Last reviewed: 19 September 2026

The EUDI Wallet for HR and recruitment: what actually changes

For an employer or a staffing agency, the wallet changes how the pre-employment file is assembled, not what has to be in it. The identity check, the right to work check and the qualification check stop being a set of emailed scans chased across days and become a single request the candidate approves. What it does not change: the duty to run those checks, the record national law says you must keep, or your own decision about who to hire.

This page covers who is affected and on what basis, which hiring processes the wallet touches, the credentials that matter, what changes versus today, a worked cross-border contractor example, how right to work and data protection rules interact with a wallet presentation, and three concrete next steps. It assumes you already know what an EUDI Wallet is; it does not repeat that introduction.

Onboarding a contractor from another member state

The case where the difference is largest: a contractor hired across a border, cleared before the first day rather than during the first week. The wallet shortens the presentation steps. It does not remove the record national law still requires you to keep.

Who is affected, and on what basis

Start with what does not apply. eIDAS 2.0 (Regulation (EU) 2024/1183) on EUR-Lex puts the wallet acceptance obligation on private relying parties in named sectors, such as banking, health, transport, energy, education and telecommunications. Being an employer is not one of those bases. If you also operate in one of the named sectors, the obligation reaches you through that activity rather than through your hiring.

What does bind an HR department arrives from employment law instead. the Employers Sanctions Directive 2009/52/EC on EUR-Lex requires an employer hiring a third-country national to check that the person holds a valid residence permit or equivalent authorisation before employment starts, to keep a copy or record of it available for inspection for at least the duration of the employment, and to notify the competent authority. For an EU or EEA national there is nothing equivalent to check: Regulation (EU) 492/2011 on freedom of movement for workers, on EUR-Lex means no work authorisation is needed at all.

Staffing agencies sit in both positions at once. They perform checks on an employer's behalf while being an employer themselves for the workers on their own books, so the same process has to satisfy two sets of expectations about who asked for what and on whose authority.

Right to work procedure is set by national transposition, not at EU level. Describe your own member state's rule rather than assuming a common European procedure exists.

Where the wallet actually shows up in hiring

Six points in the hiring cycle, in practice, once a candidate can present credentials:

Candidate identity checks, at offer stage and again at contract signing
Right to work verification, where the hire is a third-country national
Diploma and professional certification checks for a role that states a requirement
Background and screening, including the references an employer chases by email today
Contractor and agency worker onboarding, where the checker is not the employer
Payroll identity, where the same person has to be proven again to a different system

The credentials that matter here

Six credential types cover most of what a hiring process asks for. PID is the person identification data every wallet carries. A right to work or residence attestation issued by a public authority is a PuB-EAA; a diploma or certification from a qualified issuer is typically a QEAA. Diplomas in particular already have their own European format, the European Digital Credentials for Learning built on the Europass framework, which predates the wallet and is being aligned with it rather than replaced by it. Source

Credential	Who issues it	Who relies on it
PID	National PID Provider	Recruiter, at the identity check before the contract
Right to work or residence attestation	National immigration or residence authority	Compliance, for the pre-employment check on a third-country national
Diploma (European Digital Credential for Learning)	Awarding university, college or training provider	Recruiter, where the role states a qualification requirement
Professional certification or licence	Professional body, certification scheme or national register	Line manager or site supervisor, before the worker starts
Employment history attestation	Former employer, or a payroll or social security body	Screening, in place of chasing a reference by email
Agency mandate credential	The employer, to the staffing agency acting on its behalf	The candidate, who can see which employer the agency is asking for

What changes versus how this is done today

A scan of a passport emailed to a recruiter and filed in the HR system is replaced by a signed attribute presentation, so the identity step no longer produces a document you then have to protect.
A diploma taken on trust, or sent to a verification bureau at a per-check fee, is replaced by a credential whose signature traces back to the awarding institution.
A reference chased by email over a week is replaced, where the former employer issues one, by an employment history attestation the candidate already holds.
Screening repeated in full at every new employer is the case with the most to gain and the least settled position, because how long a result stays valid and who may see it is a matter of national rule rather than of technology.

