For European financial service providers, this is an exciting time. The rollout of AMLR, eIDAS 2.0, and the EUDI Wallet is fundamentally changing how regulated institutions engage with their customers and governments, from identity verification to compliance. This presents plenty of opportunities for organisations that get it right to scale across 27 markets.  

But working on the eID and EUDI Wallet products at Fourthline, I spend a lot of time looking at what the new framework makes possible vs. what users in a given market are actually ready to do.  

This gap is perhaps most pronounced in relation to eID adoption, which varies dramatically across Europe. The key variable is rarely the product; it’s the market. And it's often related to how long digital identity verification (or digital adoption in general) has been part of everyday life. 

With 27 markets, the difference in adoption likely won’t change just because AMLR goes into effect. However, understanding the discrepancy will change how you build your products. 

The conversion problem you're calling a product problem is probably a market problem 

As we’ve all heard by now, from July 10, 2027, AMLR requires eID, QES, or the EUDI Wallet integration for remote onboarding across the EU. The important thing to remember here is that this is a regulatory requirement, not an adoption mandate. And from the statistics we’ve seen, usage will vary widely.  

According to Eurostat, in 2025, eID adoption across the EU averaged 52% of adults. But behind that average the figures skew in wildly different directions: Denmark lands at 99%, Finland at 96%, the Netherlands at 95%, and Sweden at 92%. Meanwhile, Germany, Slovakia, Bulgaria, and Romania all sit under 15%.  

It’s important to note that Germany, for example, has had this technology available for 16 years. What it didn’t have is a digitally native public ready to adopt a solution like this. Sweden, on the other hand, had built an electronically minded banking system over 50 years, first with direct bank transfers in the 1950s, then bank-based identity cards in the 1970s, then transitioning to BankID starting back in 2003. Here, the public’s trust in the process was built over decades, making eID adoption simple and straightforward.  

Part of operating in Europe is understanding the ways in which each market is distinct, and what their customers want. Then, you need to balance that with your regulatory obligations to come up with solutions that fit your company best. As product teams, of course we need to be asking how we should integrate eID. That’s a given. But we also need to be asking: "What does eID maturity in this market tell me about what my users are expecting?" 

The market reality: multiple schemes, unequal access 

Europe doesn't have a single language, a single culture, or a single set of customs. So, it follows that it also doesn’t have a single eID landscape. Instead, it has dozens of them.  

This is by design, and something that’s accounted for in AMLR. In fact, most EU member states have more than one eID scheme, and the level of access available to private sector organisations varies significantly between them. 

Many modern schemes share OpenID Connect (OIDC) as their underlying protocol. The issue here is that certain countries have specific registration requirements and access rules, meaning they’re not always easy to work with. Certain schemes that don't use OIDC each require their own integration approach, adding further complexity. 

However, access inequality runs deeper than protocol differences. Across Europe, countries fall into roughly four categories: 

• Countries with direct integration available: Here, the eID scheme is accessible, documented, and open to private entities 

• Countries where a broker is helpful: Here, integration is made significantly easier through a certified intermediary, adding longer wait times and costs 

• Countries where certain schemes block foreign entities: Here, the eID scheme is available domestically but might be inaccessible to non-local legal entities. 

• Countries with no private sector path: In this scenario, the scheme exists for government use only; document verification remains the only practical option. 

Why the high eID adoption rates weren't built by governments 

The pattern across Europe's highest-adoption markets is consistent and worth naming directly: the schemes that work weren't built as compliance infrastructure. Instead, they were built by private companies as everyday banking and telecoms tools, which helped them to become identity infrastructure through habit. 

Sweden's BankID launched as a bank login in 2003. Norway's BankID followed a similar path. Finland's Mobiilivarmenne was telecoms-driven. Belgium's itsme® was built by a bank and telecoms consortium, and Smart-ID across the Baltics saw their governments collaborating with private entities. In every case, the habit of using a digital credential for daily banking and government services preceded any formal eID recognition by years, or even decades. 

Germany is the counter-case. The chip-based eID card was technically sophisticated from launch in 2010. What it lacked was a compelling everyday use case that would drive habitual adoption. What’s more, it wasn’t easy to use: customers had to go out of their way to activate and most didn’t bother. This remained the status quo for years, and even after this was fixed, adoption continues to remain low. 

Estonia is perhaps the exception that proves the rule: government-built and highly successful, because utility was embedded from day one across tax, healthcare, voting, and banking simultaneously. Here, the government built the habit directly. 

What this means if you're building regulated onboarding across Europe now 

For product teams, what I’m saying has immediate consequences for your strategy. In markets where eID wasn't embedded through banking habits, you're effectively asking users to engage in an unfamiliar behaviour in a high-stakes moment. That is a different type of design problem that also requires a different solution. 

Here are a few principles that I think should be shaping your architecture decisions: 

• Treat every country as a product variable, not a demographic filter. eID method, user familiarity, broker requirements, and fallback tolerance all differ by market. A single onboarding flow deployed uniformly across Europe is really not a European onboarding strategy. 

• Sequence your market rollout by eID maturity. The Baltics, Nordics, and Belgium are markets where eID-first flows will likely convert from day one. Western and Southern Europe require more nuanced approaches, like document verification as the first-line approach, with eID as a backup. 

• The access inequality problem is not theoretical. Broker markets and restricted-access schemes mean longer integration timelines and different architecture decisions. Some schemes require approval from governments, local legal entities, or even direct contracts with national providers. In my own conversations with clients, I’ve learned that integration can take up to a year.  

• "Support eID" and "eID as primary flow" are different things in different markets. Build the acceptance infrastructure now, but design your fallback logic with the same care as your primary path. 

• Segment your verification performance by country. If you're looking at aggregate funnel metrics, you're averaging out the most useful signal available to you. A 60% eID completion rate across five markets might be 95% in one country and 25% in another. So, look closely: those two numbers require completely different responses. 

Putting the market at the forefront 

The adoption gap in eID is a critical consideration for your business that simply won’t be solved by the AMLR deadline. This is the product of decades of different (sometimes conflicting) decisions about what digital services to build, what habits to embed, and what infrastructure to invest in. Regulation can mandate acceptance, but it can’t mandate familiarity and a desire to move with the times.  

At Fourthline, we have a clear view on this: eID integration is a market-by-market decision that the design should reflect. We're expanding eID coverage across Europe's priority markets with a deliberate sequencing logic: the Baltics and Nordics first (where eID-first flows perform from day one), followed by markets where broker access and user familiarity require a more structured transition. 

If you're designing your eID integration and thinking about which markets to prioritise, what the access architecture requires, or how to structure the transition from documents to eID, we've done that analysis for you. Coming from a product perspective, I can tell you that the country should come first, and the architecture should follow from there.  

Get in touch with a specialist at Fourthline to learn more.