European Business Wallet: digital identity, secure data exchange and legal notifications for simple, digital business

European Commission
Have your say

Proposal for a regulation – COM(2025)838
Annex – COM(2025)838
Staff working document – SWD(2025)837

Feedback

The Federation of Finnish Enterprises (Suomen Yrittäjät), representing small and medium-sized enterprises and micro enterprises across Finland, considers the objective of the proposed Regulation on European Business Wallets to be fundamentally positive. The initiative rightly identifies key challenges faced by businesses, particularly SMEs, including fragmented administrative systems, repeated identification and verification requirements, legal uncertainty in digital interactions, and the lack of a harmonised digital alternative for legally binding cross border communications. If well implemented, European Business Wallets could significantly reduce administrative burdens and improve legal certainty within the Single Market.

However, the proposal does not sufficiently ensure that these objectives will be realised in practice. There is a substantial risk that the Business Wallet, while formally voluntary, becomes a de facto mandatory channel for interaction with public authorities, procurement entities or dominant market actors. SMEs often have limited real choice and must comply with required systems in order to operate. Without stronger safeguards, this may effectively force businesses to adopt the Business Wallet, particularly given the uneven readiness of public authorities across Member States, potentially leading to legal uncertainty and unequal treatment.

On the other hand, broad and consistent uptake by public sector actors is essential for the success of the initiative. To deliver tangible benefits, companies must be able to use the Business Wallet for permits, notifications and other administrative procedures. Without firm public sector commitment and sufficient coverage of public services, expected simplification gains will not materialise. The balance between voluntary use for businesses and meaningful public sector adoption therefore requires clearer treatment in the proposal.

The cost assumptions also raise serious concerns from an SME perspective. Reliance on market driven provision may not guarantee affordability, particularly for micro enterprises and sole entrepreneurs. Recurring fees, onboarding and training costs, as well as the time required to adapt internal processes, risk placing a disproportionate burden on small businesses. The proposal currently lacks sufficient guarantees that core functionalities, including secure official communications, will remain largely affordable.

Furthermore, benefits are likely to be unevenly distributed. While companies engaged in cross border activities may gain significant advantages, many SMEs operating primarily on domestic markets may experience limited added value despite real compliance and adaptation costs. This highlights the need for more thorough and differentiated business impact assessments, with particular attention to micro enterprises.

There is also a clear risk of creating overlapping systems. If European Business Wallets are introduced alongside existing national solutions without replacing or effectively integrating them, overall administrative burdens may increase. Genuine simplification requires the removal or consolidation of obsolete obligations and parallel processes, supported by interoperable solutions.

Finally, special attention must be paid to the needs of micro‑enterprises and solo entrepreneurs in both the legislative framework and technical implementation. Proportionality, usability and simplicity must be prioritised to avoid user overload, low uptake and reduced acceptance of the regulatory framework.

In conclusion, Suomen Yrittäjät sees considerable potential in European Business Wallets to improve the operating environment for SMEs. However, stronger safeguards on costs, clearer guarantees of real voluntariness in practice, firm public sector commitment and concrete measures to avoid parallel systems are needed to ensure that the initiative delivers true simplification rather than becoming an additional regulatory layer.

With regards,
Suomen Yrittäjät

Maria Nyroos
Digital and RDI policy specialist