption and onboarding costs outweigh the gross benefits. This trend reverses as of year 
two, once the one-off costs have been absorbed, resulting in positive net benefits for PSBs (€0.85 
billion). By contrast, EOs generate substantial positive net benefits from the outset (€15.15 billion 
in year one, increasing to €18.64 billion in year two). 

Table 21– Annual net direct benefits:~10% usage (range 1) 

Net benefits 
(€ bn ) 

Gross benefits 
Costs (one-off) 
Costs (recurring) 
Y1 net benefits 
Y2 net benefits 

PSBs 
2.00 
6.18 
1.15 
-5.33 
0.85 

Range 1 
EOs 
21.48 
3.49 
2.84 
15.15 
18.64 

TOTAL 
23.48 
9.67 
3.99 
9.82 
19.49 

Despite these overall net benefits, usage rates would remain fairly low under this range. With only 
10.43% usage by both PSBs and EOs, the EUBWs would not achieve the critical scale required to 
transform administrative processes or to reach the aimed levels of burden reduction. The absence of 
widespread use in turn would prevent the establishment of a trusted, standardised environment for 
business–government interactions across the Union. 

While  range  1  demonstrates  that  the  EUBWs  can  generate  positive  net  benefits  even  under 
conservative conditions, its limited scale makes it suboptimal. Efficiency is not fully achieved, as 

173 Derived from the proposed DigitalEurope target KPI for business wallet use in cross-border legal, administrative and 
commercial  interactions  by  EU  businesses  by  2030;  see:  https://www.digitaleurope.org/public-administration/.  See 
more in Annex 4. 

87 

 
 
 
costs  exceed  benefits  for  PSBs  in  the  short  run,  and  effectiveness  is  constrained,  since  relatively 
low  usage  prevents  the  generation  of  sufficient  network  effects.  The  policy  objectives  would 
therefore be only partially met. 

Under range 2, where one third of EOs adopt the EUBW, all categories show positive net benefits 
as  of  the  second  year.  For  PSBs,  the  net  benefits  are  negative  at  €1.02  billion  in  year  one  and 
become positive at €5.16 billion in year two. EOs register even stronger results, with net benefits of 
€47.94 billion in year one, rising to €59.97 billion in year two. Overall, total net benefits amount to 
€46.92 billion in year one and €64.13 billion in year two. 

Table 22– Annual net direct benefits:33% usage (range 2) 

Net benefits 
(€ bn ) 

Gross benefits 
Costs (one-off) 
Costs (recurring) 
Y1 net benefits 
Y2 net benefits 

PSBs 

6.31 
6.18 
1.15 
-1.02 
5.16 

Range 2 

EOs 

67.96 
11.03 
8.99 
47.94 
58.97 

TOTAL 

74.27 
17.21 
10.14 
46.92 
64.13 

Compared  with  range  1,  the  higher  usage  rate  of  about  one  third  (33%)  for  both  PSBs  and  EOs 
translates  into  substantially  larger  benefits.  This  usage  rate  ensures  that  PSBs  reach  a  sufficient 
level  of  usage  to  recover  their  initial  costs  and  realise  additional  gains.  At  this  level  of  usage,  at 
least  9  million  microenterprises  are  included174,  alongside  larger  SMEs  and  corporates.  The 
involvement  of  microenterprises  is  key,  given  their  centrality  to  the  EU  economy,  but  with  an 
average size of only 1.5 employees they frequently lack dedicated staff for compliance. As a result, 
they are disproportionately affected by administrative requirements. Time spent on administrative 
tasks  reduces  the  resources  that  microenterprises  can  devote  to  business  development,  revenue 
generation and innovation, and in some cases affects their overall resilience. The wide participation 
of  microenterprises  therefore  broadens  the  base  of  users  and  creates  stronger  network  effects, 
making the EUBW more effective as a standard tool for business–government interactions. 

In range 2, positive net  benefits  are delivered for all categories, combined with  a critical  level  of 
adoption  that  enables  PSBs  to  recover  initial  costs  while  at  the  same  time  ensuring  wide 
participation  by  microenterprises.  The  scale  of  benefits  and  the  emergence  of  stronger  network 
effects  make  this  range  a  more  favourable  outcome  than  range  1,  while  still  leaving  significant 
room  for  further  efficiency  and  effectiveness  gains  in  higher  ranges.  As  a  result,  the  policy 
objectives,  e.g.,  simplification,  cost  reduction,  and  the  creation  of  a  trusted  EU-wide  business 
identity infrastructure, are partially met. 

174  This  calculation  reflects  the  composition  of  EOs:  out  of  a  total  of  32,721,957  economic  operators,  53,061  are 
corporates  with  more  than  250  employees  and  1,832,523  are  SMEs  with  10–249  employees.  The  remainder  are 
microenterprises with fewer than 10 employees, representing over 94% of all EOs. 

88 

 
 
 
 
Under range 3, where all PSBs and about one half (50%) of EOs adopt the instrument, net benefits 
increase substantially compared with range 2. PSBs record positive net benefits of €2.24 billion in 
year one, rising to €8.42 billion in year two. EOs generate net benefits of €72.63 billion in year one 
and €89.35 billion in year two. Overall, total net benefits amount to €74.87 billion in year one and 
€97.77 billion in year two. 

