The European Business Wallet solves the e-invoicing address problem, if the right choices are made
A recent article on Peppol.now described a problem that is well-known to anyone who sends invoices across borders: finding the correct e-invoicing recipient address for a new international customer is harder than it should be. The challenge breaks down into three layers — registration, lookup, and addressing — each fragmented, each requiring a different solution per country.
That article ended with a call to put an interoperable cross-border routing directory on the policy agenda. This article names a concrete candidate for that role: the European Business Wallet.
The argument is not that the Business Wallet is ready for this function today. It is not. The argument is that the architectural fit is strong, the policy window is open, and two specific decisions would make it happen.
The three-layer problem, briefly restated
Correctly addressing an e-invoice to an international recipient involves three distinct challenges.
The first is the registration layer: businesses are registered in national registries, and access to those registries is inconsistent — some offer machine-readable APIs, others restrict access, some have no central access at all.
The second is the lookup layer: connecting a company name to a fiscal identifier across borders. Europe has a cross-border infrastructure for this — VIES — but it validates numbers rather than enabling name-based search, for deliberate privacy reasons.
The third is the addressing layer: translating a fiscal identifier into a valid e-invoicing endpoint. In Peppol countries this means a Peppol Participant ID. In France it means identifying which certified Plateforme Agréée the recipient uses. In clearance countries it means submitting the right fiscal identifier to the right platform.
All three layers remain fragmented at European level. No single standardised service resolves all three. For a full analysis of why, see the e-invoicing recipient address article.
What the European Business Wallet is
The European Business Wallet — the business-facing extension of the European Digital Identity (EUDI) Wallet initiative — is grounded in the eIDAS 2.0 regulation adopted in 2024. In early 2026, the European Commission took a further step by publishing a formal legislative proposal: the Regulation on the establishment of European Business Wallets. Legislatively, the direction is set. Practically, the Business Wallet is in the same phase Peppol once was: being tested at scale through a Large Scale Pilot — the WE BUILD Consortium — before any broad operational rollout. The policy window and the pilot infrastructure exist simultaneously — which is precisely why the decisions described in this article need to be made now, not after the LSP concludes.
Where the citizen-facing EUDI Wallet holds verified personal credentials, the Business Wallet holds verified organisational attributes: company registration data, VAT numbers, economic operator certificates, and authorisations to act on behalf of the organisation. These attributes are drawn from authoritative sources — national business registries, tax authorities, sector regulators — and cryptographically signed so that they can be presented to third parties with verifiable provenance. The wallet architecture supports selective disclosure: the holder presents only the attributes required for a specific transaction.
The scale of the effort underway is significant. The WE BUILD Consortium — selected by the European Commission to participate in the Large Scale Pilots for the EU Digital Identity Wallet — brings together more than 190 organisations across 30 countries. Its membership spans 13 National Business Registers, tax authorities, banks and financial institutions, wallet providers and QTSPs, technology companies, SMEs, and academic institutions. Countries represented include the Netherlands, Belgium, France, Germany, Sweden, Greece, Spain, Finland, Italy, Norway, and others across the EU and beyond. Critically for the topic of this article, e-invoicing is explicitly one of the WE BUILD use cases — designated SC5 in the Supply Chain domain, led by OpenPeppol.
How the Business Wallet could technically solve all three layers
Layer 1: Registration
A Business Wallet holding verified credentials from national base registries is, by definition, a portable and authenticated company registration record. A supplier interacting with a recipient that holds a Business Wallet does not need to query the Dutch KvK, the Belgian KBO, or the German Handelsregister separately. The wallet presents the relevant identifier — KvK number, KBO/BCE number, VAT number — as a verified attribute. The integration burden shifts from every service provider individually to the wallet issuance infrastructure, built once per member state.
Layer 2: Lookup
VIES — the VAT Information Exchange System operated by the European Commission — currently allows VAT number validation but not name-based search. That restriction is a deliberate privacy decision: open name-to-number lookup at scale creates risks of data harvesting.
The Business Wallet dissolves this tension. A supplier does not search an open registry for the recipient’s identifier. Instead, the recipient presents their wallet — including their VAT number and national identifier — directly, as part of an authenticated business interaction. The lookup is replaced by a verified presentation.
If the wallet is connected to VIES as an authoritative source for VAT data, the resulting attribute is validated against the member state’s tax authority record. Privacy is not compromised; it is by design. The wallet holder controls what they share, with whom, and for what purpose.
