Ukraine adopts use of digital ID wallets meeting EU standards

On 11 June 2025, the Cabinet of Ministers of Ukraine adopted Resolution No. 689, which sets out comprehensive functional, methodological, technical and technological requirements for the issuance and operation of digital identification wallets.

These digital wallets are to be used under a high-trust eID scheme for both individuals and legal entities and will allow them to store documents, ID-data, electronic signatures and use them online. Under the Resolution, a wallet is not a classic digital wallet storing user’s payment cards, as with Google Pay and Apple Pay. Instead, the wallet, compliant with the EU eIDAS 2.0 standard, will store ID documents for both Ukraine and the EU.

Ukrainian citizens in Europe will be able to use such documents to receive public services, open bank accounts, register SIM cards, etc., with no need to carry physical ID cards. Basically, it will serve as an analogue of “Diia” application in terms of storage of documents but will be available both in Ukraine and the EU. At the same time, the citizens of the EU will be able to use their European digital wallets to enjoy the same benefits in Ukraine.

The framework is a significant step toward establishing a secure, privacy-conscious, and user-centric digital identity infrastructure, supporting Ukraine’s digital transformation and alignment with European standards.

Regulatory scope and terminology

The Resolution establishes standards for providers of the wallets and defines key concepts such as validation, executable code, source code, compilation, and digital wallet users/providers.

Voluntary use and accessibility

The issuance and use of the wallets is voluntary. The wallets are provided free of charge for individuals and on a contractual basis for legal entities. To ensure accessibility of the interfaces as information and communication technologies, they must comply with the relevant DSTU EN 301 549:2022 state standard.

Core user functionalities

The wallets must enable users to:

• Securely request, store, delete, combine, and share identification data under the user’s sole control.
• Use and store pseudonyms locally and securely.
• Authenticate and interact with other wallet users to exchange data securely.
• Create qualified electronic signatures or seals using compliant software/hardware.

Security, privacy and data integrity

To be valid under the Resolution, emitted wallets must be compliant with security requirements. They must:

• comply with high-trust eID standards;
• ensure that identity data clearly links to individuals or legal entities; and
• be developed using open-source software, with exceptions permitted only for national security or privacy protection.

User protection and support

Resolution also provides for protection and support of individuals and businesses using wallets.

Fundamentally, providers must offer accessible technical support and allow users to report incidents, while users must have full transparency into all wallet-related data processing. Data collected must be limited strictly to what is necessary for wallet operation and must not be merged with other services unless explicitly requested by the user. Personal data used in a wallet, as the most sensitive type of data, must be logically separated from other processed data.

The above requirements apply to all providers and users of digital ID wallets issued under Ukraine’s high-trust electronic identification scheme. The implementation of these requirements will serve the further integration of Ukraine in the European regulatory and digital space and will allow both Ukrainians and Europeans to enjoy the facilitated access to digital versions of their ID documents and electronic signatures to confirm their identity easily when needed.

For more information on the Resolution and the Ukrainian financial sector, contact your CMS client partner or these CMS experts: Ihor Olekhov, partner or Bohdan Ilchenko, senior associate.