MOZOM-analyse
EU digital ID: voluntary wallet or shortcut to practical coercion

- Source
- EUR-Lex, Europese Commissie, EDRi, epicenter.works, Mozilla, EFF en EHDS-bronnen
- MOZOM headline
- EU digital ID: voluntary wallet or shortcut to practical coercion
- Original headline
- European digital identity promises voluntariness and privacy, but critics fear actual dependency
- Author
- Ron Caroselli
- Date
- 12 juli 2026 om 03:36
- Subject
- MOZOM investigates whether the European digital ID wallet is only a voluntary key to convenience, or an infrastructure that may later become necessary via banks, platforms, healthcare systems and government counters.
Summary of the original report
The European digital identity, often called EUDI Wallet, is part of Regulation (EU) 2024/1183. The European Commission writes that the regulation came into force on May 20, 2024 and that member states must make at least one European digital identity wallet available to citizens, residents and companies by 2026. The official promise is clear: citizens keep control over data, share only what is necessary, and use of the wallet must be voluntary and free for natural persons. At the same time, the framework obliges member states to roll out and obliges certain public and private parties to accept the wallet. That's where the tension begins: legally, use is voluntary, but in practice the system can become more important once banks, telecom, major platforms, healthcare access, education, travel and government counters treat the wallet as the easiest route.
Own source research
MOZOM distinguishes between three questions. One: is the EU legally allowed to do this? The answer is nuanced but not simple, no. The EU is not a state, but an EU regulation is binding and directly applicable in Member States under Article 288 TFEU when it is adopted within EU competences. Member states cannot simply refuse because the EU is not a country. Two: is the wallet mandatory for citizens according to current law. No, the law presents use as voluntary and free for natural persons. Three: can actually erode voluntariness later. Yes, that is the core risk. A system can be formally voluntary, while in practice non-participation becomes more expensive, slower or more difficult.
Striking in this message
It is striking how often new digital infrastructure starts with words such as voluntary, free, safe and convenient. Those words may be true on day one, but they don't answer the most important question of power. Who will decide later which services will continue to be easily accessible without a wallet? If the fast queue is digital and the paper queue slowly disappears, freedom of choice changes without the need for one hard sentence of obligation.
Less visible context
What is less visible is that the digital ID is not separate from other EU digitization projects. The digital euro, age verification, platform rules, the European Health Data Space system and identity requirements at banks or online services are legally different files. They are not yet a proven one-to-one control system. But they can point in the same direction: more and more social access is becoming digital, verifiable, linkable and dependent on accepted infrastructure. Precisely for this reason, the demand for voluntariness is not only legal, but also practical.
Possible message behind the news
A possible message is that the EU gives citizens a secure digital key. The critical MOZOM lecture is that a key can also become a gate: whoever manages the gate will later determine how easily citizens can enter without that key.
Neutral conclusion
The preliminary conclusion: according to current law, the European digital ID is not a direct civic obligation and not every disaster scenario has been firmly proven today. But the concerns about broadening functions, practical coercion, biometrics, traceability and linking with other digital files are real enough to take seriously. The problem is not just what Brussels promises today, but what the infrastructure makes possible tomorrow.
Source:
- EUR-Lex: Regulation (EU) 2024/1183 establishing the European Digital Identity Framework
- European Commission: Digital Identity Regulation enters into force
- European Commission: Security and Privacy in the EU Digital Identity Wallet
- EDRi: The eID Wallet still does not deserve your full trust
- Cryptographers' feedback on the EUDI Architecture and Reference Framework
- Mozilla: Behind the scenes of eIDAS Article 45
- European Commission: European Health Data Space
- EUR-Lex: Regulation (EU) 2025/327 on the European Health Data Space
- EUR-Lex glossary: EU regulations are binding and directly applicable