Layer 3: Addressing
The addressing layer requires knowing not just who the recipient is, but where to route the invoice. The Business Wallet can hold the e-invoicing endpoint as a standard verified attribute. A recipient registers their preferred receiving channel — Peppol, a national platform, a specific service provider — once, in their wallet. A supplier with access to that attribute has everything needed to route correctly, without contacting the recipient and without querying multiple country registries.
The routing network — whether Peppol or another — does not change. The wallet is not a routing network. It is the identity and addressing layer that sits in front of it.
What makes this architecturally elegant
First, authentication is built in. The wallet proves that the presenting entity is who it claims to be, eliminating a category of fraud risk that currently exists in e-invoicing.
Second, mandating and authorisation follow naturally. A person presenting a Business Wallet on behalf of a company can carry a credential indicating the scope of their authorisation — to contract, to receive invoices, to approve payments.
Third, the architecture is network-agnostic. Whether the underlying routing network is Peppol, DBNAlliance, a national clearance system, or a certified platform under the French model, the wallet handles identity and address resolution upstream.
Fourth, this aligns with the five-corner model logic. The Business Wallet, issued by a trusted public authority and cryptographically bound to base registries, is precisely what the fifth corner — the government trust anchor — is supposed to provide.
Where the architecture meets friction
Three points of friction deserve acknowledgement before considering the policy agenda.
The first is voluntary adoption versus coverage. If Business Wallet registration remains optional, the lookup advantage evaporates for the segment that matters most. A wallet that is nearly universal delivers structural value. A wallet adopted by early movers does not.
The second is the e-invoicing endpoint as a wallet attribute. Current wallet development does not include the e-invoicing recipient address as a standard attribute. That must be decided, defined, and standardised — at European Commission level, in coordination with OpenPeppol and national Peppol Authorities. Without that decision, the wallet cannot serve the addressing function described above.
The third is scope. The European Business Wallet is an EU instrument. It resolves the three-layer problem within the EU, but does not help with counterparts in the United States, Mexico, or other non-EU jurisdictions. For globally operating businesses, this is a European solution to a European portion of a global problem.
The policy agenda: two decisions and a coordination point
Two specific policy decisions would close the gap between the Business Wallet’s current state and its potential as European e-invoicing address resolution infrastructure.
The first is mandatory or near-mandatory wallet adoption for VAT-registered businesses. The ViDA reform already extends digital reporting requirements to all VAT-registered businesses operating across borders. Combining that obligation with Business Wallet issuance — or making wallet registration a condition of VAT registration — is a tractable policy step within the ViDA implementation timeline.
The second is standardising the e-invoicing endpoint as a wallet attribute. The European Commission’s implementing acts for the EUDI Wallet and the forthcoming regulation on Business Wallets are being shaped now. This is the moment to introduce the e-invoicing endpoint as a required attribute. Once the regulatory texts are finalised, retrofitting this becomes significantly harder.
Beyond these two decisions, there is a coordination point that no single institution currently owns: the integration between the Business Wallet and existing routing networks. OpenPeppol, national Peppol Authorities, and the operators of national clearance systems need to define how a wallet attribute is translated into a routing instruction. This is not a technically complex problem — but it requires someone to convene the conversation.
Who needs to do what
The European Commission needs to include the e-invoicing endpoint as a standard attribute in both the EUDI Wallet implementing acts and the forthcoming Business Wallet regulation. This is a drafting decision within the mandate the Commission already holds. The ViDA team in DG TAXUD and the Digital Identity team in DG CNECT need to be in dialogue on this specific point.
Member states need to move from voluntary to required wallet adoption for VAT-registered businesses. The Netherlands and Belgium — both active in Business Wallet development and both operating Peppol infrastructures — are natural candidates to push this forward as a joint position in Council.
The WE BUILD Consortium is the natural vehicle for piloting this in practice. E-invoicing is already explicitly part of the WE BUILD programme as use case SC5 in the Supply Chain domain, led by OpenPeppol. The question of how the Business Wallet resolves the e-invoicing recipient address — across all three layers — should be made an explicit objective within that use case’s working programme. The Peppol Conference in Brussels on 16–17 June 2026 is a concrete near-term opportunity to put this framing on the agenda.
OpenPeppol and national Peppol Authorities need to define the integration layer between the Business Wallet and Peppol routing: specifically, how a Peppol Access Point uses a wallet attribute as input to an SMP lookup. This is a technical specification question that follows directly from what WE BUILD SC5 should be piloting.
