EUDI Wallet Poland: mObywatel 3.0 Revolution

Overview

Poland stands as one of Europe's digital identity success stories, achieving what many countries aspire to: widespread adoption of mobile digital credentials with full legal recognition. With a population of 38.0 million, Poland's mObywatel app has reached 10 million users, making it one of the most successful national digital identity platforms in the EU.

The breakthrough came in July 2023, when mDowód (mobile ID) became legally equal to the physical plastic ID card—a milestone that transformed digital identity from a convenient alternative into a fully accepted legal document. This early success positions Poland exceptionally well for the transition to EUDI Wallet compliance by the December 2026 deadline.

Key Information

• Current App: mObywatel 2.0
• Next Generation: mObywatel 3.0 (EUDI-compliant)
• Current Users: 10 million+ (mid-2025)
• Digital ID (mDowód): Legally equal to physical ID since July 13, 2023
• Responsible Ministry: Ministry of Digital Affairs
• mObywatel 3.0 Launch: November 2026 (planned)
• Strategy: Parallel operation of 2.0 and 3.0 to minimize transition risk
• Readiness Assessment: "Very likely" to meet December 2026 deadline
• Interoperability Testing: Active participation in EU pilots (Warsaw, Wrocław)

mObywatel: Poland's Digital Services Platform

mObywatel (mCitizen) is Poland's unified mobile application for accessing government services and storing digital credentials. Developed by the Ministry of Digital Affairs, it serves as a one-stop platform for identity verification, service access, and document management.

Current Features (mObywatel 2.0)

Identity & Credentials

• mDowód: Digital ID card with full legal equivalence
• mPrawo Jazdy: Digital driver's license
• Vehicle Registration: Digital proof of vehicle ownership and insurance
• Student ID: Digital student identification for discounts and services

Health Services

• e-Prescriptions: Access to medical prescriptions without physical pickup
• EU Digital COVID Certificate: Vaccination and test verification
• Health Insurance Verification: NFZ (National Health Fund) confirmation

Government Services Access

• Social Security (ZUS): Benefits, contributions, retirement information
• Tax Records (MF): Tax declarations, refunds, payment history
• Business Registry (KRS/CEIDG): Business ownership documents
• Land Registry: Property ownership verification

Notifications & Communications

• Government notifications (tax deadlines, fines, administrative decisions)
• Secure messaging with government offices
• Appointment reminders for public services
• Service status updates (passport renewal, permit applications)

How mDowód Works

When you need to present your ID (at a bank, for age verification, to law enforcement, etc.), you:

1. Open the mObywatel app on your smartphone
2. Authenticate with biometric (fingerprint/Face ID) or PIN
3. Select "mDowód" from your credentials
4. Display the digital ID screen showing your photo, name, PESEL number, and security QR code
5. The verifier scans the QR code or visually confirms the digital ID

The QR code contains cryptographically signed data that can be verified against government databases, ensuring the digital ID is authentic and has not been revoked or expired.

Legal Equivalence: The 2023 Breakthrough

On July 13, 2023, Poland achieved a milestone few countries have reached: granting full legal equivalence to digital identity credentials.

What Legal Equivalence Means

Before July 2023, mDowód was a convenience feature—helpful but not legally binding. After July 13, 2023:

• Law Enforcement: Must accept mDowód during traffic stops and identity checks
• Banks: Must accept mDowód for account opening, loan applications, and KYC verification
• Age-Restricted Sales: Shops, bars, and online platforms must accept mDowód for age verification
• Government Offices: Cannot require physical ID when mDowód is presented
• Legal Documents: Can be used to verify identity when signing contracts or notarized documents

Implementation of Legal Equivalence

Poland's government conducted extensive training for public sector employees and launched awareness campaigns for private businesses to ensure smooth adoption. Key steps included:

• Police officers trained to verify mDowód QR codes using specialized apps
• Banks updated KYC procedures to accept digital ID verification
• Retailers educated on age verification using mDowód
• Legal framework updated to clarify mDowód's binding status in court

Adoption Success: 10 Million Users

Reaching 10 million users represents approximately 26% of Poland's population (or over 40% of smartphone-owning adults). This adoption rate exceeds most EU countries' digital identity programs.

Drivers of Adoption

Legal Equivalence Mandate

Once businesses and government offices were legally required to accept mDowód, citizens gained confidence that the digital ID would actually work when needed, eliminating the "why bother?" barrier that plagues voluntary-only digital ID programs.

