In short
For online public services, most obligations are addressed to the Member States. Where a Member State requires electronic identification to access an online service provided by a public sector body, it also accepts the wallet Art. 5f(1) and, under conditions, the electronic identification means notified by the other Member States Art. 6(1). Where it requires an advanced signature or seal, it recognises them at least in the formats set by implementing act Art. 27 Art. 37; Implementing Regulation 2026/248 specifies them; the provisions that set these formats
Art. 1(1) Art. 3(1)apply from 23 February 2027 Art. 6. A public body that relies on the wallet is also a relying party, which registers Art. 5b(1).
This guide is part of step 7. Acceptance of the wallet is presented in step 3, signatures and seals in step 4. The Regulation often designates the Member State rather than the body: we use its terms. How your State allocates these tasks among its administrations is a matter for national law.
Your obligations
Identification of users
| Obligation | Addressee in the text | Legal basis | Deadline |
|---|---|---|---|
| Where electronic identification and authentication are required to access an online service provided by a public sector body, also accept wallets provided in accordance with the Regulation | the Member States | Art. 5f(1) | no deadline in the text Art. 5f(1) |
| Recognise, for that service, the electronic identification means issued in another Member State, if its scheme is included in the Commission’s list, if its assurance level is equal to or higher than the level required and corresponds to the substantial or high level, and if the body uses the substantial or high level | the first Member State | Art. 6(1) | no later than 12 months after the Commission publishes the list in which the scheme concerned is included Art. 6(1) |
| Notified means at assurance level low: it may be recognised | public sector bodies | Art. 6(2) | — |
| Not substitute the identification data in an attestation for the electronic identification required by national law, unless expressly allowed by the Member State; in that case, also accept qualified attestations issued in other Member States | general rule; the permission is for the Member State | Art. 45c | — |
| If the body relies on the wallet: register as a relying party, then comply with the obligations in the relying party guide | the relying party | Art. 5b(1) | Implementing Regulation 2025/848 applicable from 24 December 2026 Art. 11 |
| For a cross-border online service, where a public sector body acts as a relying party: ensure unequivocal identity matching of natural persons, on the basis of the mandatory PID data (wallet) or of the minimum data set (notified scheme) | the Member States | Art. 11a(1) Art. 2 | Implementing Regulation 2025/846 applicable from 24 December 2026 Art. 6 |
Registration includes an indication of whether the relying party is a public sector body Annex I.
Signatures and seals
| Obligation | Addressee in the text | Legal basis | Deadline |
|---|---|---|---|
| If an advanced electronic signature is required to use an online service offered by a public sector body, recognise advanced signatures, advanced signatures based on a qualified certificate and qualified signatures, at least in the formats or using the methods defined in the implementing acts | the Member States | Art. 27(1) | — |
| If an advanced signature based on a qualified certificate is required, recognise those and qualified signatures, under the same conditions | the Member States | Art. 27(2) | — |
| Not require, for cross-border use, a signature at a higher security level than the qualified signature | the Member States | Art. 27(3) | — |
| Same rules for advanced and qualified electronic seals | the Member States | Art. 37 | — |
| Recognise advanced signatures and seals whose format or container complies with the specifications of Annex I to Implementing Regulation 2026/248 | the Member States that require an advanced signature or seal, or one based on a qualified certificate | Art. 1 Art. 3 | from 23 February 2027 Art. 6 |
| Also recognise those that comply with the specifications of Annex II, where they were created before 23 February 2028 | the Member States | Art. 1 Art. 3 | — |
| Recognise other formats where the Member State of the trust service provider offers validation methods that meet the conditions of the act | the Member States that require an advanced signature or seal, or one based on a qualified certificate | Art. 2 Art. 4 | — |
A dash indicates that the cited provision sets no deadline of its own.
Attestations and authentic sources
A qualified attestation and an attestation issued by a public sector body responsible for an authentic source have the same legal effect as a lawfully issued attestation in paper form; the latter is recognised as such in all Member States Art. 45b(2) Art. 45b(3).
