What to do, by when
What to do, by when: the plain timeline
Every date in the new EU rules that matters to a company, a register, a relying party or a software team — what is actually obliged, what is merely smart, and what you can safely ignore.
The honest one-line version: almost all of the hard deadlines in these rules fall on Member States, registers and the Commission — not on companies. What companies get is mostly new rights (a free certificate, an apostille-free power of attorney) plus two real duties: keep your register filings current within hard deadlines, and — if you are a partnership — a new compulsory disclosure regime. Anyone selling you an urgent "Directive 2025/25 compliance package" for a limited company should be asked which article they mean.
This page says what to do in plain words. Every claim carries the article it comes from, so your lawyer can check us in minutes.
If you run a company (limited liability, Annex II)
Your two real obligations, from 31 July 2028
1. File changes fast. Once your Member State applies the new rules, any change to your registered documents and information — directors, registered office, statutes, and so on — must be filed with the register within at most 15 working days of the change being made [Directive (EU) 2025/25, Art. 15(2)(a) of Dir. (EU) 2017/1132 as replaced]. Accounting documents are excluded from that clock, and conversions, mergers and divisions follow their own rules [Directive (EU) 2025/25, Art. 15(2)(a) and recital 22]. Member States must back this with "effective, proportionate and dissuasive penalties", explicitly including late filing [Directive (EU) 2025/25, recital 22]. If your company currently treats register filings as an annual clean-up job, that habit becomes a liability.
2. Keep the register true. The register becomes the thing everyone else relies on — the EU Company Certificate is generated from it, and other Member States' registers will pull your documents from it instead of asking you. Wrong register data stops being a cosmetic problem and starts propagating across the EU with your name on it [Directive (EU) 2025/25, Arts. 16b(1) and 13g(2a)].
Your new rights, from the same date
| From | You can | Basis |
|---|---|---|
| 31 July 2028 | Get your EU Company Certificate — proof of incorporation and key facts accepted in every Member State — free of charge at least once per calendar year | Art. 16b(1), (5) |
| 31 July 2028 | Use the digital EU power of attorney to authorise someone for cross-border formation, branch and merger-type procedures — accepted as evidence, no apostille | Arts. 16c(2), 16d(2) |
| 31 July 2028 | Refuse apostille demands on register-certified documents in other Member States | Art. 16d(1)–(2) |
| 31 July 2028 | Form a company or register a branch in another Member State without re-supplying documents your home register already holds — the registers exchange them | Arts. 13g(2a), 28a(5a) |
| 31 July 2028 | Push back on routine translation demands where the information is in the certificate or the register interconnection | Art. 16g |
Worth doing before 2028 (smart, not obliged)
- Audit your register entries now — especially who is recorded as authorised to represent the company, and whether representation is sole or joint. That exact field goes into your EU Company Certificate [Directive (EU) 2025/25, Art. 16b(2)(j)], and errors take time to fix through a register.
- Map who acts for you across borders — which people hold which authority for which procedures. When the power of attorney template lands, companies that know their own mandate map will use it in days, not quarters. Our mandate pages cover how to think about this.
- Do not buy anything sold as a "digital EU power of attorney" today. The Commission template is not yet in the Official Journal; we check for it weekly [Directive (EU) 2025/25, Art. 24(2)(e)].
If you run a partnership (Annex IIB types)
This is the group with genuinely new homework. From 31 July 2028 (as transposed), partnerships of the types listed in Annex IIB face compulsory disclosure — for many, for the first time under EU law — of at least: name, legal form, registered office, registration number, limited partners' liability caps (where registered), the instrument of constitution and every amendment with consolidated text, who is authorised to represent the partnership and whether alone or jointly, general and limited partners' particulars (where registered), accounting documents, and winding-up, nullity and liquidation events [Directive (EU) 2025/25, Art. 14a of Dir. (EU) 2017/1132 as inserted]. The 15-working-day filing clock applies to partnerships too [Directive (EU) 2025/25, Art. 15(2)(a)].
What to do: check whether your legal form appears in your country's Annex IIB list once transposition lands (our country table will track this), and get your constitutive documents and representation records into filing-ready shape before 2028, not after.
If you accept documents or authority from companies (banks, notaries, registers, counterparties)
| Date | What changes for you | Basis |
|---|---|---|
| 24 Dec 2026 | EUDI wallets exist in every Member State; if you intend to rely on wallet presentations, you must register as a wallet-relying party in your Member State, declare what data you will request, and request nothing beyond it | Reg. 910/2014 as amended, Art. 5a(1), 5b(1)–(3); IR (EU) 2025/848 |
| 24 Dec 2027 | If you are a private relying party required to use strong customer authentication (banking, financial services, telecoms and other listed sectors; micro and small enterprises excepted): you must accept EUDI wallets at the user's voluntary request | Reg. 910/2014 as amended, Art. 5f(2) |
| 31 Jul 2028 | You must accept the EU Company Certificate as sufficient evidence, accept the digital EU power of attorney as evidence of authority within its stated scope, and stop demanding apostilles on in-scope documents | Dir. (EU) 2017/1132 as amended, Arts. 16b(1), 16c(2), 16d |
Two duties arrive with the acceptance duty: you remain responsible for authenticating and validating what is presented to you [Regulation (EU) 2024/1183 (eIDAS 2), Art. 5b(9)], and refusal is confined to the narrow authenticity and fraud safeguards, case by case [Directive (EU) 2025/25, Arts. 16e–16f]. Build your intake procedures for that now — the failure mode to design out is the one where a valid signature is mistaken for valid authority: valid token ≠ allowed action.
