European Business Wallet
A New Chapter in the EU Trust Infrastructure Part 3:
Implementation Challenges

Implementation Challenges

The success of the European Business Wallet will not be determined by its regulatory text or technical specifications alone. Its impact depends on whether governments, businesses, and digital trust providers adopt it with a shared strategic purpose: enabling verifiable, interoperable, data-driven interactions across sectors.

To achieve this, several implementation dimensions must be addressed deliberately rather than left to organic evolution:

1. Coordinating Public-Sector Adoption & Policy Alignment

Public administrations are the anchor tenants of the EBW ecosystem. They validate credentials, issue regulatory attestations, and act as relying parties in critical workflows. However, digital maturity varies widely across Member States, and many already maintain custom-built portals or national frameworks they may be reluctant to abandon.

To avoid a patchwork of partial implementation, a priorized action plan could be defined and adoptes, as follows:


Priority Action Justification
Mandate minimum EBW acceptance for key public services Prevents parallel national systems
Phased migration from document uploads to machine-readable proofs Ensures interoperability is real, not symbolic
Align with sectoral regulators early Avoids conflict between domain laws and wallet capabilities
Incentivise early adoption rather than waiting for deadlines Builds momentum and market readiness

Without policy signalling, the EBW risks becoming technically available but sparsely integrated into public workflows.

2. Sector-Specific Data Schemas & Semantic Coordination

A secure channel for verifiable attestations does not guarantee that different actors interpret those attestations similarly. For industries such as logistics, energy, financial services, and pharmaceuticals, inconsistent data semantics can render trust infrastructure ineffective. To unlock EBW value, sector bodies should:

  • create credential standards for common regulatory proofs
  • align lifecycle events (issuance, renewal, revocation)
  • harmonise attributes with global or domain standards (if applicable)
  • ensure public-sector requirements reflect these schemas

The table below shows some illustrtative but realistic examples of potential, sectoral EBW credentials:


Sector EBW Credential Types
Manufacturing conformity, safety, origin, sustainability claims
Energy guarantees of origin, emissions declarations
Health certifications, authorisations, clinical supply chain credentials
Logistics customs filings, transport permits, chain-of-custody proofs
3. Wallet Integration Into Existing Enterprise Workflows

For enterprises, value will emerge when EBW interactions integrate into operational workflows, not sit in isolation as a standalone app.

Organisations will likely need:

  • APIs to trigger attestations from ERP and procurement systems
  • credential lifecycle management integrated into IAM and governance platforms
  • automated issuance and renewal pipelines
  • connections to compliance tools
  • support for multi-entity organisational structures

If wallet interactions remain manual, adoption will stagnate. Thus, automation must be designed from the outset.

4. Credential Lifecycle Governance & Assurance Models

While issuing a credential is simple, ensuring it remains valid, trusted, and revoked appropriately, especially when done at scale, is significantly harder.

Critical governance should include provisions for:

  • clear liability models for issuers and verifiers
  • tamper-evident revocation registries
  • expiry policies that reflect regulatory timelines
  • discovery mechanisms for relying parties to validate issuer trustworthiness
  • procedures for compromised keys, dissolved companies, or fraudulent issuers
5. Avoiding Proprietary Interoperability Gatekeepers

If national or industry platforms implement EBW interoperability through exclusive APIs or proprietary middleware, the wallet ecosystem risks fragmenting behind commercial gateways.

Interoperability safeguards could be considered the following:

  • open, standardised protocols for credential exchange
  • certifiable compliance profiles for wallet providers
  • transparent interoperability testing frameworks
  • avoidance of single points of commercial control

Safeguards such these are critical to ensuring that EBW remains a public good.

6. Designing for Machine-to-Machine and Autonomous Transactions

A significant portion of future EBW value may arise not from human-driven workflows, but from automated digital systems or agentic AI workloads. To support his future, the EBW should allow:

  • organisational identities extendable to devices and autonomous agents
  • programmatic delegation of authority to processes, not only people
  • verifiable credentials designed for automated consumption
  • signed machine-readable payloads rather than static files

This prepares the EBW for industry 4.0, IoT, and cyber-physical infrastructure.

What This Means for Stakeholders

The table below summarizes the key strategic implementation priorities for each stakeholder category involved in the EBW ecosystem.


Stakeholder Strategic Priority
Governments Mandate acceptance, harmonise data models, incentivise adoption
Enterprises Integrate EBW into workflows, automate credential lifecycles
Trust Service Providers Offer end-to-end wallet-native capabilities
Sectoral Supervisory Bodies Coordinate schemas and interoperability rules
Technology Vendors Build EBW-ready integrations, not standalone portals

The next and final part of our four-part EBW analysis series provides an outlook on strategic opportunities.