89 

 
 
 
Table 23– Annual net direct benefits:50% usage (range 3) 

Net benefits 
(€ bn ) 

Gross benefits 
Costs (one-off) 
Costs (recurring) 
Y1 net benefits 
Y2 net benefits 

PSBs 

9.57 
6.18 
1.15 
2.24 
8.42 

Range 3 
EOs 
102.97 
16.72 
13.62 
72.63 
89.35 

TOTAL 
112.54 
22.90 
14.77 
74.87 
97.77 

This higher level of adoption consolidates the efficiency gains already observed in range 2, while 
further  strengthening  network  effects.  The  EUBW  becomes  more  effective  as  a  standard  tool  for 
business–government interactions across the Union, with a significantly larger scale of benefits. 

Range 3 ensures positive net benefits for all categories, with PSBs recovering costs from the outset 
and EOs achieving very large gains. Stronger network effects and a broader user base mean that the 
EUBW  goes  towards  substantially  meeting  the  policy  objectives  and  moves  closer  to  their  full 
achievement. 

The assumption of 75% EO adoption leads to range 4, with all PSBs adopting the instrument, and a 
corresponding usage rate of 75% for both.  

Table 24– Annual net direct benefits:75% usage (range 4) 

Net benefits 
(€ bn ) 

Gross benefits 
Costs (one-off) 
Costs (recurring) 
Y1 net benefits 
Y2 net benefits 

PSBs 
14.35 
6.18 
1.15 
7.02 
13.20 

Range 4 

EOs 
154.45 
25.08 
20.43 
108.94 
134.02 

TOTAL 
168.80 
31.26 
21.58 
115.96 
147.22 

This  range  is  fully  aligned  with  the  policy  objectives  and  the  intervention  logic,  as  it  implies  the 
inclusion  of  the  entire  business  community  and  the  widespread  take-up  of  the  instrument. 
Financially, the effect is significant: participation by all categories of EOs is essential to unlock the 
highest  level  of  benefits.  Range  4  generates  –  by  a  considerable  margin  –  the  largest  annual  net 
benefits  annually,  both  in  the  first  year  at  €115.96  billion  and  in  subsequent  years  at  €147.22 
billion.  Therefore,  range  4  maximises  efficiency  and  effectiveness  and  helps  to  fully  achieve  the 
objectives  of  the  proposal.  Existing  Union  initiatives  for  digital  transformation  and  capacity-
building, which can help alleviate training and adaptation costs, could support the attainment of the 

90 

 
 
 
highest  levels  of  adoption  and  usage  of  the  EUBW,  thus  reinforcing  the  maximisation  of  the 
benefits. 

It  should  also  be  noted  that  SMEs  are  well  positioned  to  benefit  from  usage  of  the  EUBW.  In 
particular, the overall cost–benefit balance is especially favourable to them: total costs (one-off and 
recurring) are estimated to represent only around 24% of the direct benefits, and as of year two the 
cost-benefit ratio further reduces to 12%, implying significant savings potential. By comparison, in 
year 2, corporates’ cost-benefit ratio is 51%. 

6.  TEN-YEAR COST-BENEFIT ANALYSIS 

The  Cost-Benefit  Analysis  presented  so  far  focuses  on  the  first  two  years  of  implementation  and 
use of the European Business Wallet. For a long-term perspective, an additional analysis has been 
conducted  over  a  10-year  period.  This  time  horizon  is  aligned  with  methodologies  commonly 
applied  in  EU  impact  assessments  for  comparable  initiatives  —  such  as  the  European  Digital 
Identity (EUDI) framework175. This duration is considered appropriate for capturing the medium- to 
long-term effects of digital infrastructure projects, enabling a comprehensive evaluation of both the 
initial adoption impacts and the sustained benefits over time. 

With regard to direct benefits, the maximum scenario has been considered (in line with the benefits 
assessment  for  the  different  ranges  presented  above)  and  Range  4  at  75%  adoption  for  EOs  has 
been adopted (given the long-term perspective of the analysis and facilitating comparisons with the 
main  figures  presented in Chapter 6). Benefits  are kept  constant  over the 10-year time horizon at 
€169bn, of which €14bn for PSBs and €155bn for EOs. 

With regard to costs, one-off costs (total of €31bn) apply in year 1 only, while recurring costs (total 
of €22bn) apply from year 1 to year 10 included.  

Total net benefits amount for €116bn in Year 1 and €147bn from Year 2 to Year 10.  

To  calculate  the  Net  Present  Value  (NPV)  of  the  10-year  net  benefits  for  PSBs  and  EOs,  a  5% 
nominal  discount rate has been  applied. This  rate is  composed of: a 3% real  social discount rate, 
consistent  with  the  European  Commission’s  Better  Regulation  Guidelines  and  commonly  used  in 
Regulatory Impact Assessments (RIAs) across the EU; a 2% annual inflation adjustment, reflecting 
the  European  Central  Bank’s  medium-term  inflation  target.  The  NPV  for  PSBs  is  estimated  at 
€96bn, while the NPV for EOs is estimated at €1,011bn. This results in a total NPV of €1,107bn. 

