Is the EUDI wallet a digital silver bullet?

This article is authored by Viktoras Kamarevcevas who is an expert in eID and trust services and a digital transformation leader. The article was originally posted here.

When European policymakers unveiled the European Digital Identity Wallet (EUDI Wallet) framework under eIDAS 2.0, they promised a revolutionary transformation: a single, secure digital identity for seamless cross-border use.

This ambitious initiative might seem like the definitive solution to Europe’s fragmented digital identity landscape a "silver bullet." However, a deeper look through the lens of wicked problems reveals a more nuanced reality. This perspective compels us to see the EUDI Wallet not as a final fix, but as an essential starting point, demanding cautious optimism rather than blind faith or cynical dismissal.

Understanding wicked problems: beyond simple solutions

The concept of wicked problems was first introduced in 1973 by design theorists Horst Rittel and Melvin Webber to describe a category of challenges that defy conventional problem-solving approaches. Unlike tame problems in mathematics or engineering that have clear parameters and definitive solutions, wicked problems are characterized by fundamental complexity that resists resolution.

Wicked problems possess ten defining characteristics that make them particularly intractable. They lack definitive formulation because understanding the problem depends on understanding potential solutions. They have no stopping rule since there is no clear signal indicating when the problem is solved. Solutions are not true or false but only better or worse, and stakeholders will disagree on what constitutes improvement. Every attempted solution is consequential and irreversible “every trial counts”. They exist within complex adaptive systems where addressing one aspect often reveals or creates other problems. Stakeholders hold conflicting values and interests, making consensus elusive. Finally, wicked problems are essentially unique, each requiring context-specific responses.

Digital identity as a wicked problem

The EUDI Wallet initiative does not match every characteristic of wickedness, but I think that it well represents a situation when we are hoping for one single silver bullet for multiple things. The challenge is not merely technical, creating secure cryptographic systems or standardized protocols. It is deeply entangled with social, legal, governance, and trust dimensions that span diverse jurisdictions, institutional structures, and cultural contexts across Europe.

Each of the 27 EU member states has developed its own approach to digital identity, resulting in a fragmented landscape with divergent technical standards, legal frameworks, and levels of digital maturity. Some countries have well-established government-backed systems with high adoption, while other states are still developing foundational infrastructure. Achieving true interoperability requires reconciling different protocols, encryption methods, authentication flows, and data formats. The European Commission’s Architecture and Reference Framework provides technical specifications, but translating these into functional reality across diverse national contexts remains an ongoing challenge.

The stakeholder landscape adds another layer of complexity. The EUDI Wallet ecosystem involves citizens, national governments, EU institutions, privacy regulators, trust service providers, banks, telecommunications companies, healthcare providers, educational institutions, and countless private-sector relying parties. Each group has different, often conflicting, priorities and definitions of success. Privacy advocates emphasize data minimization and user control. Governments focus on security and fraud prevention. Businesses prioritize convenience and seamless user experience. Balancing these interests requires continuous negotiation rather than a one-time technical fix.

Governance presents yet another wicked dimension. While the EU provides the regulatory framework through eIDAS 2.0, implementation responsibility falls to member states, which must deliver national wallets, establish oversight frameworks, and ensure alignment with both EU implementing acts and national regulations. This multi-level governance structure creates coordination challenges typical of wicked problems.

The University diploma example: illuminating multi-dimensionality

The challenge of cross-border recognition of university diplomas vividly illustrates why technical infrastructure alone cannot solve wicked problems. Consider a Portuguese university issuing a digital diploma that a student wishes to use when applying for a master's program in Germany or seeking employment in Sweden. The EUDI Wallet can certainly store the diploma as a verifiable digital credential, cryptographically signed by the issuing university and presented on demand. This solves the technical problem of credential portability and verification of authenticity. But it doesn't begin to address the fundamental questions of recognition.

Is the issuing Portuguese university accredited, and if so, by which body? Does Germany recognize that accreditation authority? Does the diploma's curriculum meet the educational standards required in Germany for the equivalent qualification? Who makes that determination, and according to what criteria? If there are gaps in the curriculum or differences in learning outcomes, what additional requirements might be imposed? How long does the recognition process take, and what recourse exists if recognition is denied?

These questions reveal multiple interconnected layers of complexity that transcend technical solutions. The legal layer involves divergent national regulations on higher education, degree requirements, and professional qualifications. The institutional layer encompasses varied accreditation systems, quality assurance frameworks, and recognition procedures across member states. The political layer includes national sovereignty over education policy, resistance to harmonization, and competing priorities among member states.

The EU has made commitments toward automatic mutual recognition of qualifications by 2025 through the 2018 Council Recommendation. Yet implementation remains fragmented and inconsistent. An evaluation report published in February 2023 found that stakeholders remain unclear about what "automatic recognition" even means, that conceptual confusion persists, and that significant divergence exists in recognition practices both between and within countries.