Worked example: a contractor from another member state, cleared before day one

A firm needs a certified electrical engineer on site for a six-month contract. The candidate lives in another member state, holds a degree from a university there and a certification from a scheme in a third country. Today this runs roughly as follows: the candidate emails a passport scan, the agency files it, the diploma goes to a verification bureau, the certification body is contacted separately, and the site supervisor takes the certification on trust in the meantime because the start date will not move. The contractor is on site in week one and fully cleared some time in week two.

With wallets on both sides, the agency sends one request. The candidate approves it and presents PID, a right to work attestation if the hire needs one, the diploma as a digital credential from the awarding university, and the certification from the issuing scheme. Each one is verified against its issuer rather than against a copy. The agency returns a verified result to the employer, not the underlying documents.

What the wallet removes here: the emailed scan sitting in three inboxes, the bureau fee and its turnaround, and the gap where a supervisor accepts a claim because the start date is fixed. What it does not remove: the employer's record-keeping duty where the hire is a third-country national, any site-specific competence assessment the supervisor runs on their own account, and the fact that this only works to the extent the issuing university and certification scheme actually issue credentials, which today is uneven.

Right to work, retention and screening data

Right to work is a national procedure: the EU-level duty is to check before employment starts and to be able to show you did. The document list, the format of the record and the inspection regime are set by each member state when it transposes the directive, and they differ. A wallet presentation changes the evidence you hold, so the question to ask locally is whether your national rule accepts a verified presentation and a log entry in place of a document copy. Source

The identity copy problem: an HR system holding scans of passports and permits is holding exactly the data that hurts most in a breach, usually for longer than anyone intended, and data minimisation under the GDPR pushes against keeping it. Presenting an attestation lets you verify an attribute without receiving the document behind it, which reduces what you retain. It does not reduce it to nothing while a record-keeping duty applies to that hire. Source

Recognition is not verification: for a regulated profession, confirming that a qualification is genuine and confirming that it entitles someone to practise in your country are two different questions. The recognition directive governs the second one and a credential does not answer it. Verify with the wallet; recognise through the existing route. Source

Screening data is treated separately: criminal conviction data has its own regime under the GDPR and may generally only be processed under official authority or where national law provides safeguards. That constrains the portable-screening idea more than any technical limit does, and how a screening attestation would fit is not settled at the time of writing. Source

Whether a verified wallet presentation satisfies a national record-keeping duty, and how mandate credentials for delegated agency requests are standardised, are both open points at the time of writing. Confirm the current state before designing a process around either. the ARF on GitHub

When the agency does the asking: the mandate chain

A candidate asked for identity documents by a recruiter they have never met has no way to tell whether the request is legitimate, and today the answer is an email signature. A mandate credential turns that into something checkable: the agency shows whose authority it is acting on, and the employer gets back a result rather than a folder of documents.

What to do now

Inventory what your hiring process currently collects as a document rather than as a check: passport scans, permit copies, diploma PDFs. Each one is a candidate for replacement by a presentation, and each one is also a retention question you are already carrying.
Ask your legal or compliance function one specific question: under our national transposition of the right to work rules, what exactly must we retain, and would a verified presentation plus a log entry satisfy it? The answer sets how much of the identity copy problem a wallet can actually solve for you.
Pilot on cross-border hires and on roles with a stated qualification requirement first. That is where today's process is slowest and where a credential replaces a bureau rather than duplicating a check you already do cheaply.

