Delivering the EUDI Walletin Romania

Romania is legally required to make at least one European Digital Identity Wallet available to its citizens and residents by the end of 2026 and all public-sector institutions, along with part of private-sector actors, will be required to accept the wallet as a means for authentication.1Note 1Regulation (EU) 2024/1183, Article 5f: „1. Where Member States require electronic identification and authentication to access an online service provided by a public sector body, they shall also accept European Digital Identity Wallets that are provided in accordance with this Regulation. 2. Where private relying parties that provide services, with the exception of microenterprises and small enterprises as defined in Article 2 of the Annex to Commission Recommendation 2003/361/EC, are required by Union or national law to use strong user authentication for online identification or where strong user authentication for online identification is required by contractual obligation, including in the areas of transport, energy, banking, financial services, social security, health, drinking water, postal services, digital infrastructure, education or telecommunications, those private relying parties shall, no later than 36 months from the date of entry into force of the implementing acts referred to in Article 5a(23) and Article 5c(6) and only upon the voluntary request of the user, also accept European Digital Identity Wallets that are provided in accordance with this Regulation.” This obligation is codified in Regulation (EU) 2024/11832Note 2Regulation (EU) 2024/1183 of the European Parliament and of the Council of 11 April 2024 amending Regulation (EU) No 910/2014 as regards establishing the European Digital Identity Framework., and has directly applicable deadlines, with sanctions and reputational consequences attached. Regulation (EU) 2024/1183, hereinafter referred to as eIDAS 2, amends the 2014 eIDAS framework3Note 3Regulation (EU) No 910/2014 on electronic identification and trust services for electronic transactions in the internal market (eIDAS)., which was a cross-border framework for trusted electronic identification and trust services, built on mutual recognition of nationally notified eID schemes. By the time the Commission evaluated it in 2020, the instrument had only partially delivered on its 2014 objectives: fourteen Member States4Note 4Including the UK. had notified nineteen eID schemes, 59% of EU citizens were covered in principle, and only an estimated 14% of public service providers actually offered eIDAS authentication.5Note 5European Commission, Evaluation study of the Regulation no. 910/2014 (eIDAS Regulation) SMART 2019/0046 — Final Report (2020). Take-up in the private sector, where the bulk of identity transactions occur, was negligible. The EPRS briefing of March 2022 summarised this diagnosis: limited scope, absence of incentives for Member States and private actors to join the cross-border infrastructure, diverging national interpretations in trust services, and a rigid approach to attributes that left most real-world use cases outside the Regulation.6Note 6EPRS, Revision of the eIDAS Regulation: findings on its implementation and application — Briefing (2022).

Against that backdrop, the Commission’s June 2021 amending proposal (COM (2021) 281) introduced a structural shift: each Member State would be required to issue a European Digital Identity Wallet. After inter-institutional negotiations, the revised instrument was adopted and entered into force in May 2024. In addition to the regulatory framework, mechanisms meant to facilitate the deployment of the national solutions per se were put in place: the architecture and reference framework provided by the Commission, the testing carried out — and in some cases still ongoing — in large-scale pilots such as POTENTIAL, EWC, NOBID and DC4EU and, more recently, APTITUDE and WE BUILD.7Note 7„What Are the Large Scale Pilot Projects — EU Digital Identity Wallet”, accessed 9 June 2026, ec.europa.eu/digital-building-blocks.

With the deadline approaching, Romania still has no operational wallet, despite important steps being made regarding the governance of this project. The scale of the task is sometimes misunderstood: the EUDI Wallet, far from being just a technical solution, is a sovereign infrastructure for digital identity: a Personal Identification Data (PID) scheme, a qualified electronic signature instrument, a potential container for mobile driving licences, diplomas, health credentials and dozens of other attestations, a certified cryptographic architecture, and an interoperable tool recognised across 27 Member States and the EEA. Developing and operating the wallet ecosystem requires the coordinated effort of nearly all Romanian public institutions and a significant share of private-sector actors, as well as a permanent capability, both technical — to oversee the development, to facilitate the issuance of attributes, the integration with the wallet — and strategic, to ensure mass adoption.

„[…] the modular nature of the wallets’ architectural paradigm inherently creates some complexity, given the complementary roles of various ecosystem participants, such as credential issuers, wallet providers, and trust service providers. Unlike traditional centralized digital identity models, in which all of these roles might have been played by a single entity, implementing a wallet ecosystem requires active orchestration among actors. Although there are many benefits to this orchestration, such as scalability and fewer duplicative investments, operationalizing such an ecosystem can introduce some initial setup complexities and an ongoing governance overhead.”

