E-residency is moving towards a cardless solution

On 28 October, the Riigikogu adopted amendments to the Identity Documents Act and other legislation, considered as Bill 905 SE. The law has been sent to the President; adoption must be distinguished from entry into force. 905 SE legislative procedure.

According to the Riigikogu’s overview, e-residents’ identities will be established and verified remotely using biometrics from March 2027. Applicants’ biometric data and travel document information will be compared with data held in state databases.

A transition to a cardless electronic identification means is envisaged from March 2028. Notaries will also be given access to the automated biometric identification system for remote notarial authentication. Riigikogu overview.

These changes concern the organisation of e-residency and notarial acts. The suitability of a financial institution’s onboarding solution must be assessed separately: the state’s identification process does not in itself describe every step a business must take in its customer journey.

Estonia’s wallet rules remain a bill

On the same day, the Riigikogu completed the first reading of Bill 1045 SE. The bill would establish the domestic roles and rules needed to introduce the European Digital Identity Wallet, including an authorisation procedure for wallet providers.

The main supervisory authority would be the Information System Authority, with the Data Protection Inspectorate responsible for data protection matters. The deadline for proposed amendments is 11 November 2026 at 17:15. This remains a bill. 1045 SE legislative procedure.

Financial institutions may need to do more than monitor developments

The procedural status of Estonia’s bill does not mean that wallet-related obligations arise only once it is adopted. The existing EU eIDAS framework requires certain private-sector service providers to accept a compliant wallet at the user’s voluntary request where strong authentication is required for online identification. This requirement also covers banking and financial services, but includes an exemption for microenterprises and small enterprises and a separate implementation deadline. Article 5f(2) of the eIDAS Regulation.

We recommend that financial businesses check the following when planning developments:

  • which processes currently use an e-resident’s digital ID;
  • whether the wallet acceptance requirement would apply to their services;
  • what changes would be needed to the identification solution, service provider agreements and retention of an audit trail.

The new e-residency solution and the European Digital Identity Wallet may simplify customer journeys. Decisions on their adoption must nevertheless be based on the specific service, applicable requirements and the technical solution’s actual capabilities.