The Dutch Ministry of Economic Affairs is not just one voice among many on this agenda. The Ministry leads the Management Board of WE BUILD (WP1), giving it a structurally privileged position to direct the consortium’s priorities. The concrete advice is this: the Ministry should use that position to address the e-invoicing recipient address question directly to the SC5 working group, and to ensure that the connection between the Business Wallet and e-invoicing addressing is made explicit in the working programme — before the regulatory window for including it as a standard wallet attribute closes.
Why the timing matters
Two major EU regulatory tracks are in active implementation simultaneously: ViDA and eIDAS 2.0 / the Business Wallet Regulation. Both affect every VAT-registered business operating across EU borders. Both are being shaped now.
The implementing acts and regulatory texts are not yet finalised. The e-invoicing endpoint attribute can still be written into the wallet specification before it is locked. Once that window closes, the structural opportunity to solve the three-layer problem at European level through a single architectural decision closes with it.
France’s Annuaire demonstrates that routing transparency as public infrastructure is achievable. The Business Wallet generalises that principle to all EU member states, with authentication and selective disclosure built in. The question is not whether the architecture is sound. It is whether the policy decisions get made while the window is still open.
What this means when you choose a provider today
Until the Business Wallet is operational as e-invoicing addressing infrastructure — a 2028 or later horizon — the three-layer problem remains unsolved at the systemic level. Businesses invoicing internationally today need providers that address all three layers per country through their own registry integrations and SMP lookups.
The questions worth asking when selecting a provider remain the same: in which countries does the solution support recipient address resolution? How does it solve each layer for those specific countries? What happens when a recipient is not registered on any network?
The Business Wallet does not change those questions for today. It answers them, structurally, for the medium-term future — if the policy decisions get made.
Compare certified e-invoicing providers on Peppol.now | How the four-corner and five-corner models work
Frequently asked questions
What is a digital wallet in the context of European business identity?
A digital wallet, in this context, is a secure application that holds verified digital credentials on behalf of a person or organisation. In the European framework, these credentials are issued by trusted public authorities — such as national business registries or tax authorities — and cryptographically signed to prove their authenticity. The wallet does not store data centrally: the holder controls what they share, with whom, and for what purpose. This model is known as selective disclosure. For businesses, a digital wallet can hold credentials such as company registration data, VAT numbers, and authorisations to act on behalf of the organisation.
What is the European Business Wallet?
The European Business Wallet is the organisational counterpart to the citizen-facing EU Digital Identity (EUDI) Wallet. It is designed to give businesses a trusted, portable digital identity that works across EU member states. Grounded in the eIDAS 2.0 regulation and the subject of a dedicated European Commission legislative proposal published in 2026, the Business Wallet allows organisations to present verified credentials — registration data, fiscal identifiers, sector licences — to public authorities, trading partners, and platforms, without needing to repeat identity verification processes from scratch in each country or context. The WE BUILD Consortium is the Large Scale Pilot testing its implementation across 30 countries and 190+ organisations.
How does the European Business Wallet differ from the citizen EUDI Wallet?
The citizen EUDI Wallet holds personal credentials: driving licences, educational qualifications, health data, or national identity documents. The Business Wallet holds organisational credentials: company registration numbers, VAT identifiers, economic operator certificates, and authorisations granted by a legal entity to individuals acting on its behalf. Both are built on the same underlying eIDAS 2.0 framework and share the same principles of selective disclosure and cryptographic verification. In practice, the two wallets are complementary: an employee may use their citizen wallet to authenticate themselves, while presenting credentials from the company’s Business Wallet to demonstrate the scope of their mandate.
How could the Business Wallet solve the e-invoicing recipient address problem?
Finding the correct e-invoicing address for a new international customer involves three layers: identifying which registry the recipient is registered in, finding their fiscal identifier, and translating that identifier into a valid routing address for the applicable e-invoicing system. Currently, each layer is fragmented by country. The Business Wallet could solve all three in one move. The wallet holds verified registration credentials from national registries (layer 1), enables authenticated fiscal identifier exchange without requiring open name-based search (layer 2), and could hold the e-invoicing endpoint — the recipient’s preferred receiving channel — as a standard verified attribute (layer 3). The prerequisite is that the e-invoicing endpoint is defined as a standard wallet attribute. That decision has not yet been made.
Does the Business Wallet replace my current e-invoicing solution or provider?
