QERDS and the European Business Wallet: the layer that makes digital communication legally valid — and what it means for Peppol

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In the Dutch policy debate about the European Business Wallet (EBW), most attention goes to the EU Digital Identity Wallet and digital identity. At least as much weight is shifting toward the layer that makes digital communication between businesses and public authorities legally valid: QERDS, the Qualified Electronic Registered Delivery Service.

For the Peppol network, this raises a question that has barely been asked so far. Peppol has been carrying legally valid messages between businesses and public authorities for years. QERDS introduces a formal alternative for that same function, anchored in the eIDAS Regulation. What is the difference, where do they overlap, and what should OpenPeppol do about it?

What QERDS actually is

QERDS is not a new concept: it has been part of the eIDAS Regulation (Regulation (EU) No 910/2014) since 2014, and was tightened by the eIDAS 2.0 amendment (Regulation (EU) 2024/1183) in 2024. Article 43 of the Regulation grants a legal presumption to data sent and received through a qualified electronic registered delivery service: a presumption of the integrity of the data, and of its sending and receipt by the identified sender and addressee. Article 44 sets out the additional requirements a service must meet to earn that qualification, including mandatory identification of both parties and delivery by a qualified trust service provider (QTSP) listed on the national Trusted List.

An important detail: a non-qualified delivery service (ERDS) is therefore not automatically worthless as evidence. Article 43(1) explicitly states that a registered delivery service shall not be denied legal effect or admissibility as evidence solely on the grounds that it does not meet the requirements of the qualified service. The difference lies in the burden of proof: for QERDS the legal presumption applies automatically, while for an ordinary ERDS the evidentiary value must be demonstrated case by case. eIDAS 2.0 adds an interoperability obligation on top of this: QERDS providers must use standardised protocols and evidence formats between each other under the ETSI standards EN 319 522 and EN 319 523, so that a QERDS message from one provider is recognised as such by another provider.

QERDS as a core function of the European Business Wallet

On 19 November 2025, the European Commission published the formal legislative proposal COM(2025) 838 for a regulation establishing European Business Wallets. The proposal names three core functions: secure identification, electronic signing and sealing, and the sending and receiving of data through a qualified electronic registered delivery service. QERDS is therefore not a side note in the proposal, but one of the three pillars the entire Wallet rests on.

The Commission deliberately chooses to have QERDS services delivered by market parties rather than a centralised government solution. That makes interoperability, governance and oversight of those market parties a theme member states still need to take a position on. The legislative process has advanced considerably: on 9 June 2026 the Council of the European Union adopted a general approach, the ITRE rapporteur in the European Parliament (Eero Heinäluoma) published his draft report on 20 March 2026, and a political agreement is expected before the end of 2026, with formal adoption in the first half of 2027. Once the regulation enters into force, public authorities will have 24 months to be able to accept the core functions. For businesses, use of the EBW remains voluntary; the acceptance obligation in the proposal applies exclusively to public authorities.

The question that has not been asked yet: how does Peppol transport relate to QERDS?

The Peppol network already solves a similar problem with its AS4 profile: messages are signed, encrypted and provided with receipts that guarantee non-repudiation between Access Points. That trust, however, is built up predominantly through institutional and contractual means, through the Peppol Interoperability Framework, mandatory agreements between Access Points and Peppol Authorities, and conformance testing via the OpenPeppol Testbed, possibly supplemented with periodic audits or certification such as ISO 27001 depending on the requirements of the relevant Peppol Authority, rather than through a formally “qualified” eIDAS trust service. A Peppol message has a strong evidentiary position in practice, but it does not automatically enjoy the legal presumption that Article 43 grants to QERDS. For an invoice sent within a mandatory framework such as ViDA, that difference is usually of limited practical significance. For the document types the Commission explicitly links to QERDS in the EBW proposal, mandates and powers of attorney, permits and certificates, compliance documents, contractual declarations, the picture is different: precisely the documents most likely to end up in a dispute are the documents for which the legislator is now building a separate, heavier evidentiary regime.

This creates a real risk of two parallel European trust infrastructures: Peppol for invoices and procurement-related document flows, and QERDS/EBW for mandates, permits and compliance traffic. Both networks will in practice be used by the same organisations, often for document flows that are substantively linked, think of a power of attorney needed to authorise an invoice on behalf of a company, or a permit exchanged as an attachment to a tender over Peppol. Without coordination, this results in duplicate infrastructure, duplicate governance and duplicate integration costs for exactly the same end users.

This is a different question from the identity and addressing problem covered in an earlier Peppol.now article on the architectural relationship between the EBW and e-invoicing. That analysis looks at who the recipient is and where a message needs to be routed. QERDS is about something else: which legal evidentiary regime applies once the message is underway. It is the layer after addressing, before archiving, and that layer remains largely undiscussed from a Peppol perspective.

The Netherlands is already moving: the RDI opens a dialogue with Peppol Service Providers

This question is no longer purely theoretical. On 3 June 2026, the Rijksinspectie Digitale Infrastructuur (RDI), the Dutch supervisory authority for eIDAS and the Cyberbeveiligingswet, the Netherlands’ transposition of the NIS2 Directive, announced that following its own research it classifies providers of eDelivery services as trust service providers. That means these providers fall under eIDAS and under the Cyberbeveiligingswet, with obligations around risk management, duty of care and mandatory reporting of serious incidents.

