A draft bill amending and supplementing the Electronic Identification Act has been submitted in the National Assembly, with the aim of bringing Bulgarian legislation into line with Regulation (EU) 2024/1183, known as eIDAS 2.0. The draft bill aims to establish the national framework for the introduction and use of European digital identity wallets in Bulgaria.
In a previous issue of our Legal Digest, we examined the draft Law on the European Digital Identity Wallet (‘LDEDIW’), published for public consultation earlier in 2026. The present draft law pursues similar objectives but adopts a different legislative approach. Rather than enacting a new standalone law, the rules concerning digital identity wallets, their providers, relying parties and authentic sources are integrated into the existing Electronic Identification Act.
The proposed model distinguishes between European digital identity wallets and the national digital identity and e-services wallet. The European wallet is an electronic tool through which individuals will be able to identify themselves, prove certain circumstances and provide certified data when using public and private services. It will, for example, enable individuals to provide data on their identity, age, education, professional qualifications or authorisation to carry out a specific activity.
The key feature of European digital wallets is their cross-border applicability. A digital wallet that meets the requirements of eIDAS 2.0 and is recognised in one Member State should also be usable in the other Member States of the European Union. In this way, citizens and businesses will be able to use the same digital identification tool when accessing administrative, financial, educational and other services in different countries.
A competitive model is being adopted, under which multiple European digital wallets, provided by different suppliers, may be established in Bulgaria. These will be subject to certification and entry in a register maintained by the Minister for Innovation and Digital Transformation. The registered wallets will be deemed recognised within the meaning of the European regulation.
Alongside these, there are plans to develop a national digital identity and e-services wallet. This will take the form of a mobile app containing a European digital identity wallet, but will also include additional national functionalities. Consequently, the national wallet will not merely be a means of electronic identification, but a single point of access to various electronic administrative services.
Through it, citizens will be able to request electronic administrative services, exchange documents with administrative bodies, receive electronic notifications and access information from authentic state sources. Access is also provided to documents from the Unified Portal for E-Justice, information on electronic fines and penalty notices, as well as data on taxes and fees due, with the option to pay them.
The new regulations also introduce a register of relying parties. These are the public and private entities that will use the digital wallets to identify a person or to verify the authentication data provided by them. Entry into the register will take place following the submission of documents proving compliance with the requirements of the law, eIDAS 2.0 and the applicable European acts.
A significant change from the current framework is the removal of the specific regime for private electronic identification centres, which, according to the explanatory memorandum to the draft law, are redundant under the new architecture. This does not affect the activities of private providers of certification services, including qualified electronic signatures, which retain their role under the new model.
Compared to the draft LDEDIW, the main difference lies in the legislative approach. The previous draft provided for a separate law dedicated to the European electronic identity portfolio, whilst the current proposal incorporates the rules into the Electronic Identification Act and, at the same time, restructures the existing national system. In terms of the underlying concept, however, the two drafts are similar – both adopt a competitive model comprising European wallets, a dedicated state wallet and registers of system participants.
The new draft law also sets out specific deadlines for its practical implementation. The Council of Ministers must bring the Regulations for the Implementation of the Act into line with the new provisions within 9 months of the publication of the amendments. The national wallet must be established within 18 months of the act coming into force. Within the same timeframe, the Minister for Innovation and Digital Transformation and the Communications Regulation Commission must adopt a national scheme for the certification of European digital wallets.
For businesses, the new regulations will be of particular significance in relation to remote identification, the electronic conclusion of contracts and the verification of officially certified data. Banks, financial institutions, payment service providers, insurers, telecoms operators and other service providers will need to assess whether and how to integrate the digital wallets into their processes. For entities acting as relying parties, there will also be registration, technical and organisational requirements.
In the long term, European digital wallets could reduce the need to submit the same documents repeatedly, facilitate remote services and speed up the cross-border provision of services. However, the practical achievement of these objectives will depend on the adoption of secondary legislation, the certification of the portfolios, the readiness of national registers and the timely integration of public and private sector systems.
The legislative process is still at an early stage and the final text may be subject to change. Nevertheless, the draft bill outlines a relatively clear future model: a multitude of mutually recognised European digital wallets and a separate national digital wallet that combines digital identity with access to electronic administrative services.
This article has been prepared for and is part of the Legal Digest issued by Penkov, Markov & Partners. The publications therein do not constitute legal advice and are not binding. Penkov, Markov & Partners reserves all rights to this material, and any distribution thereof is subject to the prior written consent of the law firm.
