This article focuses on the risks, barriers, and limitations pertaining to the launch and adoption of the EBW and is the second of the four-part analysis on the topic. For the rest of articles, you can visit:
While the EBW introduces a compelling vision for trusted business interactions, policy ambition alone does not guarantee practical impact. The transition from conceptual infrastructure to real-world adoption requires addressing structural risks across governance, security, economics, and interoperability.
Below, we examine the most critical challenges that could limit the EBW’s success if not proactively managed.
If EBW requirements only become binding several years after regulation is adopted, organisations may postpone integration until regulatory obligations are imminent. Large enterprises in particular, tend to prioritise compliance-driven adoption rather than early adoption motivated by strategic value.
This situation might introduce risks such as:
For the EBW to catalyse innovation, policy should create short-term incentives, not only future obligations.
Even with common standards and trust services, the EBW does not automatically harmonise:
The EBW can transport verifiable data but it likely cannot ensure that actors agree on the meaning of that data.
If sectoral schemas (e.g., sustainability, customs, finance, manufacturing) remain divergent, the Wallet risks becoming a secure delivery channel for incompatible information rather than a unifying trust layer.
Thus, interoperability must become semantic, not just procedural.
A broader trust infrastructure introduces new security responsibilities for businesses, such as, protecting private keys, managing credential expiry and revocation, detecting compromised wallet instances, and validating counterparty credentials correctly.
The following attack vectors and the related risks can be identified:
| Attack Vector | Indicative Risks |
|---|---|
| Credential forgery | Fraudulent compliance documents, counterfeit product passports |
| Wallet instance compromise | Corporate account takeover, fraudulent delegation |
| Supply chain attacks | Compromised issuers or hardware providers |
| Representation misuse | Illicit use of expired or revoked mandates |
The EBW reduces fraud opportunities based on forged documents, yet increases exposure if keys or credentials are mismanaged.
Mitigation requires secure-by-default tooling, not expectation of cryptographic literacy.
The EBW is framed as infrastructure that strengthens European digital autonomy. However, complexity may result in a small number of large vendors dominating critical wallet, cloud, hardware, or identity issuance functions.
This may create new dependencies if:
To achieve sovereignty, it should be defined not only as European governance, but also as a set of EU-controlled infrastructure layers, single-vendor avoidance strategices, and effective migration pathways.
A further nuance in the sovereignty debate is that sovereignty is inseparable from legal-person identity control. When companies rely on private identity providers, platform gatekeepers, or foreign-owned commercial intermediaries to authenticate organisational identity, Europe effectively cedes sovereignty over how economic actors are recognised and trusted digitally.
The EBW attempts to correct this by shifting authority back toward European-governed trust frameworks and public-led issuers. But if EBW implementations rely too heavily on external technology stack, sovereignty benefits could be undermined.
In sort, to achieve “legal-person identity first” sovereignty, Europe must control not just the rules, but the technical and governance layers through which companies are authenticated and trusted. Otherwise, sovereignty becomes a redistribution of dependencies, not a reduction of them.
The EBW reduces friction in interactions with authorities, but also shifts operational responsibility to companies, many of which lack the capacity to manage:
To prevent inequality of benefit, the ecosystem will should require:
If left unaddressed, the EBW risks benefiting the most mature actors while replicating existing disparities.
The EBW supports exchange of attestations but does not, by itself, define a canonical source of corporate identity truth. Identity remains anchored in national company registries, which vary in:
Without consistent binding between (i) legal identity, (ii) EBW identity, and (iii) attribute issuers, relying parties may still perform parallel checks.
The wallet raises trust in presentation but does not fully solve trust in provenance.
Sectors that already operate with centralised digital platforms (e.g.finance, customs, energy, healthcare) may resist integrating horizontal infrastructure if:
Successful adoption will require coordinated governance across industries, not just compliance by public bodies.
A major strategic risk is that the EBW might be viewed merely as a digital mailbox or a document container. This would limit adoption to minimum legal obligations and prevent broader industrial transformation.
The EBW must be positioned as trust infrastructure for data-rich, identity-assured economic automation.
Without that vision, it becomes a digitised version of bureaucracy rather than an enabler of structural change.
The next article is the third of the four-post EBW analysis series and focuses on specific implementation challenges of the EBW.