Telling is where the RDI starts: the supervisor is opening a dialogue with Peppol Service Providers first in 2026, to explore what this legislation means for them in practice. The RDI itself describes eDelivery aptly as “digital registered mail”: messages sent securely with proof of arrival, exactly the qualification this article compares QERDS to.

An important distinction: “trust service provider” under eIDAS is a broader category than the QTSP status needed to provide QERDS, and it is not necessarily qualified, with lighter requirements than Article 44 sets out. But it is the step through which oversight enters the network. For Peppol Service Providers in the Netherlands, this means the question “what is the legal status of a Peppol message?” is no longer something that can be pushed down the road: the supervisor is asking that question in practice, to individual parties, already this year, and doing so without a shared answer from the network being available.

Recommendations for OpenPeppol

  1. Determine and publish a formal position on the evidentiary standing of Peppol AS4 transport relative to QERDS, in the short term. With the announced RDI conversations, this is no longer a question for the long term: without a shared position, every Dutch Peppol Service Provider will have this conversation with the supervisor separately this autumn, with the risk of diverging interpretations of the same question within the same network. A clear, authoritative interpretation, ideally aligned with the national Peppol Authorities, prevents every organisation from having to answer this question on its own.
  2. Join the RDI conversations through the Netherlands Peppol Authority, and treat the outcome as a template for other member states. The Netherlands, through the RDI, is the first country where a national supervisor concretely classifies eDelivery providers as trust service providers and opens a dialogue with Peppol Service Providers about it, but eIDAS and the underlying NIS2 Directive apply across the EU. Other national supervisors, on eIDAS and on their own NIS2 transposition, are almost certain to reach the same conclusion. By supporting the Netherlands Peppol Authority (NPA) now in its conversation with the RDI and documenting the outcome in a structured way, OpenPeppol prevents every Peppol Authority from having to go through this process separately and without coordination once their own supervisor asks the same question.
  3. Explore an optional QERDS bridge for document types that warrant it. Not every message on the Peppol network needs QERDS-level assurance, a regular invoice under EN 16931 probably does not, a power of attorney or permit possibly does. A cooperation model in which Access Points, working with QTSPs, can optionally attach QERDS-compliant proof of delivery to specific message types prevents users from having to approach an entirely separate network for those documents.
  4. Actively follow the ETSI interoperability standards EN 319 522 and EN 319 523, and assess where the Peppol eDelivery/AS4 profile can technically connect. If both worlds evolve independently, connecting them later becomes considerably more expensive than identifying shared technical touchpoints now.
  5. Use the chairing role in the WE BUILD working group constructively and neutrally, not solely to defend the existing network. OpenPeppol already chairs the eInvoicing use case (SC5) within the WE BUILD Consortium, the European Commission’s Large Scale Pilot initiative for the EUDI Wallet and the EBW. That means OpenPeppol is already at the table; the question is not whether, but how that position is used. The angle should not primarily be what the EBW means for Peppol, but how e-invoicing as a phenomenon can function well within a way of working built around the EBW, and how an interoperable network like Peppol can learn from that and contribute to it. That neutral approach pays off more in the long run than a position that only defends the interests of the existing network.
  6. Use the ongoing SML insourcing to factor in the governance implications of QERDS for mandates and powers of attorney now. This is not a hypothetical future exercise: in 2026 OpenPeppol itself is taking over the Service Metadata Locator, the DNS-based dynamic discovery infrastructure of Peppol, from the European Commission, with migration deadlines for SMP registrations and Access Point lookup in May and August 2026 respectively. Digitally provable authorisation through the EBW directly touches how those same SMP registrations and Access Point access are managed. Since this infrastructure is being rebuilt anyway, this is the moment to factor in design choices that can facilitate future EBW attributes, rather than having to do so later as a separate migration.
  7. Take into account the establishment requirement for QERDS providers from rapporteur Heinäluoma’s draft report. His proposal that providers of QERDS, wallets and cloud services be established in the EU and free from third-country control is relevant when assessing non-EU Access Point providers that might want to offer QERDS-like services within the Peppol ecosystem in the future.

As long as the regulation has not been adopted, no immediate action is required. But the legislative window is open: the technical and legal choices being made right now in the Council and Parliament will determine whether Peppol and QERDS end up functioning side by side as disconnected pieces, or as coordinated layers of the same European trust infrastructure.

Compare certified Peppol Service Providers on Peppol.now

Sources

  1. European Commission, Proposal for a Regulation establishing European Business Wallets, COM(2025) 838 final, 19 November 2025
  2. European Commission, press release “Simpler EU digital rules and new digital wallets to save billions for businesses and boost innovation”, IP/25/2718
  3. European Commission, “European Business Wallets”, Shaping Europe’s digital future
  4. Consolidated text of Regulation (EU) No 910/2014 (eIDAS), as amended by Regulation (EU) 2024/1183, EUR-Lex, Articles 43 and 44
  5. ENISA, “Security guidelines on the appropriate use of qualified electronic registered delivery services”
  6. Council of the European Union, press release “European business wallets: Council adopts negotiating position”, 9 June 2026
  7. European Parliament, Legislative Observatory, procedure 2025/0358(COD)
  8. OpenPeppol, Peppol AS4 Profile
  9. OpenPeppol, Peppol Interoperability Framework
  10. Peppol.now, “European Business Wallet e-invoicing: the architectural solution” (background on identity and addressing; this article covers a different part of the stack: the evidentiary and transport layer)
  11. Peppol.now, “European Business Wallet timeline: from proposal to regulation”
  12. WE BUILD Consortium, use case SC5 “eInvoicing”
  13. OpenPeppol, “SML Insourcing”
  14. Rijksinspectie Digitale Infrastructuur (RDI), “Aanbieders van veilige digitale post (eDelivery) vallen onder eIDAS en de Cyberbeveiligingswet”, 3 June 2026
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European Business Wallet trilogue: European Parliament takes next step