If you build software in this space
- By 31 July 2026 (overdue): the Commission's implementing acts — the certificate and power of attorney templates, taxonomies and wallet-compatibility specs — were due. As of our last verification they are not in the Official Journal; our updates page tracks this weekly [Directive (EU) 2025/25, Art. 24(2)].
- 24 December 2026: wallet-relying-party machinery applies — national registers with a common API, access certificates, registration certificates [Implementing Regulation (EU) 2025/848, Arts. 3–8, 11]. If your product relies on wallet presentations, your registration path starts here.
- From 31 July 2028: the instruments go live nationally. Products that already model mandates as structured, revocable objects will consume the new attestations as inputs; products holding PDFs will be parsing prose. See the mandate object.
What you do NOT have to do
Worth stating, because the compliance-industrial complex will say otherwise:
- Nothing in Directive (EU) 2025/25 obliges any company to use the digital EU power of attorney or the EU Company Certificate. They are options — "companies can use" the template [Directive (EU) 2025/25, Art. 16c(1)]; national instruments remain valid [Directive (EU) 2025/25, recital 28].
- No company is obliged to hold an EUDI wallet. The wallet duties fall on Member States (to provide) and on relying parties (to register and, in listed cases, accept) [Regulation (EU) 2024/1183 (eIDAS 2), Arts. 5a(1), 5b, 5f].
- Nothing about the European Business Wallet is owed by anyone. It is a proposal awaiting committee decision, not law — tracked here.
The whole thing on one line each
| Date | Who | What |
|---|---|---|
| 31 Jul 2026 | Commission | Template implementing acts due — overdue, not yet in the OJ as of our last check |
| 24 Dec 2026 | Member States | EUDI wallets available; relying-party registration machinery applies |
| 31 Jul 2027 | Member States | National transposing laws adopted and published |
| 24 Dec 2027 | Banks and other SCA-bound private relying parties | Must accept EUDI wallets on user request |
| 31 Jul 2028 | Everyone | Rules apply: certificate, power of attorney, no apostille, 15-working-day filing, partnership disclosure |
| 1 Aug 2029 | Registers | Group-of-companies information through the register interconnection |
| 31 Jul 2032 | Commission | Evaluation report on how it all worked |
Dates come from the instruments, not from commentary — the chains are on the Directive page and the wallet page. When national transposition starts moving the practical dates in your country, this page and the country table move with it.
Sources
- Law Directive (EU) 2025/25 of the European Parliament and of the Council of 19 December 2024 amending Directives 2009/102/EC and (EU) 2017/1132 as regards further expanding and upgrading the use of digital tools and processes in company law (OJ L, 2025/25, 10.1.2025). http://data.europa.eu/eli/dir/2025/25/oj. Retrieved 2026-08-27.
- Law Regulation (EU) 2024/1183 of the European Parliament and of the Council of 11 April 2024 amending Regulation (EU) No 910/2014 as regards establishing the European Digital Identity Framework (OJ L, 2024/1183, 30.4.2024). http://data.europa.eu/eli/reg/2024/1183/oj. Retrieved 2026-08-27.
- Law Commission Implementing Regulation (EU) 2024/2977 of 28 November 2024 laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards person identification data and electronic attestations of attributes issued to European Digital Identity Wallets (OJ L, 2024/2977, 4.12.2024). http://data.europa.eu/eli/reg_impl/2024/2977/oj. Retrieved 2026-08-27.
- Law Commission Implementing Regulation (EU) 2024/2981 of 28 November 2024 laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and the Council as regards the certification of European Digital Identity Wallets (OJ L, 2024/2981, 4.12.2024). http://data.europa.eu/eli/reg_impl/2024/2981/oj. Retrieved 2026-08-27.
- Law Commission Implementing Regulation (EU) 2025/848 of 6 May 2025 laying down rules for the application of Regulation (EU) No 910/2014 of the European Parliament and of the Council as regards the registration of wallet-relying parties (OJ L, 2025/848, 7.5.2025). http://data.europa.eu/eli/reg_impl/2025/848/oj. Retrieved 2026-08-27.
Cite this page
Rob Prime, “What to do, by when: the plain timeline”, EUDIPOA, published 2026-08-27, last verified against its sources 2026-08-27, https://eudipoa.com/comply.
Better still, cite the instruments themselves — the Sources list below gives each one’s ELI, the EU’s permanent identifier for legislation. This page is a guide to the law, not the law.
Changelog
- 2026-08-27 — First published. Obligations and dates verified against the full instrument texts; company duties under new Articles 14a and 15 of Directive (EU) 2017/1132 read directly from the inserted text.