World Bank, Digital Wallets: A New Paradigm (2026) p. 49

The teams and models for the EUDIW rollout in the different Member States vary: some countries have mature eID schemes (example: Denmark, Italy, Netherlands, Sweden), some already have a wallet-like solution (example: Greece, Poland, Spain) that they will use as a base for the EUDI wallet, while some countries lack eID schemes, or schemes that have large adoption (example: Germany, Slovenia). Regarding the implementation per se, there is no public information that one company solely develops the wallet for a Member State and the most common scenario is that they make use of a combined in-house team, external experts as consultants and open-source software but with in-house development and private contracting for specific blocks of the wallet infrastructure. Looking at what is needed from a wallet developing team, there is some clear guidance. The technology is, to some extent, quite new; IT resources are generally quite scarce and expensive. In some parts there is need for very specialised expertise, especially in correct use of cryptography. There is also a clear need for experts who can understand both the technology and the relevant regulations and standards. Understanding legacy systems is important, but that may differ depending on if the EUDI wallet is an upgrade or something new to the national context.

There are also a number of ways to approach wallet development and the choices that need to be made. These include how the Wallet Secure Cryptographic Device (WSCD) should be handled, whether it should be an MVP-wallet containing only the PID, whether there is need for issuer and verifier capabilities, whether the wallet should be only in smartphones, web wallet or both. But the Wallet Provider role, as defined in the ARF, is essentially a technical function: its focus is not on adoption, not on how government persuades citizens to install and use the wallet, how it brings hospitals, banks, universities, and transport operators into the relying party ecosystem, nor how it sequences the addition of new attributes over time to steadily increase the wallet’s utility.

This is why, besides the technical profiles, strategic internal capability is indispensable in a way that goes beyond filling ARF roles, as a country may have a plan for who will be the Wallet Provider and the PID Provider, but the success of a national wallet will depend on a plan for who will own the adoption strategy, manage the integration pipeline for relying parties, maintain a public-facing attribute roadmap, or make the ongoing investment decisions that keep the wallet competitive and relevant as user expectations evolve. All the previously mentioned functions require different profiles, profiles that combine product thinking, stakeholder engagement, data-driven iteration, and long-term strategic focus.

This paper argues that, to deliver a successful EUDI wallet and drive adoption, Romania needs a taskforce placed at the centre of the government equipped with technical and strategic capability for developing the wallet and driving adoption.

The paper opens by grounding the analysis in the national context: Romania’s digital-government track record and the current state of play on the RoEUDIW, from the governance committee and the allocation of institutional roles to the choice of technical solution (I). It then draws on an academic literature overview on the notion of delivering and policy coordination, which supports the idea that new policy priorities, such as the EUDIW, should not only benefit from strong political sponsorship but also be doubled by a development in the operational capability, a direction that an increasing number of countries adopt, acknowledging the importance of development of in-house expertise (II). Building on the Wallet Provider function from the architecture reference framework and the indispensable strategic dimension that accompanies it, we highlight the existence of this ambivalent capacity in other EU countries by exploring team structures from France, Poland and Sweden (III). Finally, we propose technical and strategic profiles to be considered by the Romanian Government for a successful implementation and adoption of the EUDIW (IV).

Romania has repeatedly ranked last in the EU on the e-government usage dimension of the Digital Decade indicator, with a score that remains roughly a third of the EU average in the 2025 assessment. There is a familiar pattern in digitalisation efforts in Romania: fragmented mandates across ministries and agencies, long procurement cycles, oversized tenders, parallel solutions that do not interoperate, lack of integration with existing technical solutions and low citizen adoption.

What makes this pattern particularly damning is that it is not new: as far back as 2016, the OECD Public Governance Scan examined digital government as one of five priority areas and identified the same structural weaknesses.8Note 8OECD, OECD Public Governance Reviews: Romania Scan 2016, OECD Public Governance Reviews (OECD, 2016), doi.org/10.1787/d7fe89a4-en. The 2016 report called on Romania to overcome fragmented efforts across public administration by building a shared, system-thinking culture grounded in national key enablers such as eID, interoperability frameworks, and a government cloud strategy, stating that the country faced the challenge of developing more articulated, coherent and sustainable digital government policies. The report was clear that the real challenge lays ahead: putting in place the right policy processes and coordination mechanisms, and monitoring implementation and impact. Nearly a decade later, the 2023 OECD Digital Government Review9Note 9OECD, Digital Government Review of Romania: Towards a Digitally Mature Government, OECD Digital Government Studies (OECD Publishing, 2023), doi.org/10.1787/68361e0d-en. and the 2025 Digital Nation report for Edge Institute10Note 10Digital Nation for Edge Institute, Digital Governance Framework for Romania (2025). found that challenge still unmet, with the same vocabulary reappearing almost verbatim: fragmentation, missing coordination, absent accountability.

A 2026 European Commission study on the EU’s critical digital capacities identifies, as structural weaknesses across Member States, a „siloed national approach to technology, particularly in the deployment of interoperability technologies”11Note 11European Commission, Technopolis Group, Study on the EU’s critical digital capacities deployment beyond 2027 — Final report (Publications Office of the European Union, 2026), data.europa.eu/doi/10.2759/0673677, p. 174. and „fragmentation in the implementation of cross-border services despite regulations”. Romania’s digital-government record is therefore not an outlier, but it is one of the most acute expressions of a problem the Commission documents across the Union. That, however, makes it no less urgent to address; what it means is that without deliberate structural intervention, the result is predictable.