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Brussels, 1 July 2026 – With the Council of the EU having adopted its negotiating position on 9 June 2026, attention now shifts to the European Parliament. Once Parliament finalises its own position, formal European Business Wallet trilogue negotiations between the Council, Parliament and Commission can begin, aiming for a political agreement before the end of 2026.

Where does the European Parliament stand?

The file has been assigned to the Committee on Industry, Research and Energy (ITRE), with Eero Heinäluoma (S&D, Finland) as rapporteur. Heinäluoma published his draft report on 20 March 2026. Broadly, he welcomes the Commission’s proposal and supports keeping wallet use voluntary for businesses. He does propose a number of changes.

The rapporteur wants to soften the obligation for public sector bodies to accept European Business Wallets by introducing an exemption for municipalities with 10,000 inhabitants or fewer, to avoid placing a disproportionate financial burden on them. To strengthen the EU’s digital sovereignty, Heinäluoma also proposes that wallet providers, qualified electronic registered delivery service (QERDS) providers and cloud providers be established in the EU and remain free from third-country control. He further proposes that wallet data be processed and stored exclusively within the Union. Members of Parliament have since tabled hundreds of amendments to the text.

Divided views among member states

At the Transport, Telecommunications and Energy Council meeting of 5 December 2025, ministers expressed a range of views on the proposal. Countries such as Italy voiced strong support, while Estonia and Poland raised concerns, warning against duplication of existing systems and unnecessary costs. The Council’s eventual June 2026 position, with its national flexibility mechanisms, is partly a response to those concerns: member states may keep using existing national solutions, provided they remain interoperable with the European Business Wallet.

Broad stakeholder involvement

The file is also drawing attention from advisory bodies and interest groups outside the legislative institutions. The European Economic and Social Committee has already adopted an opinion on the proposal, and the Council of the Notariats of the European Union (CNUE) published its own position paper in March 2026, raising points about legal validity and powers of attorney. This broad involvement underlines that the European Business Wallet is not purely a technical file, but one that raises legal and societal questions the trilogue negotiations will need to resolve.

What follows in the second half of 2026?

With both a Council position and a forthcoming Parliament position in place, the trilogue phase can begin: negotiations in which the Council, Parliament and European Commission try to agree on a single, final text. The ambition set by EU leaders in the March 2026 European Council conclusions is a political agreement before the end of this year. If that is achieved, formal adoption by both institutions follows, after which the two-year implementation window for public administrations begins.

For Dutch and European businesses, this means the contours of the European Business Wallet are becoming clearer, even though the final text is not yet settled. Peppol.nu continues to follow the trilogue negotiations and will report once a provisional agreement is reached.

Preparing now for the European Business Wallet and the e-invoicing requirements that come with it? Use our comparison tool to find a Peppol Service Provider. Also read our earlier article on how the European Business Wallet connects architecturally to e-invoicing.

  1. European Parliament: Legislative Train Schedule, European business wallets (updated 20 April 2026)
  2. European Parliament, ITRE Committee: Draft report, 2025/0358(COD)
  3. Council of the EU: European business wallets: Council adopts negotiating position (9 June 2026)
  4. European Parliament, Legislative Observatory: Procedure file 2025/0358(COD)
With the Council’s 9 June 2026 position in place, the European Parliament can open trilogue talks on the European Business Wallet. Rapporteur Eero Heinäluoma (S&D, Finland) already published his draft report in March. His proposals: an exemption for small municipalities, an EU-establishment requirement for wallet and cloud providers, and wallet data processed exclusively within the Union. Member states remain divided: Italy backs the proposal, Estonia and Poland warn of duplication and cost. The ambition remains a political agreement before the end of 2026. Follow the developments: [link to news article]
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European Business Wallet authorisation: supervisors get 60 days

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Brussels, 1 July 2026 – In the negotiating position the Council of the EU adopted on 9 June 2026 on the European Business Wallet, the cybersecurity section was tightened considerably. The key change: national supervisory authorities will now have up to 60 days, instead of the initially proposed 30, to review an authorisation application from a would-be provider. The European Business Wallet authorisation process is becoming both more thorough and stricter than the European Commission originally proposed in November 2025.

Why the Council extended the deadline

Providers of European Business Wallets take on a sensitive role: they manage the digital identity businesses use to identify themselves across borders, sign documents and share data. A rushed or superficial review of an authorisation application could undermine trust in the entire system. By extending the review period to 60 days, supervisory authorities gain more room to thoroughly examine a provider’s technical, organisational and security setup before granting approval.

Alongside the longer deadline, the Council also specified that the European Commission must adopt implementing acts detailing exactly what documentation aspiring providers need to submit. This is meant to prevent member states from applying inconsistent evidentiary standards, supporting harmonisation across the EU. In cases of systemic non-compliance by a provider, national supervisory authorities also gain a stronger role to intervene.