Table 25– Cost-benefit Analysis over a 10-year time horizon 

175  European  Commission.  (2021).  Study  to  support  the  impact  assessment  for  the  revision  of  the  eIDAS  regulation. 
Available at:  https://digital-strategy.ec.europa.eu/en/library/study-support-impact-assessment-revision-eidas-regulation 

91 

PSBsEOsTOTALPSBsEOsTOTALGross Direct benefits (max, range 4)14.34          154.45        168.79        14.34          154.45        168.79        One-off costs6.18            25.08          31.25          -             -             -             Recurring costs1.14            20.43          21.57          1.14            20.43          21.57          Total Costs7.32            45.50          52.82          1.14            20.43          21.57          Net Benefits7.02            108.95        115.97        13.20          134.02        147.22        10-YEAR CBA(€ bn)YEAR 1YEAR 2-10 
 
 
 
7.  SURVEY AND EXPERT INTERVIEWS 

As  part  of  the  support  study  for  the  European  Business  Wallet,  evidence  was  gathered  through  a 
dedicated online survey and in-depth interviews with stakeholders. 

The  survey  targeted  primarily  members  of  the  Large-Scale  Pilot  projects176,  given  their  expertise 
and  interest  in  digital  identity,  and  was  also  extended  to  other  relevant  stakeholders.  It  collected 
quantitative and qualitative information on: 

the profile of responding organisations (type, size, cross-border activities); 
the burden of administrative activities and the effort required to perform them; 

• 
• 
•  expected  benefits  from  a  European  Business  Wallet,  including  potential  cost  reductions 

from digitalisation and automation; 

•  willingness to adopt a cloud-based solution; and 
•  open comments and follow-up availability. 

In  total,  340  stakeholders  were  reached  and  65  responses  were  received  (a  19%  response  rate), 
including economic operators, public administrations, associations, and educational institutions. 

The survey evidence was complemented by 14 in-depth interviews with selected stakeholders (out 
of  40  invited),  covering  associations,  solution  providers,  and  public  administrations.  These 
interviews  provided  more  detailed  insights  on  administrative  burdens,  potential  cross-border 
simplification, use cases, adoption costs, and possible business models177. 

8.  LIMITATIONS TO THE ANALYTICAL METHODS 

The Cost-Benefit Analysis offers a structured assessment of the potential  economic impact of the 
European Business Wallet (EUBW) and is grounded in available public data, empirical evidence, 
and  stakeholder  input.  However,  given  the  ambitious  scope  of  this  Cost-Benefit  Analysis—
covering a diverse and large spectrum of stakeholders and synthesizing complex assessments into 
actionable insights—certain limitations are inherent. These include the limited availability of public 
data  for  example  on  cost  structures,  the  lack  of  comparable  benchmarks  with  similar  digital 
solutions  in  the  European  market  and  the  challenges  in  approximating  an  advance  estimate  of 
market-driven aspects  such as licensing fees, and the need to rely  on average values  across large 
and heterogeneous stakeholder segments.  

For  the  estimation  of  the  direct  benefits,  the  methodology  defined  for  the  calculation  of  the 
minimum reflects the savings potential expected by each stakeholder category, and a limitation in 
that  regard  is  represented  by  a  relatively  small  number  of  survey  responses,  complemented  by 
additional research to mitigate against any risks arising from the sample size. 

For  public  sector  bodies,  weighted  averages  are  used  for  both  costs  and  benefits  to  allow  for  the 
calculation of net benefits. While it has been possible to segment the costs by size of PSB on the 
basis  of  headcount  into  national  and  regional  administrations,  large  municipalities,  and  small 
municipalities, the benefits are segmented by efficiency levels, as size-based data is unavailable and 

176 See Large Scale Pilots on European Commission website. 
177 See Business Wallet Study, NTT Data, October 2025, Annex 5: Stakeholder Consultation Synopsis. 

92 

 
 
 
efficiency is the key differentiating factor. Because it was not possible to have more granular data 
about PSB’s benefits by size, the presentation of the costs and benefits is limited to the weighted 
average to ensure comparability. 

Assumptions regarding adoption and usage are informed by a dedicated methodological approach, 
the  previous  2021  Impact  Assessment  and  stakeholder  positions,  though  future  patterns  may  be 
influenced  by  political,  technical,  or  behavioural  factors  beyond  the  model’s  reach,  thus  overall 
affecting the direct benefit estimates. Particularly, the estimation of range 1 reflects a conservative 
assessment on the likelihood of EOs adopting the instrument, but it should not be interpreted as a 
minimum adoption scenario. Moreover, the mapping of additional and indirect benefits, including 
those  identified  for  quantitative  estimations,  are  not  intended  to  be  exhaustive,  and  some  overlap 
may occur across direct, additional, and indirect benefit categories. 

93 

 
 
Table 25 – Overview of net benefits across ranges, as derived from average costs of different stakeholder groups 

Public Sector Bodies 

Economic Operators 

Total 

Range 1 

Range 2 

Range 3 

Range 4 

Range 1 

Range 2 

Range 3 

Range 4 

Range 1 

Range 2 

Range 3 

Range 4 

10.43% 

33% 

Gross benefits (€bn) 

1.99 

6.31 

50% 

9.56 

75% 

10.43% 

33% 

50% 

75% 

10.43% 

33% 

50% 

75% 

14.35 

21.48 

67.96 

102.97 

154.45 

23.47 

74.27 

112.53 

168.79 

Costs (one-off) (€bn) 

-6.18 

-6.18 

-6.18 

-6.18 

-3.49 

-11.03 

-16.72 

-25.08 

-9.67 

-17.22 

-22.90 

-31.26 

Costs (recurring) (€bn) 

-1.15 

-1.15 

-1.15 

-1.15 

-2.84 

-8.99 

-13.62 

-20.43 

-3.99 

-10.13 

-14.76 

-21.57 

Y1 net benefits (€bn) 