A common diploma rulebook would be essential for truly addressing this challenge. But creating such a rulebook encounters fierce resistance rooted in national educational traditions, institutional autonomy, and legitimate differences in pedagogical approaches. It requires sustained negotiation among stakeholders with fundamentally different interests and values a process with no clear endpoint.

The diploma example demonstrates a crucial insight: the EUDI Wallet provides a technical mechanism for credential attestation, but it cannot substitute for the political, legal, and institutional work of establishing mutual trust and common standards. The wicked problem lies not in the digital format of the credential but in the social, political, and governance dimensions of recognition.

Why starting points matter: iterative and adaptive approaches

Recognizing the EUDI Wallet as addressing a wicked problem fundamentally changes how we evaluate its success. Wicked problems cannot be solved in any final sense, they can only be improved through iterative, adaptive approaches that acknowledge complexity and uncertainty.

Scholarship emphasizes that wicked problems require complex, iterative approaches rather than one-time interventions. Practitioners must choose contextualized, incremental actions to influence intractable patterns over time. The adaptive, participatory, and transdisciplinary (APT) approach emphasizes continuous learning, exploration, and experimentation rather than seeking definitive solutions.

Critically, the initiative recognizes that technical deployment is insufficient without addressing adoption challenges. Governments are encouraged to conduct public awareness campaigns, build digital literacy, ensure service readiness, and communicate benefits to citizens. These strategies reflect an understanding that wicked problems have social and cultural dimensions that technology alone cannot address.

Beyond pessimism: cautious optimism grounded in reality

Just recently, when I made EUDI Wallet presentation, I was labeled "pessimistic" as well, it might look like when reading this article. This reaction is understandable but fundamentally misguided. Recognizing a problem as wicked isn't pessimism, it's a prerequisite for effective engagement.

The truly pessimistic stance would be to believe that no progress is possible. Problems can be engaged productively through specific approaches: acknowledging complexity rather than seeking false simplicity, embracing iterative adaptation rather than pursuing definitive solutions, fostering collaboration across diverse stakeholders rather than imposing top-down mandates, prioritizing learning and continuous refinement rather than declaring victory prematurely, and recognizing provisional progress while preparing for emerging challenges.

The optimistic realism of the wicked problem framework lies in accepting the difficulty while maintaining commitment. It means understanding that engagement with the EUDI Wallet is not about reaching a final destination but about beginning a long journey of continuous improvement, adaptation, and learning.

Ongoing engagement with the EUDI Wallet initiative, despite awareness of its challenges, reflects this cautious optimism. Progress on wicked problems comes through sustained, iterative effort rather than dramatic breakthroughs. Even partial improvements in cross-border digital identity generate significant benefits for citizens, businesses, and public services. Building foundational infrastructure is essential groundwork for addressing subsequent complexity layers.

The wicked problems perspective suggests realistic metrics for success. Rather than measuring complete resolution, whether all challenges are solved, success should be evaluated through multiple dimensions: Are citizens using digital identity more easily? Are cross-border transactions more convenient and secure? Are privacy protections improving? Is the infrastructure proving interoperable and adaptable? Is trust being built among stakeholders? These incremental improvements constitute genuine progress even if they fall short of total transformation.

The path forward: embracing complexity

The EUDI Wallet represents the EU’s most ambitious attempt to create a unified digital identity infrastructure. Viewing it as the initial phase of addressing deeply intertwined challenges allows for more strategic planning, realistic expectations, and effective implementation strategies. Success will require sustained commitment to iterative refinement, continuous stakeholder engagement, adaptive governance, and patient capacity building rather than expecting immediate wholesale transformation.

Humans naturally gravitate toward simple solutions and silver bullets when confronting complex problems. The appeal of technological fixes, build the wallet and the problems will solve themselves, is powerful. But wicked problems resist such simplification. They demand approaches that embrace complexity, acknowledge uncertainty, involve diverse stakeholders, iterate based on experience, and maintain long-term commitment to incremental progress.

The EUDI Wallet is not destined to fail pessimistically, nor guaranteed to succeed optimistically. It is a crucial starting point, essential technical and governance infrastructure that makes subsequent progress possible. Whether it ultimately transforms European digital identity will depend on sustained, adaptive, collaborative work that follows this initial phase. That work must be grounded in realistic understanding of the wicked complexity involved, not wishful thinking about simple solutions.

As Europe embarks on this digital identity journey, maintaining this balanced perspective, acknowledging challenges while recognizing genuine opportunities, will be essential for navigating the complex terrain ahead. The EUDI Wallet marks not the destination but the beginning of a longer, iterative process of addressing the wicked complexity of trusted, interoperable, user-centric digital identity across diverse European contexts