Who becomes the supervisory authority?

Under the Commission’s proposal, the bodies already designated as supervisory authorities under the broader eIDAS2 digital identity framework also become responsible for overseeing European Business Wallets. They monitor compliance, review notifications and complaints, verify termination plans when a provider ceases operations, ensure providers remedy any shortcomings, and inform competent authorities of major security breaches. They can also impose effective, proportionate and dissuasive penalties.

Cooperation between member states

The existing European digital identity cooperation group, established under the eIDAS2 regulation, gains an expanded role under the Council’s position: it will also facilitate the implementation and functioning of the European Business Wallet. This is meant to prevent 27 national supervisory authorities from each developing their own interpretation of the authorisation requirements, and ensures that providers operating across multiple member states face a consistent set of demands.

What this means for the provider market

For parties considering certification as a European Business Wallet provider, the longer authorisation window means a more thorough, but also more predictable, process. Providers must demonstrate that they are established in the EU, have their principal place of business and main operations in the EU, and do not pose a security risk to the Union. They must ensure the confidentiality, integrity, authenticity, interoperability and availability of the wallet, working according to a security-by-design principle.

For Peppol Service Providers weighing whether to take on this role, or trying to understand how the broader supervisory framework relates to existing Peppol certification, this is a process worth following. The tightened cybersecurity requirements fit a broader European trend towards stricter oversight of digital identity and invoicing infrastructure. Existing certification routes within the Peppol network run through OpenPeppol and national Peppol authorities, and remain separate from the authorisation procedure for European Business Wallets. Still, it is realistic to expect the two frameworks to intersect over time, especially now that the European Business Wallet and Peppol infrastructure are already being brought together in projects such as WE BUILD.

Looking for a reliable Peppol Service Provider for your e-invoicing? Use our comparison tool. Also read our earlier article on how the European Business Wallet connects architecturally to e-invoicing.

  1. Council of the EU: European business wallets: Council adopts negotiating position (9 June 2026)
  2. Council of the EU: General approach, ST-7659-2026-INIT
  3. EUR-Lex: Proposal for a regulation on the establishment of European Business Wallets, COM(2025) 838
  4. European Parliament: Legislative Train Schedule, European business wallets
Supervisory authorities will soon get up to 60 days, instead of 30, to authorise European Business Wallet providers. That’s part of the negotiating position the Council of the EU adopted on 9 June 2026. The longer window gives supervisors more room to thoroughly check a provider’s technical and security setup before granting approval. The European Commission will also need to specify more precisely what documentation aspiring providers must submit. A stricter, but more predictable process for anyone considering provider certification. More details: [link to news article]
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European Business Wallet Peppol: e-invoicing use case in WE BUILD

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Brussels, 1 July 2026 – Within the WE BUILD consortium, one of the large-scale pilots selected by the European Commission for the EU Digital Identity Wallet, e-invoicing is one of thirteen use cases now being developed in practice. The European Business Wallet Peppol connection is getting its first concrete test environment, which matters for any Peppol Service Provider looking ahead to the coming years.

What is the WE BUILD consortium?

WE BUILD, short for Wallet Ecosystem for Business and payments Use cases on Identification, Legal representation and Data sharing, was officially launched on 3 September 2025 at a General Assembly in Amsterdam. More than 180 organisations from 26 countries are involved, coordinated by the Dutch Chamber of Commerce (KVK), the Dutch Ministry of Economic Affairs and Sweden’s Bolagsverket. The consortium is developing thirteen use cases across the Business, Supply Chain and Payments domains to test the EU Digital Identity Wallet and the European Business Wallet in practice.

E-invoicing falls under the Supply Chain domain and is defined as the structured, machine-readable exchange of invoice data between suppliers and buyers, as set out in EU legislation. According to WE BUILD, the EU Digital Identity Wallet and the European Business Wallet should make e-invoicing practically scalable by providing a consistent, secure and verifiable trust framework for identity, authentication and authorisation across the invoicing chain.

Why this matters for Peppol Service Providers

Today, identity verification in e-invoicing still largely relies on manual checks and separate platforms. Authentication and authorisation mechanisms are not yet fully standardised, and cross-border interoperability remains limited. A European Business Wallet carrying a verified attribute, such as a validated Peppol participant ID, could allow a Peppol Service Provider to initiate an SMP lookup based on verified rather than manually entered identification data. That could reduce fraud-prone steps in the invoicing chain and strengthen the reliability of cross-border Peppol transactions.

Exactly how this connection will be shaped still needs to be worked out within WE BUILD. The Peppol Conference in Brussels, held on 16 and 17 June 2026, was a concrete moment where this integration between wallet technology and Peppol routing was on the agenda. Peppol.nu is following this development and will report once concrete technical arrangements are in place.

Part of a broader programme

E-invoicing is one of thirteen use cases WE BUILD is developing across its three domains. In the Business domain, use cases include setting up a company branch abroad, digitally proving authority to act on behalf of a business, and access to the Once-Only Technical System (OOTS) for exchanging official documents between public authorities. In the Payments domain, the consortium is working on corporate payments and bank onboarding. This overlap matters: a European Business Wallet once verified for company registration or bank onboarding could, in principle, reuse the same trusted identity attribute when setting up a Peppol connection, rather than each process requiring its own separate verification.