No. The Business Wallet is not an e-invoicing solution. It is an identity and addressing layer. It tells a routing network who the recipient is and where to deliver the invoice. The actual creation, validation, and transmission of the invoice remains the responsibility of your e-invoicing provider and the underlying network — whether that is Peppol, a national clearance platform, or a certified service provider under a framework such as the French Plateforme Agréée model. Think of the wallet as the address on an envelope: it tells you where to send, but not how to write the letter.
What is the relationship between the European Business Wallet and Peppol?
Peppol is a routing network: a four-corner infrastructure that transports e-invoices between certified Access Points. The Business Wallet is not a routing network. It is an identity and addressing infrastructure that could sit upstream of Peppol — and of any other routing network. In practical terms, a Business Wallet holding a Peppol Participant ID as a verified attribute would allow a Peppol Access Point to initiate an SMP lookup with a validated input, rather than relying on a manually entered or unverified identifier. The connection between the two is not yet standardised. OpenPeppol leads the e-invoicing use case (SC5) within the WE BUILD Consortium, making it the natural actor to define how wallet attributes feed into Peppol’s routing logic. Peppol itself is a useful analogy for the current phase: it too began as a Large Scale Pilot before becoming the operational infrastructure it is today.
When could the Business Wallet be used for e-invoicing in practice?
Operational deployment at scale is realistically a 2028 or later horizon, given current LSP timelines and the legislative process for the Business Wallet Regulation. But the decisions that determine whether the wallet will be capable of serving e-invoicing addressing functions need to be made now — while the implementing acts are still being drafted and the WE BUILD pilot programme is still defining its use case objectives. The window for including the e-invoicing endpoint as a standard wallet attribute is open. It will not remain open indefinitely.
Sources
European Commission — eIDAS 2.0: Regulation (EU) 2024/1183 on the European Digital Identity framework. Digital Strategy, European Commission. https://digital-strategy.ec.europa.eu/en/policies/eidas-regulation
EUDI Wallet Implementation: Overview of implementing acts and architecture reference framework. European Commission. https://digital-strategy.ec.europa.eu/en/policies/eudi-wallet-implementation
Architecture Reference Framework (ARF): Technical specification for the EUDI Wallet, maintained by the European Commission. https://github.com/eu-digital-identity-wallet/eudi-doc-architecture-and-reference-framework
VIES — VAT Information Exchange System: European Commission official VAT number validation tool. https://europa.eu/youreurope/business/taxation/vat/check-vat-number-vies/index_en.htm
EU VAT Directive: Council Directive 2006/112/EC — legal basis governing VAT information sharing between member states. EUR-Lex. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32006L0112
ViDA — VAT in the Digital Age: European Commission reform package for digital VAT reporting. DG TAXUD. https://taxation-customs.ec.europa.eu/taxation/value-added-tax/vat-digital-age-vida_en
OpenPeppol: Peppol Interoperability Framework — overview of the four-corner model, SML and SMP. https://peppol.org/learn-more/peppol-interoperability-framework/
Peppol Directory: Public search interface for registered Peppol participants. OpenPeppol. https://directory.peppol.eu/
DGFiP — Portail Public de Facturation: Official French public invoicing portal including Annuaire documentation. Direction Générale des Finances Publiques. https://www.impots.gouv.fr/
ViDA e-facturatie en digitale rapportage — Exploratory study on the most suitable infrastructure for e-invoicing and digital reporting in the Netherlands, report 23 January 2026. https://www.rijksoverheid.nl/documenten/rapporten/2026/01/26/rapport-e-facturatie-en-rapportage
Aanbiedingsbrief rapport ViDA e-facturatie en digitale rapportage — Covering letter from State Secretary Eerenberg (Finance) to the Dutch House of Representatives, 10 March 2026. https://www.rijksoverheid.nl/documenten/kamerstukken/2026/03/10/aanbiedingsbrief-rapport-vida-efacturatie-en-digitale-rapportage
Beslisnota’s bij Aanbiedingsbrief rapport ViDA e-facturatie en digitale rapportage — Policy decision notes, 10 March 2026. https://www.rijksoverheid.nl/documenten/beleidsnotas/2026/02/24/beslisnota-s-aanbiedingsbrief-rapport-vida-e-facturatie-en-digitale-rapportage
Peppol.now — E-invoicing recipient address: The preceding article that identifies the three-layer problem this piece responds to. https://peppol.now/e-invoicing-recipient-address/
