What the digital EU power of attorney is not

The digital EU power of attorney is a narrow, optional, digital-only company-law instrument for cross-border procedures — not a universal digital mandate, not a wallet feature you can switch on, and not something anyone can issue today. Most of the bad takes about it come from ignoring one of those words.

Who this page is for

Anyone about to make a decision — technical, commercial or legal — based on what they think Article 16c says. Read this before the main explainer if you have already absorbed second-hand summaries.

It is not available yet

The Commission's implementing act establishing the template is due by 31 July 2026, and Member States apply the transposing measures from 31 July 2028 [Directive (EU) 2025/25, Art. 24(2) and Art. 4(2)]. Until then there is no template, no national procedure, and no register practice. A product demo can exist; a digital EU power of attorney within the meaning of Article 16c cannot.

It is not a universal mandate

Article 16c applies to "procedures within the scope of this Directive in another Member State, in particular the formation of companies, the registration or closure of branches, and cross-border conversions, mergers and divisions" [Directive (EU) 2025/25, Art. 16c(1)]. That is company law. It says nothing about authorising someone to operate a bank account, file a tax return, sign a commercial contract, or act in litigation. Whether the same template gets reused in other domains later is speculation — nothing in the instrument does it.

It is not a replacement for national powers of attorney

The instrument "is without prejudice to national rules on legal and statutory representation or any other types of powers of attorney" [Directive (EU) 2025/25, recital 28]. National powers of attorney continue to exist and continue to work. This adds a common, recognised template for specific cross-border procedures; it deletes nothing.

It is not mandatory

Companies "can use" the template [Directive (EU) 2025/25, Art. 16c(1)]. The obligations in Article 16c fall on Member States — to make the instrument available, verify grantors, authenticate it, and accept it — not on companies to use it.

It is not paper

It "should only exist in digital form" [Directive (EU) 2025/25, recital 28]. There is no paper variant with a QR code, unlike the EU Company Certificate, which explicitly has a paper form [Directive (EU) 2025/25, Art. 16b(7)].

It is not an EU-issued document

The Commission publishes a template. The instrument itself is drawn up, amended and revoked "in accordance with national requirements", which must at least include verification of the grantor's identity, legal capacity and authority to represent by courts, notaries or other competent authorities [Directive (EU) 2025/25, Art. 16c(1), second subpara.]. Validity is anchored in national procedure, not in Brussels — and not in any private product either.

It is not "just a wallet credential"

The instrument must be authenticated by trust services under Regulation (EU) No 910/2014 [Regulation (EU) No 910/2014 (eIDAS)], and its granting, amendment and revocation must be compatible for use with the European Digital Identity Wallet [Regulation (EU) 2024/1183 (eIDAS 2)]. The recitals point to the electronic attestation of attributes machinery [Directive (EU) 2025/25, recital 27]. But wallet compatibility is a delivery requirement, not the source of legal effect: presenting a technically valid attestation is not the same thing as holding an effective authority. What the relying party accepts is evidence of "the authorised person's entitlement to represent the company as specified in the document" [Directive (EU) 2025/25, Art. 16c(2)] — scope limits included.

It is not proof against revocation

Article 16c expressly contemplates amendment and revocation under national requirements, and lets Member States require filing of the power of attorney and of any amendment or revocation with a register [Directive (EU) 2025/25, Art. 16c(1) and (3)]. It does not create a Union-wide, real-time revocation lookup. How a relying party learns that yesterday's instrument was revoked this morning is exactly the kind of question the implementing acts and national transposition will have to answer — and this site will track what they actually say.

It is not the EU Business Wallet

The European Business Wallet is a Commission proposal for a separate regulation [EU Business Wallet (PROPOSAL)Proposal]. It is not adopted law, its content can change, and it should not be cited as if it were in force. The digital EU power of attorney, by contrast, is in an adopted directive today.

It is not the EU Company Certificate

They travel together in Directive (EU) 2025/25 and share plumbing (register issuance or verification, eIDAS authentication, wallet compatibility, no apostille). But the certificate proves what a company is — its incorporation and register facts [Directive (EU) 2025/25, Art. 16b(1)] — while the power of attorney proves what a named person may do for it [Directive (EU) 2025/25, Art. 16c(2)]. Conflating "the company exists" with "this person may act" is the oldest failure mode in organisational trust, and the Directive keeps the two instruments cleanly apart.