In other words, repeating this pattern with the EUDI Wallet is highly likely to produce the same outcome at a higher cost, both from financial and opportunity perspectives. It is important to acknowledge that a weakness can, in this case, become a strength, as Romania does not have the same legacy as many other first-mover countries and there is a great potential to leapfrog into the newest technologies and ways of digital interactions. The wallet infrastructure can be an important tool to make life easier for Romanians and lower costs for the public sector as they can focus on one solution for authentication and attribute presentation, rather than many disparate and outdated solutions.

Important steps have been made recently regarding the governance of the wallet. Decision No. 183/2026, issued by the Prime Minister on 12 May 2026, establishes the RO EUDIW Committee: a consultative inter-institutional body tasked with coordinating institutional, legal, and technical steps required to develop and implement Romania’s national ecosystem for the EUDIW. The Committee is chaired by one of Romania’s Deputy Prime Ministers and has two other permanent members: the Ministry of Economy, Digitalisation, Entrepreneurship and Tourism, and the Ministry of Internal Affairs, while the Special Telecommunications Service participates through a senior management representative. According to the decision, the Committee may establish thematic working groups drawing on experts from public and private entities. The RO EUDIW Committee is a soft instrument: a consultative space in which, at least theoretically, consensus is formed among the institutions. Its decisions are not binding, unless codified in legislation initiated by its members.

In June 2026, the Government set out the principal institutional roles for implementation via a Press Release that is soon to be codified in national legislation.12Note 12Romanian Government, Guvernanță, roluri instituționale și deschidere către parteneriate strategice în implementarea Portofelului de Identitate Digitală (RoEUDIW), Press release, 26th of June 2026. Available at: gov.ro The Ministry of Economy, Digitalisation, Entrepreneurship and Tourism acts as the supervisory authority for the EUDIW ecosystem and as the single point of contact for cross-border cooperation, coordinating governance, the drafting of normative acts, the relationship with public and private actors, and the technical monitoring of the solutions deployed. The Ministry of Internal Affairs is the official provider of the mobile application (RO Wallet) and of the backend infrastructure; it issues Person Identification Data and provides attestations for age verification, hosting the solution in its online hub of services. The Special Telecommunications Service holds four roles: Access Certificate Authority, issuing access certificates to ecosystem participants; Provider of Registration Certificates for entities registered to offer services through the wallet; Registry Administrator for the centralised registry of relying parties; and Attestation Scheme Provider for the national schemes of qualified and non-qualified attestations, with the registry and attestation infrastructure hosted in the Government Private Cloud (the internal cloud component).

It must be underlined that the June 2026 allocation is, for now, a press release, not even a project in public consultation, therefore this form is not definitive, and it is to be hoped that it will not prove exhaustive either. For now, no role is foreseen for the Romanian Accreditation Association (RENAR)13Note 13Regulation (EU) No. 910/2014, as amended by Regulation (EU) No. 2024/1183, Article 3, point (18): „»conformity assessment body« means a conformity assessment body as defined in Article 2, point 13, of Regulation (EC) No 765/2008, which is accredited in accordance with that Regulation as competent to carry out conformity assessment of a qualified trust service provider and the qualified trust services it provides, or as competent to carry out certification of European Digital Identity Wallets or electronic identification means”, Romania’s single national accreditation body under Regulation (EC) No 765/2008; for the Romanian Digitalization Authority (ADR), which under the eIDAS framework remains the supervisory body for the qualified trust service providers that issue QEAAs into the wallet14Note 14The Ministry of Economy, Digitalisation, Entrepreneurship and Tourism is described as the supervisory authority for the EUDIW ecosystem and the single point of contact for cross-border cooperation. „Supervisory authority for the EUDIW ecosystem”, however, is a national umbrella label: eIDAS 2 speaks of a supervisory body for trust services and, separately, of the oversight of wallet providers. The trust-services supervisory function is precisely the competence that HG 89/2020 vested in ADR. Since ADR now sits under this ministry’s coordination, the natural reading is that its supervisory function continues inside the ministry, and the drafting should say so to avoid leaving an apparent gap.; for the National Cyber Security Directorate (DNSC), the natural author of the national certification scheme, whose absence means that, as currently configured, the Special Telecommunications Service (STS) and the Ministry of Internal Affairs (MAI) would each supervise their own cybersecurity; or for the National Supervisory Authority for Personal Data Processing (ANSPDCP), without whom there is no clear mechanism for assessing the proportionality of the data that relying parties request from citizens’ wallets.

