Last year, we launched a new specialization – Digital Identity. It is an initiative by Future Finance Poland and FinTech Poland that brings together financial institutions, technology providers, regulators, and legal experts to jointly shape the future of identity in the digital era.
The specialization focuses on preparing the financial sector for implementation of the eIDAS 2.0 regulations and on exploring business potential of the European Digital Identity Wallet across key financial business processes.
The leaders of the specializations are Mastercard, Visa, Identonic, and Obserwatorium.biz. Public administration institutions are also actively involved in the work of these specializations, including the Centre for Information Technology, the Ministry of Digital Affairs and the Ministry of Economic Development and Technology (MRiT).
As part of the specialization, we have established four dedicated working groups, each focused on a different area:
Customer Onboarding working group – led by Mastercard
In 2025, the Customer Onboarding Working Group, led by Mastercard, was formally established. The group brings together representatives from key market sectors – including financial institutions, onboarding solution providers, and the Identity Wallet Provider (COI) -with one shared objective: to validate the readiness of using an eIDAS2‑compliant wallet in customer onboarding through a series of pilots.
The prioritized pilot use cases include:
- opening personal bank accounts and accounts for sole proprietors,
- SIM card registration.
The team has also initiated the development of comprehensive pilot specifications, covering workflows, functional and security requirements, technical components, legal considerations, and a detailed implementation plan.
Plans for 2026 (Q1–Q2):
- finalizing scenario scope and conducting deep-dive workshops with partners,
- continuing analytical work and preparing required documentation,
- executing the pilot implementations,
- undertaking communication and awareness‑building activities.
Strong Customer Authentication & Age Verification working group – led by Visa
In Q4 2025, the SCA & Age Verification working group, led by Visa, was established. Key participants are representatives from leading Polish banks, acquirers and PSPs, as well technology partners and Central IT Centre – mObywatel team. The group’s objective is to design and pilot two solutions in collaboration with mObywatel, the government identity wallet:
- Strong Customer Authentication – supporting Polish banks in meeting compliance with eIDAS2 regulatory requirements;
- Age verification – addressing strong market demand for a reliable solution to unlock sales of restricted products and services, which require to verify age.
By the end of 2025 the scope of work, role allocation, and forms of partner engagement were agreed upon. In addition, the methodological assumptions for further work were also developed to continue work in 2026.
Plans for Q1 2026:
- Workshops focusing on technical specification, regulatory compliance and solution design
- Finalize key partnerships and confirm the strategic direction for the next phases, with the goal of launching pilots in Q3 2026.
Electronic Attestations of Attributes (EAA) working group – led by Obserwatorium.biz
The work of the Electronic Attestations of Attributes (EAA) working group, led by Obserwatorium.biz, focuses on three main areas:
- Legal and process support for SCA and age verification,
- Analysis of public attribute notifications outside the digital wallet,
- Development of a use case library which includes feasibility analyses, readiness scorecards, and legal opinions.
Plans for 2026:
- close cooperation with other working groups within the Digital Identity specialization,
- further business, technical, and legal research and analytical work,
- support for planned pilot projects and market consultations regarding EEAs and SCA.
Business Wallet working group – led by Identonic
In 2025, the Business Wallet working group, led by Identonic, we defined three main areas of work:
- Knowledge: educational activities and market awareness building in the area of business wallets,
- Legislation: monitoring of the EU/Polish regulations, developing sector positions and identifying legislative needs,
- Execution: preparation and implementation of pilot projects.
The team also identified target groups, including banks, telecom operators, insurance companies, the commercial sector, as well as other service providers, technology vendors and consultants.
We have created a solid foundation to co-operate with Public administration and private stakeholders.
Framework timeline:
- Stage 0: inauguration of the team’s work (February/March 2026),
- Stage I: legislative monitoring (Q4 2025 – Q2 2026),
- Stage II: analyses, standards and educational activities (Q2 – Q4 2026),
- Stage III-IV: pilot projects starting in H1 2026.