What this means for your organisation

For businesses already using Peppol-based e-invoicing, nothing changes in day-to-day practice in the short term. The WE BUILD use case is an exploration, not an obligation. Still, it is a signal: the European Business Wallet and Peppol infrastructure are moving closer together, and organisations investing now in a mature Peppol implementation are building a foundation aligned with this broader European direction.

Want to know which Peppol Service Provider suits your organisation best? Use our comparison tool. Also read our earlier article on how the European Business Wallet connects architecturally to e-invoicing.

  1. WE BUILD Consortium: eInvoicing, Use Case SC5, Supply Chain
  2. WE BUILD Consortium: officially launched at General Assembly in Amsterdam (3 September 2025)
  3. European Commission: EU Digital Identity Wallet Pilot implementation
  4. WE BUILD Consortium: EUDI & EU Business Wallet Use Cases
E-invoicing is one of thirteen use cases within WE BUILD, the consortium testing the EU Digital Identity Wallet and the European Business Wallet in practice. The idea: a verified Peppol participant ID inside the wallet could let a Peppol Service Provider initiate an SMP lookup based on verified rather than manually entered data, reducing fraud-prone steps in the invoicing chain. Not yet an obligation, but a clear signal that Peppol infrastructure and the European Business Wallet are moving closer together. More on this development: [link to news article]
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European Business Wallet Council adopts negotiating position

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Brussels, 1 July 2026 – The Council of the European Union adopted its general approach on the proposal for the European Business Wallet on 9 June 2026. The move keeps the legislation on track for a political agreement before the end of 2026, as requested by EU leaders in March 2026. The European Business Wallet Council position now forms the mandate the Council will use to negotiate with the European Parliament.

What the Council decided

The European Business Wallet builds on the eIDAS2 framework and is meant to give companies a harmonised digital tool to identify themselves across borders, sign documents and exchange data with public and private parties. Businesses will be able to prove their identity digitally, create and share trusted documents such as licences and certificates instantly, sign and seal documents electronically, delegate authority to representatives, and communicate securely with other businesses or public administrations.

Nicodemos Damianou, Deputy Minister for Research, Innovation and Digital Policy of Cyprus, which currently holds the Council presidency, called the agreement an important step towards the EU’s ‘One Europe, One Market’ roadmap. According to Damianou, businesses should be able to operate across the single market as seamlessly as they do within their own member state.

Changes compared to the original proposal

The Council amended the Commission’s initial proposal on several points. European Business Wallets must complement rather than replace existing national B2B and B2G systems, giving member states more room to keep their own infrastructure. Digital actions carried out through a wallet gain the same legal status as paper-based processes, but national administrative and procedural requirements remain fully applicable. The Council also clarified that the new authorisation rules do not affect existing powers of attorney or legal mandates under national or Union law.

On cybersecurity, the bar has been raised for European Business Wallet providers. National supervisory authorities now have up to 60 days, instead of the initially proposed 30, to review authorisation applications from providers. The Commission must also adopt implementing acts specifying exactly what documentation aspiring providers need to submit, and national supervisory bodies gain a stronger role in cases of systemic non-compliance.

Oversight and a new European digital directory

Beyond the cybersecurity changes, the Council’s position also confirms that the European Commission will set up, operate and maintain a European Digital Directory: a web application combining a machine-readable interface for system-to-system communication with a web-based portal for verified and authorised users. The Commission will also supervise EU entities that act as wallet providers themselves. Within three years of the regulation entering into force, the Commission must also assess whether its scope needs adjusting, and whether use of the European Business Wallet should eventually become mandatory for economic operators.

What this means for businesses

Nothing changes for businesses in the short term. The Council’s position is a negotiating mandate, not final law. Still, the direction matters: once the regulation enters into force, member states will have 24 months to require public administrations to accept European Business Wallets for core functionalities, with an extra year for more complex features. Businesses are not obliged to use the wallet, but companies already working with Peppol-based e-invoicing are building the same digital infrastructure the European Business Wallet is likely to connect to.

The next step is for the European Parliament to finalise its own position, after which formal trilogue negotiations between the Council, Parliament and Commission can begin. Peppol.nu is following this process and will keep you updated on developments towards the political agreement expected by the end of 2026.

Considering an investment in Peppol-based e-invoicing? Use our comparison tool to find a suitable Peppol Service Provider. Also read our earlier article on how the European Business Wallet connects architecturally to e-invoicing.

  1. Council of the EU: European business wallets: Council adopts negotiating position (9 June 2026)
  2. Council of the EU: General approach, ST-7659-2026-INIT
  3. EUR-Lex: Proposal for a regulation on the establishment of European Business Wallets, COM(2025) 838
  4. European Commission: European Business Wallets
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European Business Wallet eIDAS 2.0: the legal basis

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European Business Wallet eIDAS 2.0: the legal basis

The European Business Wallet eIDAS 2.0 relationship is the foundation the entire regulation rests on. The European Business Wallet (EBW) is not a stand-alone initiative; it builds legally and technically on the eIDAS 2.0 regulation adopted by the EU in 2024. Understanding why the EBW works the way it does, and what guarantees the wallet offers, starts with the underlying eIDAS 2.0 architecture.