On the technical strategy, Romania has decided to adopt and deploy the German EUDI Wallet solution, following an assessment of the solutions at various stages of implementation across other Member States and of their long-term ecosystem development strategies. The solution is developed as open source, which the Government presents as giving Romania free access to source code, certification schemes, and technical components that can be adapted to national needs, avoiding the cost of building a complex infrastructure from scratch and aligning Romania with a collaborative European approach. Government officials described the choice as the result of a „rigorous assessment of other solutions”, but no evaluation criteria or shortlisted alternatives have been published yet. How the solution will be adapted to Romania’s own identity infrastructure is yet to be defined.

Romania has a solid basis for implementation: in June 2025, it started the nationwide rollout of the electronic identity cards, with over 1.5 million cards issued in over a year.15Note 15Publicly available data from the Ministry of Internal Affairs. Additionally, from December 2025, the Ministry of Internal Affairs launched eIDentity, the dematerialized version of the electronic identity card, which allows for selective disclosure and the sharing of the data via a generated QR code valid for 10 minutes. These two instruments that are already available, although highly underused because of lack of integration with public or private services16Note 16On low adoption of eID in Romania: Melany Pașca, „Identitate electronică în România: Cauzele adopției scăzute și direcții de acțiune”, Edge Institute (2026), edgeinstitute.ro, will facilitate the task of building the national wallet.

Delivery of the Romanian EUDI wallet is announced to be structured in successive phases. The first phase, running through 2026, will focus on implementing the first version of the RoEUDIW mobile application, issuing PID and developing the age-verification functionality, and finalising the regulatory framework.

On the market structure, the Government has indicated that it intends, in time, to open the market to private wallet providers, conditional on certification under the national scheme. The Government has also invited organisations and interested actors willing to provide technical assistance on the development of the wallet to submit a letter of intent to the Ministry of Economy, Digitalisation, Entrepreneurship and Tourism, expressing thereby its openness to sign memoranda of understanding similar with the one signed with Mastercard.17Note 17Memorandum of understanding between the Government of Romania and Mastercard Europe S.A., available at: sgg.gov.ro

Taken together, these two pictures frame the task ahead. On one side is a digital-government record defined, across a decade of external assessments, by the same recurring weaknesses: fragmentation, missing coordination, and absent accountability. On the other is a set of decisions taken in the first half of 2026 that, for the first time, give the RoEUDIW project the basis of a governance structure that is yet to be codified in legislation, a technical choice in the form of the German open-source solution, and even a sort of head start, with the electronic identity card and eIDentity. Nonetheless, the question of human resource is still unaddressed. To technically adapt the German solution to the Romanian context, develop and maintain it over time, expertise in the field is required. It is important to keep in mind that the decision to adopt the German open-source solution, while sensible as a reuse-first strategy, does not reduce the internal capacity Romania needs: it certainly lowers the cost of the first build, but the state still has to integrate the solution with national registers and the PID issuance process, operate it at production scale, and maintain it over time.

Moreover, adoption is precisely the point at which Romania’s previous digital efforts have repeatedly stalled, strategic human resource is indispensable for the success of this project. The electronic identity card and eIDentity already demonstrate that Romania can deliver capable instruments and still see them go underused for want of integration with public and private services. The wallet risks the same fate unless the gap between responsibility, capability and actual adoption is owned by teams of experts with the mandate and capacity to close it, as responsibility assigned without being doubled by the development of capacity is, as we will show next, most likely to result in an implementation failure.

The academic literature on policy coordination captures the previously presented dynamic precisely. Peters shows that policy coordination is one of the oldest challenges for governments, and that the absence of explicit coordinating structures reliably produces fragmentation even when individual agencies are competent in the matter. Using the example of the Finnish government, which „developed a program management system that required a new government to select four or five priorities after its election […] (that) cut across existing departments and require the involvement of these departments”, Peters illustrates how governments can produce enhanced policy coordination.18Note 18B. Guy Peters, „The Challenge of Policy Coordination”, Policy Design and Practice 1, no. 1 (2018): 7, doi.org/10.1080/25741292.2018.1437946.

The integrative capacity framework, as seen by Vince et al., identifies four conditions under which integration fails: weak coordination and coherence; unclear accountability; insufficient dedicated resources; and inadequate institutional architecture.19Note 19Joanna Vince et al., „Understanding Policy Integration through an Integrative Capacity Framework”, Policy and Society 43, no. 3 (2024): 381–95, doi.org/10.1093/polsoc/puae027. Formulated positively in the paper: „Policy coordination and coherence; accountability, transparency, and legitimacy; resourcing and adequate institutional architecture were identified as conditions for integration.” Romania’s EUDI Wallet context is very likely to encounter all four. Knill, Steinebach and Zink, surveying the European literature on bureaucratic overload, show that when policies pile up in organisations without commensurate increases in dedicated capacity, the organisations develop „policy triage” behaviour, meaning that some tasks are quietly delayed or neglected in favour of others with more immediate visibility20Note 20Christoph Knill et al., „How Policy Growth Affects Policy Implementation: Bureaucratic Overload and Policy Triage”, Journal of European Public Policy 31, no. 2 (2024): 324–51, doi.org/10.1080/13501763.2022.2158208. and the EUDI Wallet is exactly the kind of politically abstract, technically demanding, long-horizon project that might be first to be triaged out of existence in an overloaded administration.

