How eIDAS 2.0, EUDI Wallets, and the AML Single Rulebook converge on remote customer identification — documents, timeline, and MLRO decision points.
eIDAS 2.0 and the AML Single Rulebook converge on remote customer identification. AMLR Art. 22(6)(b) requires obliged entities to accept substantial or high assurance electronic identification — including EUDI Wallet credentials — while AMLA drafts the operational detail in the Art. 28(1) CDD RTS. This guide maps the timeline, consultable documents, and MLRO decision points without duplicating a full eIDAS package.
AML-impact only. eIDAS governs digital identity across the EU economy. Here we focus on CDD, remote onboarding, and vendor due diligence — cross-link to AI Act & AML classification when biometric verification is involved.
Key dates where eIDAS wallet rollout meets AMLR CDD obligations.
20 May 2024
PassedEuropean Digital Identity Framework applies — Member States begin wallet programmes; obliged entities should track wallet rollout in their markets.
24 December 2024
PassedCore implementing regulations on wallet integrity, PID/EAAs, protocols, and certification enter into force — starts the 24-month clock for national wallet availability.
10 July 2026
PassedDraft RTS on CDD information requirements (consultation closed May 2026) should specify remote verification, eIDAS attributes, and reliable sources under Art. 22(6)–(7).
31 December 2026
154d leftEach Member State must offer at least one compliant EUDI Wallet within 24 months of the first implementing acts — practical remote ID option for EU-resident customers.
10 July 2027
345d leftHarmonised CDD under AMLR Arts. 20–22 applies directly — Art. 22(6)(b) requires acceptance of substantial/high eIDAS identification where used.
24 December 2027
512d leftCertain public bodies and regulated private-sector relying parties must accept EUDI Wallets within 36 months of the first implementing acts — widens customer access to wallet-based ID.
Primary AMLA mandate
Customer due diligence — information requirementsThe information obliged entities must collect and verify for standard, simplified and enhanced CDD, including sectoral adjustments.
Level 1 eIDAS, implementing acts, EC toolbox, and AML hooks — curated for onboarding and MLRO teams.
AML Package hooks
Core CDD identification duties — Art. 22(6)(b) explicitly allows verification via substantial/high eIDAS electronic identification and qualified trust services.
AML relevance
Your primary Level 1 hook — remote onboarding policy must accommodate eIDAS means where customers can present them.
AML Package hooks
AMLA consultation (closed May 2026) on CDD fields, remote verification, and attributes required from eIDAS means and trust services.
AML relevance
Will operationalise Art. 22(6)–(7) — define minimum data, reliable sources, and non-face-to-face mitigations across the Single Rulebook.
AML Package hooks
Future guidelines on relying on another obliged entity's CDD — including remote identification chains and allocation of responsibility.
AML relevance
Successor to EBA remote onboarding guidance — governs when you can rely on a partner's wallet-based or remote CDD.
eIDAS Level 1
Amends eIDAS to establish the EUDI Wallet ecosystem — Member State issuance, cross-border recognition, and relying-party obligations.
AML relevance
Sets the legal basis for wallet-based identification that AMLR Art. 22(6)(b) cross-references via Regulation (EU) No 910/2014 assurance levels.
eIDAS Level 1
Electronic identification assurance levels (substantial, high) and qualified trust services — the direct legal hook in AMLR Art. 22(6)(b).
AML relevance
Obliged entities must accept electronic identification means meeting substantial or high assurance when customers use them for identity verification.
Implementing acts
First legally binding technical rules — wallet integrity, person identification data, electronic attestations of attributes, protocols, certification.
AML relevance
Defines what wallet-presented attributes and trust marks mean in practice for CDD evidence — watch AMLA RTS alignment on required attributes.
EC toolbox & ARF
Commission overview of wallet rollout, Cooperation Group, and implementation support for Member States and market participants.
AML relevance
Track national wallet pilots and acceptance timelines — affects when remote onboarding can rely on wallet credentials in your jurisdictions.
EC toolbox & ARF
Common Union Toolbox — Architecture and Reference Framework, reference implementation, and harmonised standards for wallet ecosystems.
AML relevance
Technical context for vendor due diligence on wallet integrations and qualified trust service providers used in KYC flows.
EC toolbox & ARF
Living technical blueprint for issuers, wallets, and relying parties — informative, not a substitute for implementing acts.
AML relevance
Use when assessing onboarding vendors claiming EUDI compatibility — understand PID, attestations, and verifier responsibilities.
EBA predecessor
Current EU standard for non-face-to-face identification — pre-implementation assessment, data reliability, and risk-sensitive policies.
AML relevance
Applies until AMLA Art. 50 guidelines replace it — baseline for remote KYC governance during the transition to wallet-heavy onboarding.
AMLR Art. 22(6)(b) references substantial and high assurance — not low.
Meets AMLR Art. 22(6)(b) threshold for electronic identification means — suitable for standard remote CDD where risk assessment supports it.
Stronger eIDAS assurance — useful for higher-risk relationships or where supervisors expect enhanced remote verification evidence.
Common remote identification scenarios as eIDAS wallets roll out alongside the Single Rulebook.
EU-resident customer offers person identification data or attestations via a Member State wallet meeting substantial or high assurance.
Customer cannot use EUDI Wallet (non-EU resident, wallet not yet live in Member State, or prefers traditional documents).
You outsource or buy SaaS for video KYC, document capture, or wallet verification integration.
Partner bank, EMI, or introducer performed wallet-based or remote identification that you rely on.
EBA predecessor (until AMLA Art. 50)
EBA/GL/2022/15 — Guidelines on the use of remote customer onboarding solutionsCommon EU standards for non-face-to-face identification and verification — pre-implementation assessment of onboarding tools, data reliability, and risk-sensitive policies under the AMLD.
EBA → AMLA migration view →