What eIDAS 2.0 actually entails

eIDAS 2.0, formally Regulation (EU) 2024/1183, amends the original 2014 eIDAS Regulation and introduces the European Digital Identity Framework. At the core of that framework is the European Digital Identity (EUDI) Wallet: a digital wallet that lets EU citizens identify themselves and share verified documents such as driving licences, diplomas, or identity cards, without repeating a verification process every time. Every member state is required to offer at least one EUDI Wallet to its citizens by the end of 2026.

The European Business Wallet as the business counterpart

On 19 November 2025, the European Commission published the proposal for a separate regulation establishing the European Business Wallet, specifically aimed at businesses rather than individuals. According to the Commission, the technical architecture and functionality of the EBW build directly on that of the EUDI Wallet. The difference lies in the nature of the credentials: where the EUDI Wallet holds personal data, the EBW holds organisational data such as company registration numbers, VAT identifiers, permits, and mandates a legal entity grants to people acting on its behalf.

Selective disclosure: the privacy architecture

A core principle of both the EUDI Wallet and the European Business Wallet is selective disclosure. The wallet does not store data centrally with a government or platform; the holder decides what is shared, with whom, and for what purpose. Credentials are issued by trusted public authorities, such as national business registers or tax authorities, and cryptographically signed to guarantee their authenticity. A business can, for example, share only its VAT number with a trading partner without disclosing other company data.

The technical framework: Architecture Reference Framework

The technical specifications for both the EUDI Wallet and the European Business Wallet are laid down in the Architecture Reference Framework (ARF), developed by the European Commission together with the member states. The EBW regulation additionally requires that providers of a European Business Wallet be established in the EU, have their main operations there, and not pose a security risk to the Union. Providers must ensure confidentiality, integrity, authenticity, interoperability, and availability of the wallet, and operate according to the principle of security-by-design.

Supervision and cooperation

In each EU member state, the same supervisory bodies already responsible for the digital identity framework are also designated as supervisory authorities for the European Business Wallet. They monitor compliance, investigate complaints, and can impose penalties for systemic violations. The European Digital Identity Cooperation Group, established under the eIDAS 2.0 regulation, also facilitates implementation and functioning of the European Business Wallet across member states.

What this means for your business

Because the European Business Wallet eIDAS 2.0 foundation is shared with the EUDI Wallet, the wallet benefits from a framework that is already partly established: defined principles around selective disclosure, cryptographic verification, and a European supervisory system. For businesses, this means the European Business Wallet does not stand alone, but is part of a broader European digital identity infrastructure in which Peppol e-invoicing may also play a role as a routing network downstream of the identity layer. A detailed analysis of that relationship can be found in European Business Wallet e-invoicing: the architectural solution.

Compare Peppol Service Providers on Peppol.now and make sure your e-invoicing already aligns with the European standards the European Business Wallet also builds on.

Sources

  1. European Commission, “EU Digital Identity Wallets”, eIDAS 2.0 regulation
  2. European Commission, “European Business Wallets”, Shaping Europe’s digital future
  3. Proposal for a regulation on the establishment of European Business Wallets, COM(2025) 838
  4. WE BUILD Consortium

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European Business Wallet timeline: from proposal to regulation

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European Business Wallet timeline: from proposal to regulation

The European Business Wallet timeline became considerably more concrete in June 2026. On 9 June 2026, the Council of the European Union adopted a general approach on the proposal for a regulation establishing European business wallets, an important step toward a political agreement with the European Parliament before the end of 2026. For businesses operating across borders within the EU, including users of Peppol e-invoicing, it is worth following this European Business Wallet timeline closely: the regulation touches directly on digital identity, document exchange, and potentially e-invoicing addressing as well.

From the Competitiveness Compass to a legislative proposal

The European Business Wallet (EBW) originates in the Competitiveness Compass that the European Commission presented in January 2025. There, the Commission announced it would develop a proposal building on the European digital identity framework (eIDAS 2.0). Between 15 May and 12 June 2025, the Commission ran a public consultation. Respondents broadly welcomed the idea of a business wallet and called for a technologically neutral, flexible, and future-proof solution.

On 19 November 2025, the European Commission published the formal legislative proposal: the regulation on the establishment of European Business Wallets (COM(2025) 838, procedure 2025/0358(COD)). The proposal forms part of a broader digital package aimed at reducing administrative and compliance burdens for businesses. Core functions of the EBW include secure identification, electronic signing and sealing of documents, and transmitting and receiving data through a qualified electronic registered delivery service. Actions carried out through the wallet have the same legal effect as actions carried out in person or on paper.

The position of the Council of the European Union

At the Transport, Telecommunications and Energy Council meeting on 5 December 2025, member states discussed the proposal for the first time at Council level. Views diverged: Italy expressed strong support, while Estonia and Poland were more sceptical, warning of duplication with existing national systems and unnecessary costs.

On 9 June 2026, the Council nonetheless adopted a general approach. Nicodemos Damianou, Cyprus’s Deputy Minister for Research, Innovation and Digital Policy, called the agreement an important step that puts the EU on track to reach a political agreement before the end of 2026, in line with the March 2026 European Council conclusions and the “One Europe, One Market” roadmap. The Council’s position introduces several refinements to the original Commission proposal: the EBW should complement existing national B2B and B2G systems rather than replace them, national procedural requirements remain applicable alongside the wallet, existing powers of attorney and legal mandates remain unaffected, and European Business Wallet providers face a higher cybersecurity threshold along with stronger involvement of national supervisory bodies in cases of systemic non-compliance. Supervisory bodies were also given more time to review applications from prospective providers: sixty days instead of the thirty initially proposed.

