EU BUSINESS IDENTITY · ENTERPRISE GUIDE

European Business Wallet: Identity, Representation and Enterprise Authority

The European Business Wallet is a proposed EU framework designed to give businesses and public-sector bodies a trusted digital way to identify themselves, exchange verified documents, sign and seal information, communicate across borders and delegate others to act on their behalf.

For enterprises, one aspect is particularly important: digital identity is moving closer to digital representation and delegation.

But representation is not the end of the governance question. As organisations increasingly delegate work to people, systems and AI agents, they still need to determine what authority has been granted, within what scope, which actions require human judgment and what record remains.

Trusted business identity establishes who acts. Governance establishes what they may do — and what happens when they act.

What is the European Business Wallet?

The European Business Wallet is a legislative proposal from the European Commission for a harmonised digital wallet framework for businesses and public-sector bodies across the European Union.

The proposal is intended to simplify trusted digital interactions between businesses and between businesses and public administrations. Proposed capabilities include proving business identity, creating and exchanging trusted documents, using electronic signatures and seals, communicating through secure channels and delegating representatives to act on behalf of an organisation.

European Business Wallets are designed to build on and interoperate with existing European digital identity infrastructure, including the EU Digital Identity framework.

As of September 2026, the European Business Wallet remains a legislative proposal. It should not be described as final adopted EU law.

The Commission proposed the regulation on 19 November 2025, and the legislative procedure remains ongoing.

Why is the EU proposing a European Business Wallet?

Businesses operating across the EU still encounter fragmented processes for proving organisational identity, submitting documents, demonstrating representation rights and interacting with public administrations.

The European Business Wallet proposal aims to create a more consistent digital mechanism for these interactions across the Single Market.

Instead of repeatedly relying on scanned documents, separate portals and manual verification, organisations could use a trusted digital environment to identify themselves, exchange verifiable business information and perform legally significant digital actions.

The objective is not simply another place to store documents. It is to make trusted business interactions more interoperable across borders.

The Commission frames the initiative around harmonised business identity, representation and regulatory interaction; the Council says the wallets should complement rather than replace existing B2B and B2G systems.

What could businesses do with a European Business Wallet?

Under the current proposal and Council position, European Business Wallets are intended to support several forms of trusted digital interaction.

Prove organisational identity

Establish the identity of a business or public-sector body in trusted digital interactions.

Create and exchange trusted documents

Store, present and exchange trusted business information such as licences, permits, certificates and other verified documents.

Sign, timestamp and seal

Use electronic signatures, electronic seals and timestamps for trusted digital business processes.

Delegate representatives

Allow authorised representatives to act on behalf of the organisation within the mechanisms established by the framework.

Communicate across borders

Support secure digital interactions with other businesses and public administrations across the EU.

These functions are reflected in current Commission and Council descriptions.

European Business Wallet vs EUDI Wallet: what is the difference?

The European Business Wallet and the EU Digital Identity Wallet belong to the same broader European movement toward trusted, interoperable digital identity, but they address different contexts.

The EUDI Wallet framework establishes trusted digital identity and credentials for natural and legal persons across digital interactions.

The European Business Wallet proposal focuses more directly on organisations and their operational interactions: proving business identity, exchanging trusted documents, representing the organisation and conducting business or administrative processes digitally.

The proposed European Business Wallet framework is intended to interoperate with the EU Digital Identity ecosystem rather than replace it.

QuestionEUDI WalletEuropean Business Wallet
Core contextDigital identity and credentialsOrganisational digital interactions
IdentityNatural and legal persons within the EUDI frameworkBusiness/public-body identity
Credentials/documentsPresent trusted identity data and attestationsCreate, manage and exchange trusted business documents
RepresentationCan carry relevant attestationsRepresentation and mandates are a central business use case
Business operationsIdentity layer used in digital servicesDesigned specifically for B2B/B2G operational interactions
Enterprise AI governanceNot its primary purposeNot its primary purpose

Neither framework should be presented as an enterprise AI governance system.

EUDI Wallet for businesses

FROM REPRESENTATION TO AUTHORITY

Representation is not the same as unlimited authority

The European Business Wallet proposal makes delegation materially more important for digital business.

The Commission's proposal includes a mandate- and role-based authorisation approach intended to let organisations assign rights to authorised representatives and manage roles and responsibilities within the wallet environment.

That does not mean every representative receives unrestricted authority.

Enterprise authority remains contextual. An organisation still needs to know who granted the mandate, what it covers, which constraints apply, whether it remains valid and whether a particular consequential action requires additional human judgment.

This distinction becomes especially important when authority is exercised not only by employees or legal representatives, but by automated systems and AI agents.

  1. Business IdentityWhich organisation is acting?
  2. RepresentativeWho is acting on its behalf?
  3. MandateWhat representation has been granted?
  4. Enterprise AuthorityWhat may this actor actually do here?
  5. ActionWhat was done?
  6. Governance RecordWhat decision and history remain?
Enterprise governance interpretation — not the European Business Wallet technical architecture.

What does a digital mandate actually establish?

A digital mandate can provide trusted evidence that an actor has been authorised to represent an organisation within a defined context.

But the existence of a digital mandate should not be confused with a universal permission to perform any business action.

The Council's negotiating position explicitly preserves national and EU rules governing powers of attorney and legal mandates. The proposed Business Wallet authorisation system is not intended to override those underlying legal arrangements.

Enterprises therefore still need to interpret representation and authority in the context of their own business processes, responsibilities and decision rights.