-5.34 

-1.02 

Y2 net benefits (€bn) 

0.85 

5.17 

2.23 

8.42 

7.01 

15.15 

47.94 

72.63 

108.95 

9.82 

46.92 

74.87 

115.96 

13.20 

18.64 

58.97 

89.35 

134.02 

19.49 

64.14 

97.77 

147.22 

Stakeholder group 

Number of entities 

Economic 
Operators 

Microenterprises 

SMEs 

Corporates 

Total 

Public Sector Bodies 

30,836,373 

1,832,523 

53,061 

32,721,957 

95,825 

(Weighted) average 
cost 
(one-off) 

(Weighted) average 
cost 
(recurring) 

(Weighted) Average 
benefit 

€ 620 

€ 2,600 

€ 180,000 

€ 500 

€ 5,000 

€ 50,000 

€ 4,000 

€ 42,250 

€ 97,300 

€ 64,542 

€ 11,956 

€ 199,600 

94 

 
 
 
 
 
 
 
ANNEX 5: COMPETITIVENESS CHECK 

1.  OVERVIEW OF IMPACTS ON COMPETITIVENESS  

Table 26– Overview of impacts on competitiveness 

Dimensions of 
Competitiveness 

Impact of the initiative 
(++ / + / 0 / - / -- / n.a.) 

References to sub-sections of the 
main report or annexes 

Cost and price competitiveness  ++ 

International competitiveness  

Capacity to innovate 

SME competitiveness 

+ 

+ 

++ 

2.  SYNTHETIC ASSESSMENT  

Section 6 of the main report  

Section 6 of the main report  

Section 6 of the main report  

Section  6  of  the  main  report  and 
Annex 6 

The proposed Regulation for the European Business Wallets is expected to have numerous impacts 
on EU business competitiveness. 

The  initiative  is  expected  to  have  a  strong  positive  impact  in  terms  of  cost  and  price 
competitiveness. Initial compliance costs will be outweighed by long-term efficiency gains and 
reduced administrative burdens, resulting in cost savings. Economic operators and public sector 
bodies will face one-off costs for training and onboarding, activation and IT implementation, and 
contracting/procurement  costs  as  well  as  recurring  costs  for  licensing  fees  and  maintenance. 
Overall, assuming the 75% adoption of the European Business Wallets, the total estimated costs 
for all EOs amounts to €40.5 billion in the first year, split between €25.1 billion of one-off costs 
and  €20.4  billion  of  recurring  costs,  while  total  estimated  costs  for  all  PSBs  amounts  to  €7.3 
billion in the first year, split between €6.2 billion of one-off costs and €1.1 billion of recurring 
costs.  As  these  figures  show,  costs  will  be  concentrated  mainly  in  the  first  year  due  to  the 
predominance of one-off expenditures. Regarding the total maximum net benefits for both PSBs 
and EOs, they are expected to be positive already in year 1, regardless of the share of adoption 
range considered. Minimum net benefits are also positive as of year 2 for any range considered, 
whilst in year 1 they are positive for ranges 3 and 4178. 

The initiative could deliver immediate economic benefits in terms of cost savings by reducing or 
replacing  manual  administrative  processes  with  digital,  secure  and  interoperable  solutions  for 
identification  and  exchange  of  electronic  attestations  of  attributes.  The  total  direct  benefits  in 
case  of  100%  adoption  by  PSBs  and  75%  adoption  by  EOs,  were  estimated  at  around  €168.8 
billion,  split  into  €14.3  billion  for  PSBs  and  €154.5  billion  for  EOs  per  year.  For  economic 
operators  and  public  authorities,  the  elimination  of  redundant  reporting  and  paper-based 
procedures  translates  into  recurring  efficiency  gains.  These  benefits  improve  businesses’ 
competitiveness  by  lowering  their  operational  expenditure  and  redirecting  resources  to  core 
businesses tasks, while simultaneously allowing for improvements in public service delivery. 

178 See Chapter 6 for more details on the adoption ranges.  

 
 
 
 
Beyond these direct gains, the initiative generates substantial indirect benefits in the long run. In 
particular, the reduced time spent on administrative activities is expected to reallocate savings to 
improve products and services and therefore, to promote innovation. Evidence shows that every 
euro shifted from compliance to research and innovation can generate a multiple return in GDP 
gains, underlining the long-term competitiveness dividend of the initiative179. 

In addition, economic operators of all sizes will be able to expand their activities beyond national 
boundaries with fewer obstacles, creating new opportunities for growth and  facilitating the free 
movement of goods and services. Simplified procedures for proving legal status, ownership, and 
compliance  attributes,  including  across  borders  within  the  EU,  will  make  it  easier  for 
entrepreneurs to  set  up companies abroad and potentially  gain  better access  to  finance as well. 
These changes in the Single Market will promote an environment that champions SMEs agility 
and  competitiveness,  ensuring  their  pivotal  role  in  fortifying  Europe’s  economic  and  digital 
landscape. 

SMEs  in  particular  stand  to  gain  significantly  from  the  introduction  of  the  European  Business 
Wallets  in  myriad  ways,  both  directly  and  indirectly,  thus  making  a  significant  contribution  to 
the EU’s 35% burden reduction target for SMEs. As the mainstay of the European economy, this 
category of EOs gain the most (compared to larger businesses) from lower compliance burdens, 
simplified  procedures,  and  stronger  participation  in  the  Single  Market.  SMEs  and  micro-
enterprises  face  indeed  the  highest  costs  in  dealing  with  administrative  complexity,  redundant 
reporting  and  fragmented  digital  channels.  Direct  benefits  are  estimated  at  €4,000  per  year  for 
microenterprises  and  €42,250  for  larger  SMEs  per  single  entity,  but  the  benefits  for  SMEs  go 
beyond cost savings. 