The implementation unit model draws on a well-documented body of academic and practitioner literature on centre-of-government delivery units. The canonical case is the UK Prime Minister’s Delivery Unit (PMDU), established by Tony Blair in 2001 under Sir Michael Barber, which developed the practice now known as „deliverology”. Clement’s work on the PMDU documents how a compact team of roughly 40 professionals, reporting directly to the Prime Minister through the Cabinet Secretary, with an annual budget around €2 million, was able to materially accelerate delivery across health, education, crime and transport priorities.21Note 21Michelle Clement, The Art of Delivery: The Inside Story of How the Blair Government Transformed Britain’s Public Services (Biteback Publishing, 2024). Blair himself later described the approach as „quite revolutionary, more so than we realised at the time”22Note 22King’s College London, „Blair’s »delivery revolution« Unveiled: New Book Reveals inside Story of Government Reform”, accessed 8 June 2026, kcl.ac.uk.. Research by the World Bank23Note 23World Bank, Driving Performance from the Centre: Malaysia’s Experience with PEMANDU (World Bank Group, 2017). and the Centre for Public Impact24Note 24Centre for Public Impact, „The Prime Minister’s Delivery Unit (PMDU) in the UK” (2016). has documented the spread of the delivery-unit model to different countries and the conceptual synthesis by Williamson25Note 25Williamson T and others, Delivery Approaches to Improving Policy Implementation: A Conceptual Framework (Learning Generation Initiative, 2024). and colleagues identifies the core functions of effective delivery units, the main ones being: goal-setting and prioritisation; data-driven performance management; problem-solving and unblocking; stakeholder engagement; and capacity-building, all five being directly relevant to the EUDI Wallet context. The same literature flags the well-known pitfalls: delivery units that lose political sponsorship, become monitoring-only without delivery capability or grow beyond their effective size, which inform the unit’s design below.26Note 26Ibid. On task forces specifically, the comparative literature by Nair and Garg distinguishes task forces that are purely advisory from those that are operational27Note 27Sreeja Nair and Akshat Garg, „How Do Governments Learn from Ad Hoc Groups during Crises? From SARS to COVID-19”, Policy & Politics 52, no. 4 (2024): 625–47, doi.org/10.1332/03055736Y2023D000000011. and this distinction matters because it determines skill mix and reporting line in part IV of this paper, which is oriented towards operationality.

Romania has itself experimented with structures of this type. In March 2014, with World Bank support, a Delivery Unit was established within the Prime Minister’s Chancellery, explicitly modelled on the UK PMDU: it concluded delivery agreements with line ministries specifying targets, metrics, and deadlines across four priority areas, and produced the Romanian Fiscal Authority (ANAF)’s Virtual Private Space, launched in September 2014. Yet the unit did not survive the political cycle, as it depended on the personal sponsorship of the sitting Prime Minister and on externally funded advisory support.

More recently, the NRRP institutional framework established under Emergency Ordinance No. 124/2021 required ministries responsible for reforms and investments to create dedicated implementation structures, staffed where necessary with fixed-term contractual personnel recruited outside the approved organisational chart. In the digital domain this produced two such units: the Task Force for the Implementation and Monitoring of Digital Transformation Reforms and Investments within the Ministry of Economy, Digitalisation, Entrepreneurship and Tourism, and the Unit for the Implementation of Digital Transformation Programmes within the Romanian Digitalisation Authority. Their limits are instructive and five design requirements, directly linked to the pitfalls identified in the academic literature, follow for any successor:

• proximity to a strong political sponsor with clear ownership of the project;
• basis in an act with the force of law, so that the unit’s existence and reporting lines are more likely to survive a change of government;
• a stable multiannual budget line and focus on transfer of expertise to permanent internal resource rather than dependence on donor-funded advisers whose expertise leaves with the contract, where possible;
• a mandate defined by outcome, through formal delivery milestones, published targets, so that authority derives from an institutionalised process, besides personal access to one office-holder;
• deliberate continuity mechanisms via documented methods, with evolution into a permanent structure envisaged from the outset.

The OECD Digital Government Outlook 202628Note 28OECD, „Digital Government Outlook 2026: From Foundations to Transformational Impact”, OECD Publishing, 15 June 2026, doi.org/10.1787/0496b2bc-en., published in June 2026, provides guidance on why internal capacity matters, and why outsourcing alone cannot deliver the kind of digital infrastructure countries need to build. One of the report’s central arguments is that governments must retain sufficient internal expertise to govern, oversee, and adapt digital systems over time.

„Governments need the right balance between outsourcing and in-house capability to sustain transformation and preserve agency. External providers can bring skills and capacity that government does not have and accelerate delivery. But over-reliance hollows out the internal knowledge and judgement that governments need to define what they want, assess whether they are getting it, hold suppliers to account and adapt systems when circumstances change. Several OECD countries are actively rebuilding internal digital capability. The goal is not to bring everything in-house, but to ensure government retains the core expertise needed to govern digital transformation responsibly.”