The position of the European Parliament

In the European Parliament, the file has been assigned to the Committee on Industry, Research and Energy (ITRE). The rapporteur is Eero Heinäluoma (S&D, Finland), who published his draft report on 20 March 2026. Heinäluoma broadly welcomes the Commission proposal and supports keeping use of the EBW voluntary for businesses. He does propose adjusting the acceptance obligation for public bodies: municipalities with ten thousand inhabitants or fewer should be exempted, to avoid imposing a disproportionate financial burden on them. To strengthen digital sovereignty, the rapporteur further argues that wallet providers, qualified electronic registered delivery service providers, and cloud providers should be established in the EU and remain free from third-country control, and that wallet data should be processed and stored exclusively within the Union. Members of the European Parliament have since tabled hundreds of amendments to the text, and the European Economic and Social Committee has also issued its opinion.

The European Business Wallet timeline: what happens next

Before trilogue negotiations between the Council, Parliament, and Commission can begin, Parliament must first adopt its own negotiating position based on the draft report and the amendments tabled. A political agreement is expected before the end of 2026, in line with the European Council’s ambition. Formal adoption and publication in the EU Official Journal are expected in the first half of 2027. From entry into force, public administrations will have 24 months to ensure they can accept the core functions of the European Business Wallet. Within three years of entry into force, the Commission must evaluate the regulation and consider whether to adjust its scope or make use of the wallet mandatory.

Timeline at a glance

  • January 2025: announced in the European Commission’s Competitiveness Compass
  • May-June 2025: public consultation on the business wallet
  • 19 November 2025: Commission publishes the legislative proposal
  • 5 December 2025: first discussion at the Transport, Telecommunications and Energy Council
  • 20 March 2026: draft report by rapporteur Eero Heinäluoma (ITRE)
  • 9 June 2026: Council adopts its general approach
  • Expected late 2026: political agreement between Council and Parliament
  • Expected early 2027: formal adoption and publication of the regulation
  • 24 months after entry into force: public administrations must be able to accept core EBW functions

What this means for your business

Until the regulation is formally adopted, participation in the European Business Wallet remains voluntary for businesses, with no direct obligations. Still, it is worth following developments closely, especially for businesses already working with Peppol Service Providers: the EBW is designed as an identity and addressing layer that can work alongside existing networks such as Peppol, not as a replacement for them. A detailed analysis of how the European Business Wallet relates to e-invoicing and the Peppol network can be found in European Business Wallet e-invoicing: the architectural solution.

Want to lay the right foundation for cross-border e-invoicing ahead of the European Business Wallet timeline? Compare certified Peppol Service Providers on Peppol.now and choose a solution that grows with EU regulation.

Sources

  1. Council of the European Union, press release “European business wallets: Council adopts negotiating position”, 9 June 2026
  2. European Commission, “European Business Wallets”, Shaping Europe’s digital future
  3. European Parliament, Legislative Train Schedule: “European business wallets”
  4. Proposal for a regulation on the establishment of European Business Wallets, COM(2025) 838
  5. European Parliament, Legislative Observatory, procedure 2025/0358(COD)
  6. WE BUILD Consortium

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European Business Wallet for SMEs: what changes administratively

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European Business Wallet for SMEs: what changes administratively

For SMEs operating within the EU, the European Business Wallet for SMEs could meaningfully simplify administration. Small and medium-sized enterprises make up 99 percent of all businesses in the European Union, and they are the ones who feel the impact of fragmented national procedures most when operating across borders. The European Commission expects the European Business Wallet for SMEs to structurally reduce hassle around onboarding, tenders, and permit applications.

What the European Business Wallet for SMEs actually offers

With a European Business Wallet, businesses can digitally prove their own identity and instantly verify that of others. The wallet makes it possible to create, store, and share trusted documents such as permits, licences, and certificates. Documents can be digitally signed, timestamped, or sealed. Businesses can also delegate others to act on their behalf with legal effect, and communicate securely with other businesses or public administrations through a single digital channel.

Less paperwork in onboarding, tenders, and permits

According to the European Commission, a single digital identity combined with a single communication channel toward public administrations means businesses operating across the EU experience up to 26 times less hassle than today. Actions that currently require paper or in-person handling gain the same legal effect when carried out digitally through the wallet. That affects processes that are especially time-consuming for SMEs: onboarding new customers and suppliers, going through tender procedures, applying for permits, and compliance checks such as anti-money-laundering (AML) procedures. Because the necessary data is available digitally and across borders, the need to be physically present or repeatedly resend documents disappears for many of these processes.

What the numbers say about the savings

The European Commission estimates that simplification measures around the European Business Wallet could save up to €5 billion in administrative costs by 2029. For European businesses as a whole, the wallet could unlock at least €160 billion in savings every year. Because SMEs make up by far the largest group of businesses in the EU, a substantial share of those savings lands with exactly the businesses that have the least budget for legal and administrative overhead.

Voluntary for businesses, mandatory for public administrations

A key principle of the legislative proposal is that use of the European Business Wallet remains voluntary for businesses. The obligation in the regulation applies solely to public sector bodies, which must be able to accept the wallet’s core functions. For SMEs, this means you can decide for yourself when and to what extent you adopt the European Business Wallet, without it becoming an obligation in the near term. At the same time, the more public administrations and larger trading partners accept the wallet, the greater the practical benefit becomes for businesses that use it.