BUSINESS AUTHORITY IN AN AI-AGENT WORLD

What happens when an AI agent acts for the organisation?

The European Business Wallet proposal is not an AI-agent governance framework.

But its focus on business identity, representation and delegated mandates highlights a question that becomes increasingly important as enterprises deploy AI agents:

On whose authority is the agent acting?

An AI agent may have a technical identity and permission to access enterprise systems. That still does not establish the complete business mandate under which a consequential action is performed.

Enterprise AI governance needs to connect the agent to the responsible principal, the delegated authority, the action performed, any required human Review or Decision, and the resulting Governance Record.

Alterlayer treats this as a governance problem rather than an identity-wallet function.

  1. Principal
  2. Delegated Authority
  3. AI Agent
  4. Agent Action
  5. Authority Evaluation
  6. Human Review / Decision when required
  7. Governance Record
Alterlayer authority-governance model. This is not part of the European Business Wallet specification.

The European Business Wallet is designed to complement existing systems

Enterprises already operate identity platforms, ERP systems, CRM systems, workflow tools, regulatory portals and other business infrastructure.

The European Business Wallet proposal does not require all of those systems to be replaced by a wallet.

The Council's position explicitly states that European Business Wallets should complement rather than replace existing national B2B and B2G systems.

That principle matters for enterprise architecture: trusted identity and representation can become inputs into existing business processes rather than requiring every process to move into a new platform.

WHERE ALTERLAYER FITS

From delegated identity to governed AI authority

Alterlayer does not provide a European Business Wallet and does not replace enterprise identity infrastructure.

Alterlayer addresses a different layer: the operating governance around enterprise AI.

When AI systems and agents participate in business processes, organisations need to connect technical activity to accountable ownership and authority. They need to know what AI exists, who is responsible for it, which authority applies, where human judgment is required, what was decided and what historical record remains.

Alterlayer organises those questions around persistent AI Objects and the operating chain:

Discover → Govern → Record.

Trusted identity and representation can establish important facts about actors and mandates. Alterlayer provides the governance context for how enterprise AI operates around those facts.

AI Objects

Maintain the AI systems, applications, use cases and agents that the organisation needs to govern.

Ownership & Delegated Authority

Connect governed AI to accountable Owners, Principals and delegated authority where relevant.

Review & Explicit Decision

Keep consequential governance decisions connected to accountable human Review and organisational Decision Authority.

Governance Records

Preserve the decision, action and governed-state history needed to understand how an AI Object was governed over time.

Business Wallet infrastructure and AI governance answer different questions

QuestionEuropean Business WalletAlterlayer governance layer
Which organisation is this?Trusted business identityUses relevant organisational context
Who represents it?Representation and mandate mechanismsConnects relevant Principal/authority context to governed AI
Can trusted documents be exchanged?Proposed core capabilityDoes not replace business-document infrastructure
What authority does an AI agent have?Not the primary purpose of the Business WalletGoverns delegated AI authority in enterprise context
Does an action require human Review?Not its primary purposeConnects governed work to human Review and Decision
What governance history remains?Wallet authorisation/logging concerns its own environmentGovernance Records retain AI governance decisions and actions

Why enterprise AI makes this distinction more important

Digital business is moving from proving identity toward proving representation and enabling delegated action.

At the same time, AI systems are moving from generating information toward performing work.

Those trends meet at the question of authority.

Enterprises will increasingly need to distinguish:

Who or what is authenticated?

Who does that actor represent?

What authority has actually been delegated?

What action was performed?

Was human judgment required?

What institutional record remains?

Identity infrastructure and AI governance therefore become complementary rather than interchangeable layers.

European Business Wallet: frequently asked questions

What is the European Business Wallet?

The European Business Wallet is a proposed EU framework for trusted digital business identity and interactions. It is intended to support capabilities including business identification, trusted document exchange, electronic signatures and seals, representation and secure interactions with businesses and public administrations.

Is the European Business Wallet already law?

No. The European Commission presented the proposal on 19 November 2025. The Council adopted its negotiating position on 9 June 2026, and the ordinary legislative procedure remains ongoing as of September 2026.

Is the European Business Wallet the same as the EUDI Wallet?

No. The initiatives are related and designed to interoperate, but the European Business Wallet proposal focuses specifically on organisational and business interactions, while the EUDI Wallet framework addresses digital identity and credentials more broadly.

Can a European Business Wallet delegate authority?

The proposal includes mechanisms for creating, managing and delegating mandates to authorised representatives. The Council has also emphasised that this authorisation system does not override powers of attorney or legal mandates established under national or EU law.

Does a digital mandate mean someone can perform any action for the company?

No. Representation and authority remain contextual. The existence of a mandate does not by itself establish unrestricted authority for every possible business action.

Does the European Business Wallet govern AI agents?

No. It should not be presented as an AI-agent governance framework. Enterprises deploying AI agents still need to establish ownership, delegated business authority, human oversight, Decisions and Governance Records.

Does Alterlayer provide a European Business Wallet?

No. Alterlayer provides an enterprise AI governance operating layer. It does not provide a European Business Wallet or replace enterprise identity infrastructure.

How could European Business Wallets relate to AI governance?

Trusted business identity and representation can provide useful context about organisations and mandates. AI governance addresses the separate operational questions of which AI acts, under whose authority, which actions require human judgment and what governance record remains.

Govern the authority behind enterprise AI

Trusted business identity and digital representation can establish who is acting and on whose behalf.

Enterprise AI governance must answer the next questions: what authority applies, what the AI may do, where humans must decide and what record remains.

Alterlayer provides the operating layer for those governance questions.