Promotion  of  competitiveness  could  also  originate  from  savings  generated  by  fraud  reduction: 
the initiative promotes structural improvements in the business environment by increasing data 
quality, which in turns improve accuracy of information and transparency and so allow for better 
fraud detection. This enhances resilience of the Single Markt as whole. 

When it comes to the impact on international competitiveness, there is the possibility of increase 
in  European  companies’  market  share.  By  cutting  administrative  costs  and  creating  trusted 
channels for the recognition of EOs’ credentials, the Business Wallets can enhance their ability 
to operate with more confidence in the global market. EUBW use could benefit both European 
businesses  operating  abroad  and  third-country  companies  active  in  the  Single  Market,  which, 
under  certain  conditions,  may  be  issued  a  Business  Wallet  to  interact  with  EU  partners  in  a 
secure  and  predictable  way.  In  parallel,  EU  providers  of  trust  services  would  have  the 
opportunity  to  scale-up  and  cover  a  larger  share  of  the  international  market,  strengthening  the 
EU’s position as a standard-setter in secure digital infrastructure. 

The  initiative  is  expected  to  stimulate  innovation  capacity  both  for  service  providers  and  for 
users of the Business Wallets. On the supply side, EUBW providers are expected to bundle core 
functionalities  with  value-added services tailored to  sector-specific needs, thereby  enabling the 
emergence of new business models and fostering technological advancement and investments in 

179 For every euro invested Horizon Europe generates up to €11  of economic gains in terms of increased 
GDP per capita https://ec.europa.eu/commission/presscorner/detail/en/ip_25_1115 

96 

 
 
 
innovative functionalities. The market for digital identity and trust services is expanding rapidly, 
with growing demand for functionalities such as identification, authentication, issuance, storage 
and  exchange  of  electronic  attestations  of  attributes,  and  qualified  electronic  delivery  services. 
This  market  is  expected  to  grow  to  between  €20.6  and  €54.3  billion  by  2030.  The  segment 
directly relevant to the European Business Wallets is estimated at €1.0–€1.7 billion in 2024, with 
growth  to  €4.8–€10.3  billion  by  2030.  For  providers,  this  creates  clear  opportunities  to  grow 
their customer base from natural persons to the over 30 million businesses operating in the EU.  

3.  COMPETITIVE POSITION OF THE MOST AFFECTED SECTORS 

The proposed initiative is sector-agnostic, meaning that the Business Wallets regulation does not 
single  out  specific  industries  for  direct  impact.  Its  primary  objective  is  to  reduce  compliance 
hurdles  faced  by  economic  operators  across  the  Single  Market  and  to  facilitate  more  efficient 
interactions with public sector bodies. Thus, the impacts are cross-sectoral by design, rather than 
concentrated in specific industries. 

At  the  same  time,  it  is  important  to  note  that  the  Draghi  Report  identified  digitalisation  and 
advanced technologies as areas where Europe faces a structural competitive disadvantage vis-à-
vis other global players. The report notes the close link between company size and technology 
adoption,  with  higher  levels  of  adoption  of  advanced  technologies  with  larger  firms.  By 
promoting  trusted  digital  infrastructures  and  interoperability,  the  European  Business  Wallets 
contribute  indirectly  to  strengthening  Europe’s  competitiveness  in  this  sector.  It  does  so  by 
lowering  barriers  to  the  uptake  of  digital  solutions,  creating  new  opportunities  for  innovation, 
and ensuring that companies – particularly SMEs – can more easily engage in cross border trade 
while being  able to  redirect  resources from  compliance towards higher-value activities such as 
digital transformation. 

In  this  way,  while  sector-agnostic  in  scope,  the  initiative  aligns  with  the  strategic  objective  of 
reinforcing the EU’s position in digitalisation.  

97 

 
 
 
 
ANNEX 6: SME CHECK  

OVERVIEW OF IMPACTS ON SMES 

Relevance for SMEs  

Building  on  the  analysis  of  impact  presented  in  this  Staff  Working  Document  and 
drawing  also  on  the  advice  of  the  EU  SME  Envoy180,  this  initiative  was  assessed  as 
highly relevant for SMEs, as it directly and indirectly impacts a large number of SMEs, 
cutting across sectors.  

Below an overview of the most relevant consideration that drove the assessment.  

•  Administrative burdens are the first  challenge for SMEs181; this initiative has strong 
potential to reduce them. Through simplification, SMEs will be better able to manage 
complex  administrative  tasks  and  comply  with  regulatory  requirements,  thereby 
generating cost savings and being able to focus more on core business activities. 
•  The  European  Business  Wallets,  as  integrated  set  of  core  functionalities  of  digital 
identification  and  trust  services  (i.e.  proving  identity,  signing/sealing,  submitting 
documents,  or  receiving  official  notifications),  can  enhance  companies’  operational 
efficiency  (e.g.  by  reducing  time  and  resources  spent  on  manual  processes).  This 
efficiency  gain  frees  time  and  resources  allowing  SMEs  to  redirect  efforts  and 
investment  towards  growth,  competitiveness,  and  new  product/services,  thereby 
strengthening economic integration and fostering innovation in Europe. 