OECD, Digital Government Outlook (2026) p. 74

The OECD is clear that the answer to „outsource or develop internally” is not binary. External providers play a legitimate and important role, particularly for specialised capabilities that are difficult to build internally at pace, but what the government must not outsource is the core judgement and oversight function. The report documents a clear direction among OECD countries, as the United Kingdom introduced controls on consultancy spending and is investing in permanent digital, data and technology roles across government, Canada is rebalancing spending away from external professional services, Australia is reducing labour-hire while reinvesting in internal data and digital capability, backed by a dedicated workforce plan through 2030 and France has strengthened central digital capacity through its Interministerial Digital Directorate, reducing fragmentation and dependence on outsourced delivery.29Note 29Ibid, p. 79. The OECD also highlights the specific danger of poor internal capacity in procurement decisions. Without sufficient understanding of the technology being procured, governments cannot evaluate vendor proposals critically, cannot manage contracts actively, and cannot understand the long-term implications of their choices.30Note 30Ibid, p. 75.

The recommendation of this paper should therefore not be read as a case to eliminate external contractors in building the national wallet, but to ensure the development of internal capability, organised as a governmental taskforce, that holds the institutional knowledge, technical oversight capability, and strategic judgement that no outsourcing arrangement can nor should substitute.

The ARF defines fifteen distinct roles within the EUDIW ecosystem, spanning primary roles such as the Wallet Provider, PID Provider, and Relying Party. Each role carries well-defined responsibilities within the trust architecture, and most Member States, including Romania, have made reasonable progress in assigning these roles to existing institutions or planned organisational structures, as we have seen in part I.

The Wallet Provider role in particular is relatively well understood: it covers making the wallet solution available to users, providing Wallet Trust Evidence and Wallet Unit Attestation. How a Wallet Provider team is structured — its size, its composition, the balance between in-house and contracted expertise — directly shapes what the wallet can do and how fast it can evolve.

Three national implementations will be analysed — France, Poland, and Sweden — as case studies in the design of wallet delivery organisations, since each country has made distinct choices: France has built a government agency issuer-model with a developer-facing ecosystem strategy; Poland has sustained a large in-house Scrum team over nearly a decade and uses adoption data to drive product decisions, aiming to switch to an EUDI-compliant wallet in time; Sweden has articulated a layered four-tier governance model that explicitly separates strategic, coordination, product, and execution responsibilities. Together, these profiles illustrate that governance architecture is a first-order design decision and the comparison surfaces actionable patterns for other implementing authorities, procurement bodies, and policy teams grappling with the same organisational questions that eIDAS 2 poses across all 27 member states. The common denominator, besides the technical human resource allocated to the EUDI wallet project, is the focus on adoption, even at incipient stages.

1. France

France is among the more technically mature EU member states on eIDAS 2 implementation. France Identité already covers several mandatory wallet capabilities (PID issuance, proximity presentation, online presentation). The OpenID4VP endpoint positions France to meet the regulatory deadline. Open items as of early 2026 include: wallet certification, relying party registration, and passport-based onboarding. Launched in February 2024, the French wallet already has around 4 million users and around 800,000 LoA high users. The digital wallet project was formally incubated within ANTS (Agence Nationale des Titres Sécurisés) — the agency that also manages passports, driving licences, and vehicle registrations. ANTS operates under the Ministry of the Interior and is the designated eIDAS notified scheme operator for France.

France’s approach has been shaped by a deliberate choice to build on top of existing federated login infrastructure (France Connect) rather than replace it. France Connect, launched in 2016, already had tens of millions of users across e-government services. France Identité was designed as a higher-assurance complement: where France Connect supports LoA Low/Substantial for everyday public services, France Identité targets LoA Substantial and High, including legally sensitive and proximity use cases. France Identité is developed within ANTS and the team operates a continuous delivery model, based both on internal capacity and external contractors, with regular public releases through distinct build stages (development; alpha; beta; stable). A dedicated developer relations function supports the third-party ecosystem, including the public playground environment.

The organisational model places full accountability for the wallet at agency level, with the Ministry of the Interior setting policy parameters and ANTS retaining operational and technical autonomy, with an internal team of more than 100 people, with technical and strategic profiles.

ANTS has made a deliberate decision to act as credential issuer into third-party wallets as well as operator of its own wallet application — the „issuer-as-platform” model. The agency has built a dedicated developer playground environment featuring mock credentials (PID, age verification) that third-party developers and relying parties can use. Private ecosystem wallets can receive ANTS-signed Verifiable Credentials, enabling a model where the state acts as issuer into third-party wallets without requiring citizens to use the government wallet exclusively.

