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Digital EU powers of attorney for banks and KYC teams
What banks and KYC teams need to distinguish between identity, company data and authority.
Directive (EU) 2025/25 does not create a general banking mandate. Banks should prepare to distinguish verified identity, verified company facts and authority for the requested action.
What the law covers
The digital EU power of attorney covers company-law procedures within Directive (EU) 2017/1132, including formation, branches and cross-border conversions, mergers and divisions [Directive (EU) 2025/25, Art. 16c(1)]. It is not a general authority to operate a bank account or approve a payment.
The EU Company Certificate supplies register-backed company facts [Directive (EU) 2025/25, Art. 16b]. An electronic attestation of attributes can carry evidence of powers and mandates to represent a person or company [Regulation (EU) 2024/1183 (eIDAS 2), Annex VI, point 9]. Neither removes the need to match the authority to the action.
What to build
- Keep identity, company status and authority as separate checks.
- Record the authority's source, scope, expiry and revocation state.
- Return a clear reason when authority is absent or too narrow.
- Retain the evidence used for the decision.
- Register wallet-relying-party information when the eIDAS regime applies [Implementing Regulation (EU) 2025/848].
Dates
| Date | Relevance |
|---|---|
| 24 December 2026 | Wallet-relying-party registration rules apply |
| 24 December 2027 | Certain private relying parties required to use strong authentication must accept EUDI Wallets, subject to Article 5f |
| 31 July 2028 | Main Directive 2025/25 measures apply through national law |
What is not required
The Directive does not require banks to accept its digital power of attorney for ordinary banking, tax or commercial transactions. Any wider mandate depends on other Union or national law and the bank's applicable obligations.
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) 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, “Digital EU powers of attorney for banks and KYC teams”, EUDIPOA, published 2026-09-04, last verified against its sources 2026-09-04, https://eudipoa.com/roles/banks-kyc.
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
- 2026-09-04 — First published from Directive 2025/25 and the eIDAS 2 instruments.