•  The EUBW can enhance the digitalisation of SMEs by promoting the use of secure 

and standardised tools to support their business activities and operations. 

•  SMEs,  especially  micro  enterprises,  rarely  have  the  capacity  to  manage  the  IT 
integration and implementation processes into their own IT systems. The Wallets will 
provide a ready-to-use, user-friendly solution that can be tailored to the size and needs 
of  the  economic  operators:  for  many  SMEs,  especially  microenterprises,  this  could 
simply take the form of a secure web application or a mobile application. 

The  EUBW  will  also  play  a  vital  role  for  SMEs  not  yet  active  beyond  their  home 
markets, by lowering barriers to entry and reducing administrative hurdles to gain access 
to new markets in other Member States. 

IDENTIFICATION  OF  AFFECTED  BUSINESSES  AND  ASSESSMENT  OF 

(1) 
RELEVANCE 

Are SMEs directly affected? In which sectors?  

Yes.  The  initiative  applies  across  all  sectors  in  which  economic  operators  interact 

180 https://ec.europa.eu/docsroom/documents/63274 
181 Draghi report 

98 

 
 
 
 
with  public  authorities  for  regulatory  compliance  and  reporting.  It  is  not  limited  to 
specific  industries  but  has  been  conceived  as  a  horizontal,  sector-neutral  tool  to 
reduce  compliance  burdens  and  streamline  interactions  between  businesses  and 
public administrations. Its impacts are therefore cross-cutting by design, ensuring that 
enterprises  in  all  parts  of  the  Single  Market  can  benefit.  In  particular  SMEs,  which 
are  present  in  every  sector  and  often  most  affected  by  administrative  complexity, 
stand to gain significantly from this initiative.  

Estimated number of directly affected SMEs 

The  number  of  SMEs  affected  can  theoretically  reach  a  maximum  of  the  entire 
population  of  SMES,  estimated  (Eurostat  2023)  at  a  total  of  32,668,896  SMEs,  of 
which 30,836,373 are microenterprises with less than 10 employees. 

However,  account  must  be  taken  of  the  level  of  digital  intensity  in  SMEs.  58%  of 
SMEs have at least basic level of digital intensity182. These SMEs (10-49 employees) 
are considered very likely to choose to use the European Business Wallets. Data for 
microenterprises is not available for reasons of avoiding excessive burdens. 

Estimated number of employees in directly affected SMEs 

It is estimated that the affected SMEs employ 135.6 million people183. 

Are SMEs indirectly affected? In which sectors? What is the estimated number 
of indirectly affected SMEs and employees? 

Yes.  Indirect  impacts  especially  affect  sectors  that  provide  services  to  economic 
operators  and  public  sector  bodies.  These  could  include  for  example  ICT  and 
software  development,  legal  and  accounting  services,  consultancy  and  training,  as 
well as trust and certification providers. SMEs dominate these sectors in Europe and 
many  of  them  are  likely  to  benefit  from  new  business  opportunities  linked  to  the 
deployment and integration of the European Business Wallets. 

At the same time, some service providers currently relying on paper-based or manual 
compliance processes may see demand for such services reduced as more exchanges 
become  digital.  On  balance,  however,  the  indirect  impacts  are  expected  to  be 
positive, as  the  European Business  Wallets creates opportunities for innovation and 
service provision, especially for digitally capable SMEs. 

Overall, the estimated number of indirectly affected SMEs could be approximated to 

in 

least  basic 

the  EU  reached  at 

182  58%  of  SMEs 
in  2023. 
https://ec.europa.eu/eurostat/web/products-eurostat-news/w/ddn-20240829-1.  The  figure  was  obtained  by 
multiplying the number of EU SMEs by 58%, and assuming that all larger SMEs (10+ employees), which 
are  1,832,523,  would  all  be  affected  as  having  at  least  basic  level  of  digital  intensity.  A  share  of 
microenterprises would be affected, equal to the remaining microenterprises to reach 58% of all SMEs.   
183 Assuming an average of 1.54 employees for microenterprises, and of 59.62 employees for SMEs with 
more  than  10  employees.  See  Business  Wallet  Study,  NTT  Data,  7.1.2,  Table  27:  Annual  costs  for 
Economic Operators. 

level  of  digital 

intensity 

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those  operating  in  knowledge-intensive  sectors,  that  is  one  third  of  the  SMEs184, 
equal  to  10,889,632,  of  which  9,057,109  are  microenterprises.  The  total  number  of 
employees indirectly affected is estimated at 123.2 million. 

(2) CONSULTATION OF SME STAKEHOLDERS 

How has the input from the SME community been taken into consideration? 

Input  was  gathered  through  the  Call  for  Evidence,  through  the  survey  and  expert 
interviews of the European Business Wallets accompanying study, and a series of events. 
These  included  several  distinct  dedicated  workshops,  such  as  those  organised  by  the 
Polish  Presidency,  by  the  European  Commission’s  DG  GROW,  and  by  the  association 
DIGITALEUROPE,  which  included  testimonies  from  SMEs  on  the  barriers  posed  by 
administrative complexity, redundant reporting and limited access to digital channels, as 
well  as  meetings  with  representative  organisations  of  SMEs.  Their  feedback  has  been 
reflected  in  the  design  of  the  initiative,  particularly  the  emphasis  on  a  market-driven 
approach  and  on  legal  recognition  of  notifications  and  documents  transmitted  via  the 
European Business Wallets. 

