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eIDAS 2 in Poland: What it means for businesses in practice

December 29, 2025
Accace - eIDAS 2 in Poland

The rollout of eIDAS 2 in Poland represents an important shift in how businesses verify identity, sign documents and exchange sensitive information digitally. While the regulation also affects individuals, its practical impact is most visible in the business environment, particularly for companies operating online, handling regulated documentation or working across borders within the EU.

Poland already has a relatively mature digital public infrastructure, with tools such as mObywatel, mojeID and the Trusted Profile (Profil Zaufany) embedded in everyday administrative and business interactions. eIDAS 2 builds on these foundations by introducing higher assurance standards, new trust services and the European Digital Identity Wallet, all of which will gradually reshape how companies operate in the Polish market.

This article explains the current status of eIDAS 2 in Poland, outlines what businesses should expect next and highlights where preparation efforts should focus.

This article focuses on the Polish perspective. For a complete EU-wide overview and its business impact, see our full article on eIDAS 2.

Regulatory status and local readiness for eIDAS 2 in Poland

Poland is in the process of aligning its national framework with the revised eIDAS regulation. A draft amendment to the Act on Trust Services and Electronic Identification has already been published and is intended to implement the new EU rules, including provisions related to the European Digital Identity Wallet. At this stage, the amendment has not yet been adopted.

There is no standalone national roadmap dedicated solely to eIDAS 2 in Poland. Instead, implementation is expected to proceed through this legislative amendment and subsequent regulations shaped by EU implementing acts. Oversight of digital identity and trust services falls under the responsibility of the minister responsible for digitalisation. According to current plans, the draft legislation is expected to be adopted by the government in Q2 2026, although the final timeline will depend on the legislative process.

Digital identity ecosystem in Poland

Poland already operates a well-established digital identity ecosystem that will form the backbone of eIDAS 2 implementation. The central public solution is mObywatel, a government-operated mobile application that enables digital identity verification, access to public services and the use of selected digital documents.

In the private sector, mojeID is widely used as a bank-based electronic identification scheme, particularly for online authentication and customer onboarding. These solutions are already familiar to both businesses and users, which is expected to ease the transition to the European Digital Identity Wallet.

Poland is also participating in EU large-scale pilot projects related to the wallet, including the POTENTIAL consortium, where cross-border use cases such as digital driving licences, access to public services and qualified electronic signatures are being tested.

Qualified trust service providers in Poland

Qualified trust service providers (QTSPs) are essential to the functioning of eIDAS, as they deliver qualified electronic signatures, seals and other trust services with full legal effect across the EU.

In Poland, there are currently six qualified trust service providers:

  • Krajowa Izba Rozliczeniowa S.A. (KIR)
  • EuroCert
  • CenCert (Enigma Systemy Ochrony Informacji Sp. z o.o.)
  • QSCert®
  • InfoCert / Tinexta InfoCert
  • Certum by Asseco (Asseco Data Systems S.A.)

Qualified electronic signatures are well established in Polish business practice. They are commonly used for signing commercial contracts, corporate documentation, financial statements and ultimate beneficial owner (or UBO) filings, as well as for submissions to public authorities and public procurement procedures, where legal equivalence to handwritten signatures is required.

eIDAS 2 in Poland: Impact on businesses

The impact of eIDAS 2 in Poland will be most pronounced in sectors that rely heavily on secure digital identification and legally binding electronic documentation. This includes financial services and fintech, public-sector service providers and professional advisory firms such as legal, accounting and corporate service providers.

From an operational perspective, businesses will need to ensure their systems can support the European Digital Identity Wallet, integrate with national identity solutions and comply with EU interoperability standards. This will directly affect processes such as client onboarding, contract execution, statutory filings and cross-border digital transactions.

Key challenges for companies

Business readiness for eIDAS 2 differs significantly across the Polish market. Larger organisations, particularly those already using qualified electronic signatures, are generally better prepared. Many small and medium-sized enterprises, however, remain at an early stage and are waiting for more detailed technical and implementation guidance.

The main challenges include uncertainty around final technical standards, limited time for implementation once requirements are clarified, integration with existing IT systems and the associated costs. Companies must also address internal process changes, staff training and increased focus on cybersecurity, personal data protection and legal liability.

Opportunities created by eIDAS 2 in Poland

Despite these challenges, eIDAS 2 creates concrete opportunities that are closely tied to Poland’s existing digital infrastructure. Enhancements to tools such as mObywatel, mojeID and the Trusted Profile are expected to improve efficiency in interactions with public administration and reduce reliance on in-person procedures.

For businesses subject to KYC and AML requirements, faster and more secure digital identity verification can lower operational costs linked to traditional correspondence and document handling. Integration with qualified electronic signature solutions is also expected to shorten approval cycles for contracts and internal documentation.

In addition, eIDAS 2 will support easier access to cross-border digital services, strengthening the ability of Polish companies to operate within the EU single market.

FAQs: eIDAS 2 questions Polish businesses are asking us

Not yet. Poland has published a draft amendment to align national law with eIDAS 2, but it has not been adopted. Full applicability will depend on the legislative process and EU implementing acts.

eIDAS 2 builds on existing Polish digital identity tools. Businesses can expect these systems to evolve and become interoperable with the European Digital Identity Wallet, especially in public-sector and regulated use cases

Certain sectors and services will be required to support the wallet, particularly where digital identification and trust services are regulated. Other businesses may adopt it voluntarily to improve efficiency and cross-border operations.

Yes. Qualified electronic signatures remain legally valid and widely used in Poland. eIDAS 2 strengthens the framework and expands the range of qualified trust services.

Companies should review their digital identity, onboarding and document-signing processes, assess reliance on qualified trust services and monitor legislative and technical developments at both national and EU level.

Practical support for eIDAS 2 implementation in Poland

Accace in Poland supports businesses throughout the transition to eIDAS 2 by combining legal, HR, payroll, IT and advisory expertise. Our teams assist with reviewing internal policies related to digital identity and electronic signatures, assessing compliance of existing technological processes and redesigning HR and administrative workflows.

We also support the update of legal documentation, implementation of compliant electronic document archiving, supervision of digital identity wallet certification processes and alignment with GDPR and cybersecurity requirements. We have extensive experience with qualified electronic signatures, Trusted Profiles and secure digital document exchange.

For cross-border clients, we help design unified processes across multiple jurisdictions, while accounting for differences in national implementation timelines and potential interoperability challenges.

Dominik Szupernak
Associate | Accace Poland
Get in touch with us
Agnieszka Samborska
Legal Adviser and Partner | Accace Poland
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