What is identity verification orchestration?

Identity verification orchestration connects multiple verification methods and providers behind a single API, automatically routing each user to the best method for their country and use case, with instant fallback when a method fails. Instead of integrating vendors one by one, businesses integrate once and gain access to the full landscape of eIDs, wallets, biometrics and document checks.

How many verification methods does Authologic support?

Authologic supports over 90 verification methods from more than 80 providers, covering over 230 countries and territories - including national eIDs, government identity wallets, BankIDs, biometrics and document-based verification.

Is Authologic ready for eIDAS 2.0 and the EUDI Wallet?

Yes. Authologic supports EUDI Wallet integration alongside national eIDs and government wallets such as mObywatel, Diia, SPID and FranceConnect+, helping regulated businesses prepare for mandatory EUDI Wallet acceptance under eIDAS 2.0.

How does Authologic improve onboarding conversion?

By routing users to electronic identity methods instead of document scans wherever available. eID-based verification removes photo capture and manual review, which shortens onboarding and increases pass rates, with automatic fallback to other methods when needed.

How is Authologic different from traditional KYC providers?

Traditional KYC vendors offer their own verification methods; Authologic is a neutral orchestration layer that connects them all. One integration provides access to over 90 methods from more than 80 providers, with routing, fallback and coverage that no single vendor offers.

Olga Mędraś, Florentyna Frend

October 20, 2026

What is a relying party intermediary under eIDAS 2.0?

Who registers, who holds the certificates and what an intermediary can take over.

A relying party intermediary is an entity that is itself a registered relying party and gives other organisations access to its connection to the European Digital Identity Wallet. The intermediary takes over the integration and the communication with the wallet, and it can assist with the application for registration. The obligation to register, however, remains with the relying party. Authologic will act as an intermediary once it is entered in the register, after the national registers officially open.

Written by Dr Olga Mędraś (Head of Legal) and Florentyna Frend (Head of Product), Authologic.

The rules on intermediation are set at EU level, while the registers and procedures are national. The terms used in this article are defined in the Digital Identity Glossary.

Title card reading "Relying party intermediary" with the line "EUDI Wallet access under eIDAS 2.0" above a map of Europe ringed by the EU stars

Key takeaways

In every Member State:

Both parties register: the intermediary and the organisation on whose behalf it acts. The obligation to register remains with the intermediary’s client.
An intermediary must not store data about the content of the transaction (Article 5b(10) eIDAS). The data is stored by the relying party.
Registration in the Member State of establishment is enough to use the national EUDI Wallets of all Member States.

In the Polish model:

The intermediary’s client will not need its own access certificate, but it must obtain its own registration certificate. Where the data submitted is correct, registration is expected to be automatic, so the time to go live depends on the certificates.

What is a relying party intermediary?

A relying party is an organisation that wants to request data from an EUDI Wallet: a bank opening an account, a crypto-asset exchange verifying a customer, a gaming operator checking a user’s age. To request data from a wallet, the relying party must be entered in the register of relying parties in its Member State of establishment and hold the appropriate certificates.

The eIDAS Regulation provides for the role of an intermediary explicitly: intermediaries acting on behalf of relying parties are deemed to be relying parties and must not store data about the content of the transaction.

Legal basis: Regulation (EU) No 910/2014 (eIDAS), as amended by Regulation (EU) 2024/1183, Article 5b(10).

Who registers when a relying party uses an intermediary?

Both parties register. The obligation to register lies with the relying party, in its Member State of establishment, and the intermediary, which is deemed to be a relying party, also registers in its own right. The register has a field to indicate that the relying party uses an intermediary and a field to link it to a specific intermediary.

An intermediary can assist with preparing the application for registration, including the description of the intended uses of data. The obligation to register, and the decision on which data to request and for what purpose, remain with the relying party.

Legal basis: eIDAS, Article 5b(1) and (10); Commission Implementing Regulation (EU) 2025/848 of 6 May 2025 on the registration of wallet-relying parties.

What does an intermediary take over, and what stays with the relying party?

Task	Who does it
Connection to the wallets	intermediary
Compliance with the standards and keeping up with their revisions	intermediary and relying party
A single integration instead of many	intermediary
Preparing the application for registration	relying party; the intermediary can assist
Obligation to register	relying party
Intended uses of data	relying party; the intermediary can help describe them
Deciding which data to request and for what purpose	relying party
Recording and retaining evidence of the verification	relying party

An intermediary does not store data retrieved from the wallet. The EUDI Architecture and Reference Framework (ARF) requires the intermediary to delete identity data and attestations immediately after passing them to the relying party or, if they are not passed on, immediately after the verification ends. The data is stored by the relying party, in line with its own needs and with the GDPR.

Diagram: data flows from the user to the intermediary, which passes it on and deletes it, and then to the relying party, which keeps the proof. The intermediary and the relying party have 2 linked entries in the relying party register; the user does not register.

An intermediary does not relieve its client of the obligation to register.

How does registration work in Poland?

The description below is based on information from the Polish Ministry of Digital Affairs on the planned Polish register of relying parties and on the draft act. The act has not yet been adopted, so the details may change. Other Member States design their registers independently, so the Polish model is not a universal one.