Practical guide: what SMEs can do now

  • Track the regulation: follow the development of the legislation and the expected implementation deadlines, so you are not caught off guard by obligations from public administrations you work with.
  • Map your processes: identify which parts of your business still require heavy paperwork or repeated identity checks, such as customer onboarding or tenders.
  • Choose future-proof software: when selecting service providers, consider compatibility with digital identity solutions.
  • Secure your e-invoicing: make sure your process via Peppol is in order. The European Business Wallet does not replace this network, but may sit alongside it as an identity layer in the future.

What this means for your business

As long as the regulation has not been formally adopted, SMEs do not need to take any action to comply with the European Business Wallet. Still, it is wise to map out processes with heavy administrative overhead now, so you can benefit immediately once the wallet becomes available. A solid foundation is a reliable Peppol Service Provider for your e-invoicing, since identity and addressing solutions such as the European Business Wallet are expected to work alongside existing networks like Peppol. Read more in European Business Wallet e-invoicing: the architectural solution.

Compare Peppol Service Providers on Peppol.now and choose a solution that grows with future EU regulation.

Sources

  1. European Commission, “European Business Wallets”, Shaping Europe’s digital future
  2. European Commission, press release “Simpler EU digital rules and new digital wallets to save billions for businesses and boost innovation”
  3. European Parliament, Legislative Train Schedule: “European business wallets”
  4. WE BUILD Consortium

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Preparing for the European Business Wallet: practical steps for businesses

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Preparing for the European Business Wallet: practical steps for businesses

Preparing for the European Business Wallet does not start once the regulation enters into force, it starts now. Although formal adoption is not expected until the first half of 2027 and participation will remain voluntary for businesses, the technical standards and large-scale pilots through the WE BUILD Consortium are already underway. Businesses that lay the right groundwork now will benefit fastest once the European Business Wallet becomes operational.

Why preparation should start now

The European Business Wallet builds on the same technical architecture as the EU Digital Identity (EUDI) Wallet for citizens, established under eIDAS 2.0. While the legislative procedure is still ongoing, the European Commission and member states are developing the technical standards in parallel, and the WE BUILD Consortium is testing practical implementation across 30 countries with more than 190 participating organisations, including national business registers, banks, wallet providers, and technology companies. Businesses that wait until the regulation is fully adopted risk falling behind competitors who are preparing their processes and systems today.

Step 1: track the regulation and implementation deadlines

Follow the progress of the regulation, in particular the expected political agreement between the Council and the European Parliament and the subsequent 24-month implementation period for public administrations. There is no legal deadline for your own business, but public administrations and large trading partners you work with will have one. Know when your key public and private relationships will be required to accept the European Business Wallet.

Step 2: map your digital identity processes

Identify which processes in your business still rely on repeated identity verification, paper documents, or manual exchange of permits and certificates: onboarding customers and suppliers, tender procedures, permit applications, and compliance checks such as AML procedures. These are exactly the processes where the European Business Wallet can deliver the most time savings.

Step 3: make sure your e-invoicing is already in order

The European Business Wallet does not replace existing routing networks such as Peppol. The wallet functions as an identity and addressing layer that may eventually sit upstream of networks like Peppol. E-invoicing through OpenPeppol is already an explicit use case within the WE BUILD Consortium. Businesses that are already well connected to a Peppol Service Provider will be better positioned once identity solutions such as the EBW are eventually linked to e-invoicing addressing.

Step 4: choose providers and software with interoperability in mind

When selecting new software, ERP systems, or service providers, pay attention to compatibility with digital identity standards. Providers of a European Business Wallet must meet strict requirements: establishment in the EU, security-by-design, and guarantees for confidentiality, integrity, and interoperability. Ask your current and future providers how they are preparing for this development.

Step 5: involve the right people across your organisation

Preparing for the European Business Wallet is not just an IT question. Legal and compliance teams need to understand which mandates and powers of attorney can soon be granted digitally through the wallet, and finance teams need to understand the impact on invoicing and payment processes.

Checklist: preparing for the European Business Wallet

  • Track legislative progress and implementation deadlines for public administrations and trading partners.
  • Map processes with heavy paperwork or repeated identity checks.
  • Secure your e-invoicing through a certified Peppol Service Provider.
  • Evaluate new software and providers for interoperability with digital identity standards.
  • Involve legal, compliance, and finance teams in your preparation.

What this means for your business

Preparing for the European Business Wallet does not require major investment today, but it does require awareness and a solid foundation. By getting your e-invoicing process in order now and choosing interoperable systems, you will be able to connect faster once the wallet becomes available. A good starting point is putting your e-invoicing through Peppol in order. Read more about how the European Business Wallet relates to e-invoicing in European Business Wallet e-invoicing: the architectural solution.

Compare Peppol Service Providers on Peppol.now and lay the foundation today for tomorrow’s European Business Wallet.

Sources

  1. European Commission, “European Business Wallets”, Shaping Europe’s digital future
  2. WE BUILD Consortium
  3. Council of the European Union, press release “European business wallets: Council adopts negotiating position”, 9 June 2026
  4. Proposal for a regulation on the establishment of European Business Wallets, COM(2025) 838

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European Business Wallet e-invoicing: the architectural solution

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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/

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