Romania’s current institutional context offers a promising, if still embryonic, foundation for the kind of taskforce envisioned here, placed at the centre of the government. The RO EUDIW Committee is chaired by the Deputy Prime Minister, so the responsibility for political coordination has already been assigned, although it would benefit from codification in primary legislation. The critical question is whether the Deputy Prime Minister (and, therefore, the Committee) will be resourced with an executive arm empowered to act as a genuine delivery and strategy taskforce.

The taskforce should draw staff from relevant institutions, whether on a full-time basis or through a modest allocation of several hours per week, supplemented by newly recruited specialists and, where necessary, ad hoc support from private sector companies. To preserve competitiveness on remuneration, it should benefit from a clear and stable budgetary allocation, with remuneration that can be supplemented from EU funds. For example, within the framework of the 2021–2027 programming period, Romania has the possibility to amend the existing project financed under the Smart Growth, Digitalisation and Financial Instruments Operational Programme (POCIDIF) in order to extend its scope of intervention to encompass the development, piloting, and deployment of the wallet.

Proximity to the centre of government is, in our view, non-negotiable: it gives the taskforce the flexibility required for fast delivery, the political authority needed to coordinate across ministries and hold attribute providers to account, and a natural path towards its eventual absorption into a national digital authority that should likewise sit at the centre of government. Within the centre of government, two institutional homes are plausible: the working apparatus of the Deputy Prime Minister in charge of state reform, or the Prime Minister’s Chancellery. We recommend the former. The function of a Deputy Prime Minister without portfolio charged with coordinating state reform already has a legal basis in O.U.G. No. 32/2025 and disposes of its own working apparatus, even if the legislation governing it, both primary and secondary, remains underdeveloped. The relationship would also be mutually reinforcing: the taskforce gives the Deputy Prime Minister an instrument of execution, while the Deputy Prime Minister gives the taskforce political weight, strengthening both positions and creating a solid basis for the central coordination of digital transformation.

Like the Chancellery itself, the Deputy Prime Minister’s working apparatus is a structure without legal personality, financed through the budget of the General Secretariat of the Government. The objection that a unit anchored with the Deputy Prime Minister would lack administrative resources therefore applies with equal force to one anchored in the Chancellery: both depend on the General Secretariat of the Government for premises and expenditure, and both can be consolidated through the same legislative clarification. Nor does the Chancellery offer superior continuity, as in some governments it is absorbed into the Secretariat, just as nothing guarantees that a future government will include a Deputy Prime Minister for state modernisation or, for that matter, a ministerial portfolio for digitalisation. No host institution is, therefore, safe without clear legislative consecration of its mandate, budget, scope, and institutional levers, which is precisely why the taskforce’s mandate, reporting line, and resources must be fixed in the law implementing eIDAS 2.

The taskforce’s mandate should be understood in two phases. In the longer term, once a solid foundation for the EUDI Wallet has been established, the taskforce should evolve into a permanent digital delivery structure within the Romanian government, progressively expanding its capacity and taking on the oversight of other projects, before ultimately being absorbed into a reformed Authority for the Digitalisation of Romania, repositioned at the centre of government. In the near term, it should fulfil the Wallet Provider function, taking ownership of the technical build and product roadmap from the outset, departing on this point from what the Government has announced. Far from sidelining the Ministry of Internal Affairs, this would relieve some of the pressure on it: the Ministry is already responsible for Person Identification Data and is building the age-verification pipeline, and its limited resources would be better invested in the data it actually holds (driving licences, civil status documents, criminal record certificates and other special permits), which make excellent candidates for the first publicly issued attestations in the wallet.

Cross-ministerial coordination further reinforces the case for positioning this structure at the centre of government. Persuading the Ministry of Health to become an attribute provider, or the Ministry of Education to integrate as a relying party, despite the codified obligation under the eIDAS 2 Regulation, requires a level of authority that a line ministry or agency is unlikely to hold. Without seniority and an explicit political mandate, even a well-resourced institution would struggle to convene the actors it needs to convene. Assigning the Wallet Provider function, together with strategic oversight, to an existing institution may work in more digitally mature contexts. In Romania’s case, however, it carries substantial risk, given the country’s documented history of fragmented digital mandates which means that coordination failure is not a theoretical concern. Compounding this, the public sector’s rigid legislative framework on hiring, with pre-established salary scales that are not competitive, bureaucratic recruitment processes, and limited flexibility on working arrangements, would make it genuinely more difficult to attract and retain the specialists this work demands. This model is consistent with the most successful precedents identified in the delivery unit literature, where strategic capacity was deliberately placed at the centre of government rather than inside a line ministry, and it responds directly to the OECD’s repeated recommendation to build cross-cutting coordination capacity with real authority and internal capacity. Part of the Ministry of Internal Affairs’ staff could, moreover, contribute directly to the development of the wallet through the taskforce.

A similar rebalancing is warranted for the responsibilities announced for the Ministry of Economy, Digitalisation, Entrepreneurship and Tourism, which accumulates functions of different natures. The coordination of the relationship with public and private actors, the technical monitoring of the solutions deployed and, in practice, the working-level relationship with the European Commission are operational functions that presuppose daily proximity to the delivery work, and should be absorbed by the taskforce. MEDAT would retain, and be strengthened in its supervisory function, exercised in coordination with the trust-services supervision that, under the current legislative framework, belongs to the Authority for the Digitalisation of Romania.