COVID-19 Certificate Integration

During the COVID-19 pandemic, Poland integrated EU Digital COVID Certificates into mObywatel. Millions of citizens downloaded the app for vaccine verification, then discovered they could also store their ID, driver's license, and access other services—creating a "sticky" user base.

Government Service Integration

Unlike standalone digital ID apps, mObywatel provides tangible benefits beyond identity verification: e-prescriptions, tax records, Social Security access, and business documents. This utility drives continued engagement.

Public Awareness Campaigns

The Ministry of Digital Affairs ran targeted campaigns (especially in 2025) to boost awareness among demographics with lower adoption: elderly citizens, rural populations, and those without strong digital literacy. These campaigns emphasized:

• Convenience (no need to carry wallet with physical documents)
• Security (biometric protection prevents ID theft)
• Service access (one app for all government interactions)
• Legal validity (accepted everywhere physical ID is required)

mObywatel 3.0: The EUDI Wallet Transition

While mObywatel 2.0 serves Polish citizens well domestically, it does not yet comply with eIDAS 2.0 requirements for cross-border interoperability. mObywatel 3.0 addresses this gap.

Why a New Version?

eIDAS 2.0 mandates specific technical standards:

• Credential Formats: W3C Verifiable Credentials instead of proprietary formats
• Cryptographic Protocols: Updated signatures and key management for EU-wide verification
• Interoperability APIs: Standardized interfaces for cross-border credential exchange
• Selective Disclosure: Privacy-preserving attribute sharing (e.g., "over 18" without full birth date)
• Offline Verification: Credentials that can be verified without internet connectivity

Rather than attempting to retrofit these requirements into mObywatel 2.0 (risking bugs and service disruption), Poland chose to develop mObywatel 3.0 in parallel.

Parallel Operation Strategy

Poland is running mObywatel 2.0 and 3.0 side-by-side to minimize transition risk:

• 2.0 Continues: Existing users experience no service interruption
• 3.0 Beta Testing: Selected users test the new version and provide feedback
• Gradual Migration: Users can migrate credentials at their convenience (no forced cutoff)
• Fallback Option: If 3.0 encounters issues, users can revert to 2.0 temporarily

This approach contrasts with "big bang" launches that risk catastrophic failure if technical issues arise. Poland's strategy prioritizes service continuity and user trust.

Expected mObywatel 3.0 Features

Based on EUDI Wallet requirements and Poland's announcements:

• Cross-Border Recognition: Use mDowód to access services in all 27 EU member states
• Selective Disclosure: Share only necessary identity attributes (age, residency status) without full ID details
• Qualified Electronic Signatures: Legally binding signatures through the wallet (tested October 2025)
• Private Sector Credentials: Store and present credentials from banks, universities, employers
• Enhanced Privacy Controls: Detailed logs of when and where you shared identity data
• Offline Mode: Present credentials without cellular or Wi-Fi connectivity

Interoperability Testing and EU Collaboration

Poland is actively participating in EU-wide testing to ensure mObywatel 3.0 works seamlessly with other countries' EUDI Wallets.

Warsaw Interop Event (2025)

Poland hosted a major interoperability testing event in Warsaw (2025), bringing together representatives from EU member states, technology vendors, and the European Commission to test cross-border credential exchange. Polish mDowód credentials were successfully verified by systems from Germany, France, Italy, and other participant countries.

POTENTIAL Conference (Wrocław, September 2025)

The final milestone of the POTENTIAL Large Scale Pilot project funded by the European Commission took place in Wrocław on September 29-30, 2025. This event:

• Demonstrated wallet interoperability across multiple use cases (identity verification, signing, payments)
• Identified remaining technical challenges for December 2026 compliance
• Established best practices for wallet providers and service integrators
• Showcased Poland's leadership in digital identity implementation

Qualified Signature Pilot (October 2025)

Poland ran a qualified electronic signature pilot in October 2025, testing legally binding digital signatures through mObywatel. Qualified signatures (equivalent to handwritten signatures in legal force) are a key EUDI Wallet feature, enabling:

• Signing contracts remotely with full legal validity
• Submitting official documents to government agencies
• Authorizing financial transactions
• Consenting to medical procedures

The pilot validated Poland's cryptographic infrastructure and compliance with EU trust service provider regulations.

Security and Privacy Architecture

mObywatel employs multiple security layers to protect digital credentials and user privacy.