Are SMEs’ views different from those of large businesses?  

Yes. Though the consultation showed that SMEs and large companies broadly agree on 
the need for secure, interoperable, and legally valid digital tools to reduce administrative 
burdens  and  support  cross-border  operations,  their  perspectives  differ  however  in 
emphasis. 

For SMEs, and especially microenterprises, the main concern is the disproportionate cost 
of  compliance.  They  highlighted  that  repetitive  reporting,  manual  submissions,  and 
fragmented national systems consume scarce time and resources, often at the expense of 
innovation or expansion. They often lack digital tools and outsource administrative tasks, 
raising costs. Time costs are high: 30–50% of time spent  on administrative activities, 9 
hours/week chasing payments, and 1.5 days/week on identity validation. 

SMEs  also  warned  that  poorly  coordinated  EU  digital  initiatives  could  add  complexity 
rather than reduce it, stressing the importance of alignment with instruments such as the 
European Digital Identity Wallet. 

For larger companies, the priority is ensuring that the European Business Wallet can be 
integrated  with  existing  IT  infrastructures  and  process  automation  systems.  The  wallet 
concept  is  complex  and  requires  server-based  solutions  with  role-based  access.  Larger 
corporates have stressed the need for interoperability with Enterprise Resource Planning 
platforms,  compliance  management  tools,  and  internal  reporting  channels  to  avoid 
duplication and maximise efficiency. 

In short, in their replies SMEs emphasised simplification and cost reduction. 

184  Knowledge  intensive  industries  account  See  Annual  report  on  European  SMEs,  2024/2025,  section 
3.5.2. https://publications.jrc.ec.europa.eu/repository/handle/JRC142263 

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(3) ASSESSMENT OF IMPACTS ON SMES185 

What are the estimated direct costs for SMEs of the preferred policy option? 

Qualitative assessment 

SMEs will face one-off training and onboarding costs, IT implementation costs, and recurring 
licensing fees for access to European Business Wallets services. Costs are proportionately higher 
for  microenterprises,  which  lack  specialised  staff  and  must  divert  resources  from  core  activities. 
However, for certain categories of micro-enterprises, like self-employed and sole traders, there 
is  the  possibility  to  reduce  costs  by  purchasing  the  communication  channel  as  standalone 
service while using the EUDI wallet.  For larger SMEs, while absolute costs are higher, these 
are spread across a bigger workforce and thus proportionately lower.  

Quantitative assessment 

Microenterprises (<10 employees): €520 training + €100 IT + €500 licensing and maintenance 
= €620 annual average in the first year, which is reduced to €500 yearly as of the second year. 
Larger  SMEs  (10-250  employees):  €1,400  training  +  €800  IT  +  €400  contracting  +  €5,000 
licensing and maintenance = €7,600 annual average, which is reduced to €5,000 yearly as of 
the second year.  

What are the estimated direct benefits/cost savings for SMEs of the preferred policy option186? 

Qualitative assessment 

Direct  benefits  are  calculated  as  cost  savings  expected  from  the  reduction  or  elimination  of 
manual and administrative processes and reporting requirements. These savings allow SMEs 
to redirect resources towards higher-value activities such as business development, innovation, 
and cross-border expansion. The benefits  are especially  relevant  for microenterprises,  where 
opportunity costs are higher.  

In line with the ‘Think Small First’ principle, the supporting study for the European Business 
Wallets initiative has analysed the pros and cons on the perspective of SMEs, when assessing 
each revenue stream of the business model archetypes187. 

Quantitative assessment 

Annual direct benefits are estimated on average at €4,000 for microenterprises and at €42,250 
for  SMEs  with  at  least  10  employees.  This  results  in  total  benefits  of  €123.35  billion  for 
microenterprises  and  €77.42  billion  per  year  for  larger  SMEs,  accounting  for  97.5%  of  the 
total direct benefits for economic operators. 

185 The costs and benefits data in this annex are consistent with the data in annex 3. The preferred option 
includes the mitigating measures listed in section 4.  
186 The direct benefits for SMEs can also be cost savings. 
187 See European Business Wallets, NTT Data, October 2025, Section 3.3. 

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What are the indirect impacts of this initiative on SMEs?  

The indirect benefits described in Chapter 8 also apply to SMEs. For SMEs, and especially for 
microenterprises,  the  European  Business  Wallet  can  generate  significant  gains  in  terms  of 
economic opportunities and market competitiveness resulting from increased entrepreneurship 
density  and  creation  of  new  businesses,  as  well  as  from  unlocked  capacity  of  shifting 
resources away from compliance towards strategic activities. Furthermore, SMEs are expected 
to  be  positively  impacted  by  an  increased  trust  in  digital  public  services  and  business 
processes  and  a  strengthened  resilience  of  digital  infrastructures.  Lastly,  applications  of  the 
EUBW in the domain of environmental sustainability will impact SMEs. SMEs can leverage 
the  wallet  to  reduce  paper  consumption,  which  is  particularly  relevant  to  microenterprises 
which  are  not  reaching  basic  levels  of  digital  intensity  and  rely  heavily  on  paper-based 
processes.  In  addition,  the  EUBW  may  facilitate  compliance  in  sustainability  by  easing 
reporting, which is relevant for larger SMEs. Given that SMEs represent the vast majority of 
European enterprises, the share of these indirect benefits attributable to them is significant. 