The taskforce must combine technical delivery and strategic oversight within a single structure, as this ensures that adoption considerations are embedded into technical decisions from the start. It also creates a single point of accountability, simplifying governance and reporting while eliminating the risk of parallel entities developing conflicting priorities. The strategic dimension encompasses maintaining a citizen-facing and outcome-oriented perspective, managing Romania’s relationship with the European Commission and other Member States, tracking the evolution of the Architecture Reference Framework and relevant implementing acts, developing partnerships with private actors, and planning the wallet’s role as an authentication mechanism across both the public and private sectors. The technical dimension would be in charge of the development, while constantly mapping and coordinating public acquisitions for parts of the project, as needed. In the next part, we explore the profiles of this technical and strategic taskforce.

The current situation of Romania can be summed up as follows: a governance committee is in place, key institutional roles have been allocated, Germany’s open-source solution has been announced to be adopted as the technical base, and the electronic identity card provides a foundation that not all Member States had when eIDAS 2 was first proposed. This paper has argued, drawing on the academic literature on delivery units and on the comparative experience of France, Poland, and Sweden, that building and ensuring adoption of national wallets requires development of internal capacity. For Romania, adopting Germany’s solution reduces the load for building the wallet but does not imply that there is no need to assign experts on this task, as customising a foreign codebase to national infrastructure, tracking upstream changes as the ARF evolves, and managing a cross-border technical relationship all require a team with both technical depth and institutional authority, precisely what the proposed taskforce is designed to be.

The central recommendation of this paper is therefore the establishment of a taskforce for the EUDIW at the centre of the government. The main risk this paper identifies is that assignment of roles alone, without a proper allocation of human resource dedicated to the task via a mechanism that allows for flexible recruitment and deployment of the person-hours that experts from public institutions and private companies can contribute has repeatedly failed to produce a service that is actually used. The technical team builds and operates the wallet: a bounded, technical, compliance-oriented mandate that is well defined in the ARF and well understood by most Member States. The strategic team makes the wallet matter, through adoption, trust and compliance via legal, policy and regulatory expertise and communication.

Taken together, the profiles set out above imply a unit of roughly 40 to 50 full-time equivalents at full build; a leaner configuration of around 20 people is sufficient for the 2026 phase, in which the priority is the first release of the application, PID issuance and age verification, with the testing, incident-response and mobile-engineering functions scaling as the wallet moves into production.

Edge Institute will follow this paper with a dedicated piece that translates the governance proposal set out here into a phased implementation roadmap, covering the critical window from taskforce constitution through launch, the sprint toward certification and public availability, and the 2027 horizon when mandatory private sector acceptance obligations arrive.

While a phase-by-phase implementation roadmap is deliberately left to the follow-up work, as Romania is currently in a period of government transition, the sequence of first decisions is sufficiently independent of the eventual government configuration to state here.

The immediate priorities are six:

• to select and legally constitute the taskforce vehicle and appoint a Programme Director with a clear mandate to recruit experts according to a pre-defined scheme;
• to second an initial technical core from the Ministry of Internal Affairs, the Special Telecommunications Service, the Ministry of Economy, Digitalisation, Entrepreneurship and Tourism and other relevant public institutions so that work on integrating the German solution with the national registers and the PID issuance process begins without waiting for full recruitment;
• to map the help that private companies can offer, keeping in mind that it should not undermine nor replace the development of internal capacity;
• to identify the eventual components that need to be bought from the market and prepare the public tenders accordingly;
• to confirm the funding route and secure the first tranche; and
• to stand up the ecosystem function early, so that the pipeline of relying parties and attribute providers is being built in parallel with, not after, the technical work.

About and acknowledgements

This paper was written by Melany Pașca, Director of Public Policy and Legal Affairs at Edge Institute, with the support of the think tank’s team. Special thanks are due to David Magard, Director of Government and Regulatory Affairs at the SIROS Foundation, former coordinator of the EU Digital Wallet Consortium (EWC) and of the WE BUILD large-scale pilot, whose substantial contribution shaped the architecture and part of the comparative analysis of national delivery models. Warm thanks are also due to the technical experts of the SIROS Foundation’s team, whose input strengthened the technical dimensions of the analysis.

The overview of the French, Polish and Swedish approaches was informed by discussions with key members of the teams delivering the digital identity wallets in the three countries, whose openness in sharing their experience, organisational choices and lessons learned made the comparative chapter possible.

The sections on the Romanian national context benefited from the peer review of experts in digital policy and public administration reform. Although their view is that the taskforce should be placed within the Chancellery of the Prime Minister, aspect addressed directly in the paper, their feedback was very valuable.

The views expressed in this paper are the sole responsibility of the author. Any remaining errors are the author’s own.

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