The initiative in brief

With proposal COM(2025) 838, adopted on 19 November 2025, the European Commission proposes a regulation establishing European Business Wallets: a secure digital tool with which companies, the self-employed, sole traders and public sector bodies can identify and authenticate themselves across all Member States, hold and present attestations issued by authentic sources, sign, seal and timestamp documents with legal effect, manage mandates given to authorised representatives, and exchange legally valid notifications through a qualified electronic registered delivery service.

Use of the wallet is voluntary for economic operators. All public sector bodies, by contrast, will be obliged to accept it for identification, signing, document submission and notifications. A European Digital Directory will support discoverability without centralising data, and the European Unique Identifier (EUID) is designated as the identifier of wallet owners. The Commission estimates savings of up to €150 billion per year if the wallet is widely adopted. The Council adopted its negotiating position on 9 June 2026; the European Parliament’s ITRE committee followed on 10 September 2026, adding requirements that wallet providers and their cloud infrastructure be established in the EU and that data be stored and processed exclusively on EU territory. A political agreement is targeted for the end of 2026.

What GISAD welcomes

The European Business Wallet transfers the logic of the citizen wallet – decentralised storage, attestations from authentic sources, once-only submission instead of repeatedly presented paper evidence – to the economic operator. This addresses precisely the level at which Trusted WEB 4.0 aims to integrate businesses into a sovereign European digital system. The division of roles is correct: freedom of provision and of use for companies, obligation to accept for public administrations. A directory that finds without storing, notifications with provable single-step delivery, and legal equivalence of digital actions are structure, not bureaucracy.

Five corrections GISAD recommends

1. The identity card of a company must not become a movement profile of its trade. The proposed obligation to log all transactions – including those that were not completed – would, if centrally evaluable, produce a complete traffic profile of European economic life. Logs are legitimate for traceability, but they must be data-minimal, exempt from cross-transaction analysis, and kept under transaction numbers that can only be linked internally.

2. Interoperability is not linkability. The EUID, carried through every presentation and every notification, would act as a universal correlation marker across the entire business traffic of a company. GISAD recommends a one-time, signed proof of authorisation deposited with a neutral instance, followed – wherever a mere attribute suffices – by WAN-anonymous verification: identity only where identity is needed.

3. Representation without permanent person profiles. Companies act through natural persons; the binding of an action to the entity must not create a permanent, gapless profile of the persons acting. Signed instance numbers per mandate, with limited duration and single-step scope, instead of standing powers of attorney with complete person correlation.

4. Measure sovereignty instead of declaring it. The ITRE requirement that wallet, delivery-service and cloud providers be established in the EU and process data exclusively on EU territory points in the right direction – but a seat in the EU is not sovereignty; the structure is. Shareholding constructions can circumvent formal seat criteria. GISAD recommends a measurable origin and operator criterion: no US hyperscalers in the critical infrastructure of the wallet ecosystem.

5. SME participation as the success criterion. The wallet must not become a gatekeeper instrument for small European providers. Onboarding simplicity, open standards (ETSI), and verification costs that micro-enterprises and sole traders can bear will decide adoption. Participation instead of new thresholds: the wallet serves the single market only if the smallest operators can use it without depending on a few large providers.

GISAD – Global Institute for Structure relevance, Anonymity and Decentralisation · Registered in the EU Transparency Register, No. 244298340978-40

Sources: European Commission – Have your say: European Business Wallet · Proposal COM(2025) 838 (EUR-Lex) · European Commission – European Business Wallets