Which EU member states have explicit legal language guaranteeing physical ID acceptance after eIDAS 2.0?
Executive summary
The eIDAS 2.0 package creates a binding EU-level mandate for Member States to issue European Digital Identity (EUDI) wallets and for notified electronic identification schemes to be mutually recognised [1] [2]. However, the sources provided contain no evidence that any specific Member State has adopted explicit legal language guaranteeing the continued acceptance of physical identity documents as a counterpart or fallback to the new digital regime, and the Regulation itself does not appear to enshrine a pan‑EU clause preserving physical ID acceptance in every national law [3] [4].
1. What eIDAS 2.0 actually requires at EU level
eIDAS 2.0 makes the EUDI wallet a mandatory offering from Member States and establishes interoperability and mutual recognition mechanisms for electronic IDs across the EU, requiring Member States to provide wallets within the specified timelines and to follow common technical standards to ensure cross‑border usability [2] [5] [6]. The Regulation builds on the 2014 framework that already required recognition of notified electronic identification schemes across states [1] [4]. Several briefings reiterate that the wallet and qualified trust services will carry legal effects comparable to traditional paper mechanisms for many transactions [7] [6].
2. What the reporting says — and does not say — about physical IDs
Multiple summaries emphasise digital wallets, interoperability and legal equivalence for electronic signatures and certain trust services, but none of the provided documents assert that eIDAS 2.0 abolishes or expressly preserves the legal status of physical identity documents across all Member States [1] [2] [6]. One explicit line in a specialist briefing on earlier eIDAS iterations warns that there has been no EU obligation forcing Member States to issue national eIDs under the older framework — a reminder that national practice varies and that EU measures have historically focused on mutual recognition of notified electronic schemes rather than harmonising physical‑document acceptance [3] [4].
3. National law remains the blind spot — no member states identified in the sources
The question asks which Member States have “explicit legal language guaranteeing physical ID acceptance” after eIDAS 2.0; the material provided does not include national statutes or consolidated lists of such guarantees, and therefore contains no sourceable claim that any named country has adopted that language [3] [4]. The reporting instead concentrates on the wallet rollout timetable, interoperability rules and sectoral implementation timelines — for example, private regulated sectors are expected to accept wallets for certain use cases in coming years — but these sources stop short of documenting national legal guarantees for physical IDs [6] [5].
4. Two plausible readings and why they matter
One reading — supported by the EU‑level texts and commentary — is that eIDAS 2.0 elevates electronic credentials and compels Member States to provide digital wallets while relying on mutual recognition to ensure usability across borders, leaving physical‑document rules to national law and sectoral regulation [1] [2]. The alternative, advanced in some industry pieces, is that the EU’s move toward mandatory wallets implicitly diminishes the practical need for physical documents and may prompt national legislative changes, but that implication is not the same as documented, explicit legal guarantees in any Member State that physical IDs must still be accepted [8] [9].
5. Conclusion and what would be needed to answer definitively
On the evidence in the supplied reporting, no EU Member States can be named as having explicit legal language guaranteeing acceptance of physical identity documents post‑eIDAS 2.0; the EU regulation mandates wallets and mutual recognition of electronic IDs but does not, in these sources, catalogue national provisions preserving physical ID acceptance [2] [4]. A definitive answer requires systematic review of individual Member States’ post‑eIDAS implementing legislation and sectoral rules (not present in the provided sources), because national law and administrative practice ultimately determine whether physical IDs remain guaranteed in domestic or private transactions.