Digital identity is rapidly becoming a cornerstone of modern public services. Across Europe, governments are exploring the implementation of the European Digital Identity wallet (EUDI-wallet) to simplify how citizens interact with public institutions. In theory, the concept is powerful: citizens can securely store verified personal data in a digital wallet and share only the information necessary to access services. This could mean faster processes, fewer administrative burdens, and greater control over personal data. It seems like a great opportunity to realise the MyData vision.
Although the technology can improve service delivery, its impact depends heavily on how it is implemented. To not only make it happen, but also make it right, ethical evaluation must be embedded early in the design and implementation process. Public institutions should balance values such as privacy, autonomy, inclusivity, efficiency, and accountability.
Especially within social services that directly affect vulnerable citizens, the implementation of digital identity wallets raises critical ethical dilemmas. Understanding these tensions is essential for responsible innovation. The Ethics Blueprint for Responsible Implementation of EUDI-wallets proposes a structured approach for service providers to address these dilemmas. The blueprint was developed by InnoValor together with multiple Dutch municipalities and public service providers as part of a Small Scale Pilot Digital Identity. Key insights are shared in this blog.
Key Ethical Dilemmas of EUDI-Wallet Implementation
1. The Privacy Paradox: More Control, More Risk
One of the central promises of the EUDI-wallet is enhanced privacy through data minimization. Citizens can, for example, prove they are over 18 without revealing their exact day of birth.
However, this increased control over your own data creates a paradox. If sharing data becomes too easy with the use of a convenient wallet, citizens may unknowingly share more information than necessary. Likewise, organizations might request additional data simply because the technology allows it.
This phenomenon known as “over-sharing” and “over-requesting” highlights a key ethical challenge. Technology designed to protect privacy could unintentionally weaken it if users lack awareness or if systems are not designed with safeguards.
2. The Risk of a Deepening Digital Divide
Digital identity wallets rely on secure technology and verification procedures. While these features increase reliability, they can also make systems more complex and harder to use.
For citizens with strong digital skills, the wallet may offer a smoother and more private experience. But vulnerable groups, such as people with lower digital literacy, language barriers, or disabilities, may struggle to use the technology.
This creates a real risk: digital innovation that improves services for some while excluding others. Public service providers must therefore ensure alternative access routes and additional support for citizens who cannot easily use digital tools.
3. Real Autonomy or an Illusion of Choice?
A core principle of the EUDI-wallet ecosystem is that citizens control their own data. They decide what information to share and with whom. But how meaningful is this autonomy in practice?
If the design of the interface nudges users toward certain choices, through confusing layouts or manipulative “dark patterns”, citizens may feel in control without truly understanding the consequences of their decisions. Furthermore, if access to essential public services depends on sharing data, the option to refuse may not be realistic.
In such cases, autonomy becomes an illusion rather than genuine control.
4. Questioning the Need for Data
Finally, the blueprint highlights an often overlooked issue: the EUDI-wallet improves how data is shared, but it does not question why the data is collected in the first place.
Before optimizing digital data exchange, organizations should ask a more fundamental question: Is this information actually necessary?
True data minimization requires careful reflection on necessity and proportionality, not just more efficient data sharing mechanisms.
Additional dilemmas can be found in the full report.
Moving Toward Responsible Implementation
The use of EUDI wallets offers a great opportunity to give citizens more control over their data and realise the MyData Vision. However these opportunities will only be realized if we do it right. Organizations are encouraged to:
- Map how EUDI-wallets change service processes
- Assess ethical impacts on stakeholders
- Implement technical and organizational safeguards
- Maintain human oversight in automated systems
- Build a culture of ethical reflection within the organization
Responsible implementation is not a one-time evaluation but an ongoing process. Ethical considerations must be embedded in governance, design, and everyday decision-making.
The Future of Digital Identity Must Be Ethical
Digital identity wallets have the potential to transform public services by making them more efficient, secure, and user-friendly. Yet their success will ultimately depend on public trust and ethical governance. In the end, responsible implementation is not just about building better technology. It is about ensuring that technology truly serves citizens and society.
Want to know more or interested in reading the complete ethics blueprint? Reach out to us via Ethics Blueprint | InnoValor or bart.denhaan@innovalor.nl.
This blog is authored by Bart den Haan, Digital Innovation & Ethics advisor at InnoValor Advies. InnoValor Advies is a MyData Global founding member, and an active member within the MyData community. Bart investigates the ethics of innovative digital technologies, such as digital identity wallets. He is involved with setting up the Dutch ecosystem for the European Digital Identity and contributes to the development of the Federative Dataspace for the Dutch government.