Hiring today versus hiring with the EUDI Wallet

Dimension	Today	With the EUDI Wallet
Time to onboard	Days to weeks, set by whichever third party answers last: the bureau, the former employer, the screening provider	Minutes for the checks the candidate already holds credentials for; anything still done by a third party takes the same time it did before
Documents retained	Scans of passports, permits and diplomas sit in the HR file for as long as the retention rule says, and sometimes longer	A verified result instead of the underlying document, except where national transposition of the record-keeping duty still requires a copy or record
Verification cost	Per-check fees to diploma verification bureaux and screening providers, plus recruiter time spent chasing	The issuer has already done the work, so a presentation is verified without a per-check fee; the checks no credential covers still cost what they cost
Cross-border reach	A diploma or certification from another member state often means a recognition request, a translation, or a bureau that covers that country	A credential issued in any member state is presented the same way, once wallets and the relevant attestation rulebooks are in place on both sides

Frequently asked questions

Are employers legally required to accept the EUDI Wallet?

As an employer, generally not. The wallet acceptance obligation in eIDAS 2.0 falls on private relying parties in named sectors such as banking, health, transport, energy, education and telecommunications. Being an employer is not itself one of those bases. If your organisation also operates in a named sector, the obligation reaches you through that activity, not through your hiring. What does reach HR is employment and right to work law, which sets what you must check and what you must keep; the wallet is a new way to do that checking, not a new duty.

Can we stop keeping copies of identity documents in the HR file?

Not automatically, and this is the point most worth being careful about. The Employers Sanctions Directive requires an employer hiring a third-country national to keep a copy or a record of the residence permit available for inspection for at least the duration of employment. What counts as an adequate record is set by each member state's transposition, so whether a verified wallet presentation plus a log entry satisfies it depends on your own national rule. A wallet reduces what you need to collect in the first place; it does not by itself dissolve a retention duty.

Does this change anything for hiring EU nationals?

It changes the paperwork, not the entitlement. An EU or EEA national already needs no work authorisation to take a job in another member state under the free movement rules, so there is no permit to check. Where the wallet helps with an EU hire is everything downstream of that: proving identity without emailing a passport scan, and proving a diploma or a professional certification issued in another country without a recognition request or a verification bureau.

Does a diploma credential replace a verification bureau?

For a diploma the institution has issued as a digital credential, yes, in the sense that the check no longer needs a third party to confirm the award: the signature traces back to the awarding institution directly. Two caveats. A bureau that also assesses whether a foreign qualification is equivalent to a domestic one is doing something a credential does not do, and that recognition question survives. And coverage is uneven, so plan on running both paths for some years rather than switching over.

Does the wallet let us reuse a background check from a previous employer?

That is the direction, but it is the least settled part of this page. Technically, a screening result issued as an attestation could be presented to a second employer rather than the check being run again. Legally, criminal conviction data gets specific treatment under the GDPR and national rules often fix how recent a check must be and who may see it. Treat portable screening as something to watch rather than something to build a process on today.

How does this work when a staffing agency does the checking for us?

A mandate credential is the mechanism the architecture points at: the employer issues the agency a credential naming the scope of what it may ask for, the agency presents that mandate alongside its request, and the candidate can see which employer is actually behind the question. What comes back to the employer is a verified result rather than the candidate's documents. How mandates of this kind are standardised is still being worked through, so confirm the current state before designing a process around a specific pattern.

Cite this page

Credenco. (2026). The EUDI Wallet for HR and recruitment: what actually changes. Retrieved 19 September 2026, from https://www.credenco.com/explained/eudi-wallet-for-hr-and-recruitment

Changelog

2026-09-19: Page published.

This page is informational and does not constitute legal advice. Confirm the eIDAS 2.0, employment, right to work and data protection requirements that apply to your organisation with qualified counsel.

Sources referenced on this page: eIDAS 2.0 (Regulation (EU) 2024/1183) on EUR-Lex, the Employers Sanctions Directive 2009/52/EC on EUR-Lex, Regulation (EU) 492/2011 on freedom of movement for workers, on EUR-Lex, Directive 2005/36/EC on the recognition of professional qualifications, on EUR-Lex, the Europass Decision (EU) 2018/646 on EUR-Lex, the GDPR (Regulation (EU) 2016/679) on EUR-Lex, the ARF on GitHub.

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