Device Security

• Biometric Authentication: Fingerprint or Face ID required to access the app
• PIN Fallback: Secure numeric PIN for devices without biometrics
• Device Binding: Credentials tied to specific smartphone; cannot be cloned to another device without re-verification
• Secure Element Storage: Cryptographic keys stored in hardware-protected area of the device

Credential Verification

When someone verifies your mDowód, the process works as follows:

1. You display the QR code on your phone
2. The verifier scans the QR code with a specialized app or device
3. The QR code contains cryptographically signed data linking to government databases
4. The verification app checks the signature against public keys published by the Polish government
5. If the signature is valid and the ID has not been revoked, verification succeeds

This cryptographic verification ensures that:

• The digital ID is authentic (issued by the Polish government, not a forgery)
• The ID has not been tampered with (any modification breaks the cryptographic signature)
• The ID is still valid (not expired, revoked, or reported lost/stolen)

Privacy Protections

mObywatel 3.0 will introduce enhanced privacy features required by eIDAS 2.0:

• Selective Disclosure: Share only requested attributes (e.g., "over 18" without birth date)
• Minimal Data Sharing: Verifiers cannot access more information than necessary for their purpose
• Audit Logs: Complete record of when and where you shared identity data
• Consent Management: Explicit approval required for each data sharing request
• Right to Deletion: Delete digital wallet and credentials without affecting physical document validity

GDPR Compliance

As a government service, mObywatel is subject to GDPR and Polish data protection laws:

• Does not process data for commercial or advertising purposes
• Provides full transparency about data collection and usage
• Allows users to access, correct, and delete their data
• Conducts regular security audits and privacy impact assessments

Age Verification for Social Media

Poland is planning to use mObywatel for age verification on social media platforms, addressing concerns about minors accessing age-inappropriate content.

How It Would Work

• User attempts to create social media account or access restricted content
• Platform requests age verification via EUDI Wallet protocol
• User opens mObywatel and approves sharing "over 13" or "over 18" status
• Platform receives confirmation without accessing full birth date, name, or other identity details
• User gains access to age-appropriate content

This selective disclosure approach protects minors while preserving user privacy—social media platforms don't receive full identity information, only age attestation.

Timeline and Roadmap

Completed Milestones

• Pre-2023: mObywatel 1.0 and early versions deployed
• July 13, 2023: mDowód granted legal equivalence to physical ID card
• 2023-2024: User base grows to 8+ million
• April 2024: eIDAS 2.0 regulation signed into EU law
• May 2024: eIDAS 2.0 enters into force
• 2024: mObywatel 3.0 development begins
• 2025: Warsaw Interop event hosted
• Mid-2025: 10 million users milestone reached
• September 29-30, 2025: POTENTIAL conference in Wrocław
• October 2025: Qualified signature pilot
• November 2024: EU adopts implementing acts for EUDI Wallet technical specifications

Upcoming Milestones

• Mid-2026: Cross-border eIDAS interoperability testing with other EU member states
• Q3 2026: mObywatel 3.0 beta testing with selected user groups
• November 2026: mObywatel 3.0 public launch (planned)
• December 2026: Poland must provide EUDI Wallet to all citizens (EU regulatory deadline)
• Q1 2027: Gradual migration from mObywatel 2.0 to 3.0
• End of 2027: Financial institutions required to accept EUDI Wallet for KYC verification
• 2030 Target: 80% of Polish citizens using digital wallet regularly

Cross-Border Use: Poland's EUDI Wallet Across Europe

Once mObywatel 3.0 achieves EUDI Wallet compliance, Polish digital credentials will be recognized across all EU member states.

Planned Cross-Border Use Cases

• Renting cars in other EU countries with Polish digital driver's license
• Opening bank accounts across the EU without in-person verification
• Accessing healthcare in other EU countries with European Health Insurance Card integration
• Age verification for online purchases EU-wide
• Business registration and professional license verification for cross-border work
• Proving academic credentials for employment in other EU countries
• Hotel check-ins without surrendering physical documents

Poland's Readiness Advantage

With 10 million users already comfortable using mDowód domestically, Poland doesn't face the adoption challenge plaguing many EU countries. Polish citizens are already digital identity users—they just need an app update to unlock cross-border functionality.

Official Resources and Support

For the latest information about Poland's EUDI Wallet and mObywatel:

• mObywatel Official Website - App information and download links
• Ministry of Digital Affairs - Official government digital transformation portal
• mObywatel on Google Play - Download for Android devices
• mObywatel on App Store - Download for iOS devices