Which certificates are needed?

A relying party needs 2 types of certificates. The access certificate authenticates the relying party when it communicates with the wallet and is linked to its entry in the register. At least 1 access certificate is mandatory; further ones can be added, for example one per instance, so that the failure of one instance does not stop the traffic.

The registration certificate is linked to an intended use of data. An intended use describes a single overarching purpose, which leaves considerable flexibility: a change of channel, for example from an online process to an in-person one, does not require a new registration certificate.

When an intermediary is used, the access certificate belongs to the intermediary, and communication with the wallet runs through it. The intermediary’s client will not need its own access certificate, but it must obtain its own registration certificate.

How long does registration take?

Where the data submitted is correct, entry in the register is expected to be automatic. An entry in the register does not, however, mean that the certificates have been issued. The relying party applies separately for the certificates to a qualified trust service provider of its choice, and it is this step that determines the time to go live.

How do you submit the application?

Under the draft act, an application for entry in the register, or for a change to an entry, is submitted electronically to the minister competent for computerisation (currently the Minister of Digital Affairs), in either of 2 ways.

The first is the minister’s electronic form, after authentication. A natural person authenticates with an electronic identification means at assurance level high or with data verified by a qualified electronic signature. A legal person authenticates with an electronic identification means for legal persons at assurance level high or with an advanced electronic seal verified using a qualified certificate.

The second is to submit the application through a qualified trust service provider that issues wallet-relying party access certificates or wallet-relying party registration certificates.

What can you do before the registers open?

Commission Implementing Regulation (EU) 2025/848 on the registration of wallet-relying parties applies from 24 December 2026. By that date, Member States are to launch their national registers.

In Poland, the Ministry of Digital Affairs has already made a test environment with a wallet app available, and test certificates are to be issued free of charge. The integration can therefore be prepared before the register opens.

Timeline from today to 24 December 2026 (preparation: register, intended uses, authentication method, sandbox testing, intermediary or direct) and on to 24 December 2027 (12 months: file the entry, obtain certificates, name the intermediary, production integration).

Before the registers open, it is worth deciding which register applies based on your Member State of establishment, the intended uses of data with the data scope for each of them, how the application will be authenticated, and whether to use an intermediary.

From 24 December 2027, private relying parties that are required by law or contract to use strong user authentication for online identification, except micro and small enterprises, must accept the wallet when a user chooses to use it (Article 5f(2) eIDAS). You can check your own readiness with the EUDI Wallet Readiness Checklist.

Legal basis and sources: Commission Implementing Regulation (EU) 2025/848, applicable from 24 December 2026; eIDAS, Articles 5b and 5f(2); Polish draft act amending the Act on trust services and electronic identification and certain other acts, of 18 February 2026 (UC122).

Where does Authologic fit in?

As an intermediary, Authologic will guide its clients through the registration process and connect them to the wallets, in the same integration as other electronic identification means, public and private, including bank-based ones, as well as biometrics and document verification. Authologic is a non-qualified trust service provider issuing electronic attestations of attributes, registered by Narodowy Bank Polski (the National Bank of Poland).

What the EUDI Wallet changes in KYC processes is explained in the briefing How Will the EUDI Wallet Change KYC? What AMLA’s draft technical standards expect for remote customer verification is explained in How to verify customers remotely under AMLR.

FAQ

Do I have to register if I use an intermediary?

Yes. The obligation to register remains with the relying party. The intermediary can assist with preparing the application.

Do I have to register in every Member State where my users are?

No. An organisation entered in the register of its Member State of establishment, with valid certificates linked to its entry, can use the national EUDI Wallets of all Member States. Mutual recognition does not cover additional wallets, for example commercial ones. An intermediary is not needed for this: an organisation registered directly, with its own integration, can serve users from other Member States in the same way.

Does an intermediary store my users’ data?

No. An intermediary must not store data about the content of the transaction (Article 5b(10) eIDAS). Under the EUDI Architecture and Reference Framework, it deletes the data retrieved from the wallet immediately after passing it to the relying party or, if the data is not passed on, immediately after the verification ends. The data is stored by the relying party.

Do I need my own access certificate if I use an intermediary?

Not in the Polish model. Communication with the wallet runs through the intermediary’s access certificate. The relying party must, however, obtain its own registration certificate.

When do the relying party registers start operating?

Commission Implementing Regulation (EU) 2025/848 on the registration of wallet-relying parties applies from 24 December 2026. By that date, every Member State is to launch its national register. In Poland, under the draft act, applications for registration are submitted electronically to the minister competent for computerisation.

Which companies will act as relying party intermediaries?

No intermediary can be registered yet, because the national registers are due to open by 24 December 2026. Some identity platforms have already announced that they will take on the role. Authologic will act as an intermediary from its entry in the register, connecting its clients to the wallets in the same integration as national eIDs, bank IDs, biometrics and document verification.

When do companies have to accept the European Digital Identity Wallet?

From 24 December 2027, private relying parties that are required by law or contract to use strong user authentication for online identification, except micro and small enterprises, must accept the wallet when a user chooses to use it (Article 5f(2) eIDAS). From the date the national registers are due to open (24 December 2026), that leaves 12 months for registration, certificates and the production integration.