If your body is responsible for an authentic source (a repository that is the primary source of a piece of information, or recognised as authentic under law Art. 3(47)), two topics concern you:
- verification of attributes: at least for the attributes listed in Annex VI, where they rely on authentic sources within the public sector, Member States ensure that qualified trust service providers issuing attestations can verify them by electronic means, at the request of the user, within 24 months of the entry into force of the implementing acts on the wallet and its certification Art. 45e(1). Member States set up the verification mechanisms; the result indicates only whether or not the attribute has been verified and specifies the public body responsible for the source Art. 9(1) Art. 9(4). This article applies from 19 August 2026 Art. 11. From 1 January 2027, Implementing Regulation 2026/1735 amends it: the mechanism complies with a new Annex IV, and the result is signed or sealed by the public body or the designated intermediary Art. 1(3) Art. 2;
- issuance of public attestations (PuB-EAA): see the attestation issuer guide Art. 45f.
The texts to read, in order
- Consolidated Regulation 910/2014: acceptance of the wallet, mutual recognition, signatures and seals in public services, attestations in public services Art. 5f Art. 6 Art. 27 Art. 37 Art. 45c. Library page for the Regulation.
- Implementing Regulation 2026/248 on the recognised formats of advanced signatures and seals Art. 1. Library page.
- Implementing Regulation 2025/848, if you rely on the wallet Art. 1. Library page.
- Implementing Regulation 2025/846, on cross-border identity matching by public sector bodies Art. 1. Library page.
- Implementing Regulation 2025/1569, if you hold an authentic source or issue public attestations Art. 1. Library page.
Checklist
- We have listed our online services that require electronic identification Art. 5f(1).
- For each of them, we know how the wallet will be accepted Art. 5f(1).
- We know the assurance level required by each service, a condition for the recognition of notified means Art. 6(1).
- If we rely on the wallet, we are registered as a relying party Art. 5b(1).
- Our forms do not require, for cross-border use, more than a qualified signature or seal Art. 27(3) Art. 37(3).
- If a service requires an advanced signature or seal, our validation tools accept the formats of Annex I to Implementing Regulation 2026/248 Art. 1 Art. 6.
- If we hold an authentic source, we know whether our attributes are listed in Annex VI to the Regulation Annex VI.
Advice
Asphalia advice
Where to start. Take stock of your online services: for each one, the identification means requested, its assurance level, the signatures or seals required, the attestations received. This inventory shows where the wallet must be accepted Art. 5f(1) and where your signature requirements go beyond what is necessary. If your State has an authentication service shared by its administrations, coordinate with it before developing anything of your own.
Asphalia advice
The pitfalls.
- Waiting for a date. The Regulation sets no deadline of its own for the acceptance of the wallet by public services Art. 5f(1). Follow your Member State’s timetable rather than waiting for a European deadline.
- Requiring “qualified” by reflex. If an advanced signature is enough for your procedure, the Regulation requires the Member State to recognise advanced signatures, advanced signatures based on a qualified certificate and qualified signatures Art. 27(1). Requiring more reduces the number of users able to sign.
- Forgetting the relying party role. A public body that relies on the wallet registers like any other relying party Art. 5b(1), with the same limits on the data requested Art. 5b(3).
- Ignoring your authentic source. If you hold a repository whose attributes are listed in Annex VI, you may be called upon for the verification of attributes Art. 45e(1). Plan ahead with your Member State.
In Belgium
Situation checked in the corpus on 30-10-2026.
In Belgium, FPS Policy and Support (FPS BOSA) is responsible for offering electronic identification services for public applications within the authentication service Art. 9(1), and develops the federal digital identity wallet Art. 2(1)(3). These services are presented in step 6.
Consolidation without official value
This page cites the consolidated versions, published on EUR-Lex, of Regulation 910/2014 and Implementing Regulations 2025/848 and 2025/1569 Regulation (EU) No 910/2014 — consolidated version of 18/10/2024 Implementing Regulation (EU) 2025/848 — consolidated version of 11/08/2026 Implementing Regulation (EU) 2025/1569 — consolidated version of 11/08/2026, as well as Belgian Acts in their Justel version Act of 18-07-2017 (numac 2017020539) Act of 16-07-2026 (numac 2026005829). These consolidations are documentation tools: only the Official Journal of the European Union and the Belgian Official Gazette (Moniteur belge) are authentic.
Key points
- Where a Member State requires electronic identification for an online public service, it also accepts the wallet Art. 5f(1).
- Notified identification means at assurance level substantial or high are recognised under conditions Art. 6(1).
- Advanced signatures and seals are recognised at least in the formats of 2026/248, from 23 February 2027 Art. 1 Art. 6.
- A body that relies on the wallet registers as a relying party Art. 5b(1).
- An authentic source may be called upon for the verification of attributes Art. 45e(1).
Written by Asphalia.