(4) MINIMISING NEGATIVE IMPACTS ON SMES 

Are SMEs disproportionately affected compared to large companies?  

If yes, are there any specific subgroups of SMEs more exposed than others? 

No. 

While  SMEs,  and  especially  microenterprises,  face  relatively  higher  adjustment  costs  at  the 
outset  (e.g.  training,  onboarding,  and  IT  integration),  the  overall  cost–benefit  balance  is 
particularly favourable for them. For SMEs, total costs (one-off and recurring) are estimated 
to  represent  only  around  24%  of  the  maximum  direct  benefits,  and  as  of  year  two  the  cost-
benefit  ratio  further  reduces  to  12%188,  implying  significant  savings  potential  for  SMEs.  By 
comparison, in year 2, corporates’ cost-benefit ratio is 51%,  

Microenterprises  (fewer  than  10  employees)  are  the  most  exposed  to  administrative  burden. 
They represent 94% of all EU enterprises and often operate with very limited administrative 
capacity (on average 1.5 employees). However, self-employed and sole traders (representing 
about  63%  of  microenterprises  when  considering  1-person  enterprises  only189)  may  also 
access the Business Wallets ecosystem by relying on their  EU Digital  Identity Wallets. This 
will  enable  the  use  of  trust  services,  including  those  offered  for  the  European  Business 
Wallets, such as the secure communication channel as a standalone service, without the need 
to  acquire  a  fully-fledged  Business  Wallet.  Using  only  selected  stand-alone  trust  service 
solutions  may  be  more  affordable  for  sole  traders  and  self-employed  individuals  For  these 
businesses,  every  hour  spent  on  compliance  tasks  is  directly  taken  away  from  revenue 
generation  and  business  development.  Small  enterprises  (10–49  employees)  are  also  more 
affected  than  medium-sized  firms,  as  they  may  lack  the  specialised  staff  and  digital  tools 
required to integrate new systems efficiently. The European business Wallet and particularly 

188 Range 4 of 75% usage for EOs. 
189 Based on 2023 Eurostat figures for Self-employed persons without employees (own-account workers), 
accounting for 19.3M in the EU and compared to the 30.8M of microenterprises in scope. 

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use  cases  such  as  the  Power  of  Attorney,  can  enable  SMEs  to  delegate  administrative  tasks 
digitally, reducing time and cost burdens for managing delegations190, which is recognised by 
the  European  strategy  to  support  SMEs  as  an  area  where  opportunity  to  cut  red  tape  are 
present for SMEs191. 

Have mitigating measures been included in the preferred option/proposal? (Yes/No)  

Yes.  The  European  Business  Wallets  will  significantly 
lower  adoption  costs  and 
administrative burdens for SMEs, particularly for microenterprises with limited resources. The 
preferred option relies on scalable models for the European Business Wallet, which minimise 
upfront  IT  investments  and  reduces  the  complexity  of  deployment  for  SMEs.  In  a  market-
driven  approach,  the  emergence  of  business  models  and  service  propositions  tailored  to  the 
needs  and  size  of  economic  operators  will,  for  example,  result  in  solutions  that  are  easy  to 
access and integrate for smaller SMEs, such as simple and secure web-based applications. At 
the same time, the proposal ensures that core functionalities are part of the EUBW offering. 

In addition, among the micro-enterprises, self-employed individuals and sole traders may also 
rely  on  their  EU  Digital  Identity  Wallets  to  access  trust  services  offered  for  the  European 
Business  Wallets,  including  the  secure  communication  channel  or  e-signatures,  without  the 
need  to  acquire  a  fully-fledged  Business  Wallet.  This  ensures  proportionate  treatment  of 
smaller operators by preventing the imposition of an undue burden.   

CONTRIBUTION TO THE 35% BURDEN REDUCTION TARGET FOR SMES 

Are there any administrative cost savings relevant for the 35% burden reduction target 
for SMEs? 

Yes. The European Business Wallets  initiative is conceived around reducing  the burden of 
administrative  procedures  and  regulatory  reporting  requirements,  which  translate  into  cost 
saving  opportunities.  The  expected  maximum  direct  benefits192  for  SMEs,  considering  the 
theoretical scenario of 100% adoption, amount to €200.77 billion of cost savings annually, 
split into €123.35 billion for microenterprises and €77.42 billion for larger SMEs. 

Based on current estimates of the administrative burden borne by SMEs across the EU, these 
savings correspond to a reduction well in line with, and in many cases exceeding, the 35% 
burden  reduction  target  set  by  the  European  Council  in  March  2025.  While  the  precise 
percentage  contribution  depends  on  the  baseline  used,  the  scale  of  savings  clearly 
demonstrates that the initiative can deliver a substantial share of the required reduction, with 
particular impact for microenterprises that face the heaviest compliance costs relative to their 
size. 

190 See Business Wallet Study, NTT Data, October 2025, Section 3.2.2. 
191  See  European  Council.  (2025).  Support  to  small  and  medium-sized  enterprises  (SMEs).  Available  at: 
https://www.consilium.europa.eu/en/policies/support-to-small-and-medium-sized-enterprises/#redtape 
192 Regarding range 4 of 75% usage for EOs. 

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ADDITIONAL INFORMATION  

See Chapters 2 and 4 for the analysis of the intervention logic. See Chapters 6-7-8 for the 
cross-benefit analysis. 

104