Update
State of the EU digital power of attorney: September 2026
The September 2026 position on the missing template acts, national transposition, Business Wallets, EU Inc. and the EUDI Wallet.
At 4 September 2026, the Commission's template implementing acts remain overdue, Czechia is the only Member State with measures recorded in the EUR-Lex notification database, the European Business Wallet remains a proposal, and the separate EU Inc. proposal now brings the same certificate and power-of-attorney machinery into a proposed new company form.
The legal position
Directive (EU) 2025/25 is in force. Its main national transposition deadline is 31 July 2027 and its main measures apply from 31 July 2028 [Directive (EU) 2025/25, Arts. 4–5].
The Commission deadline for implementing acts covering the multilingual templates, taxonomies and wallet compatibility was 31 July 2026 [Directive (EU) 2025/25, Art. 24(2)]. Searches through 4 September found no resulting act in the Official Journal. The site will replace that statement as soon as an act is located.
National transposition
The EUR-Lex notification record shows 14 measures under Czechia and none under the other 26 Member States [EUR-Lex transposition notifications for Dir. 2025/25Official data]. A notification is not proof that the Directive has been fully transposed. Country pages remain Unknown until the national provisions have been read against the Directive.
European Business Wallets
The Council adopted its negotiating position on 9 June 2026. It says the proposed wallet could support delegation of legal authority, while not affecting powers of attorney or legal mandates already governed by national or Union law [Council position on European Business Wallets (PROPOSAL)Proposal].
The Parliament procedure remains at “Awaiting committee decision” [OEIL 2025/0358(COD) (PROPOSAL)Proposal]. There is no final regulation.
EU Inc.
COM(2026) 321 proposes an optional EU Inc. company form. Proposed Articles 30–32 would apply the EU Company Certificate, digital EU power of attorney and reduced-formality safeguards to that company form [COM(2026) 321 — EU Inc. proposal, Arts. 30–32Proposal].
This does not alter the Directive's existing timetable. See the EU Inc. tracker.
EUDI Wallet technical baseline
The EUDI Architecture and Reference Framework page lists version 3.0.0, dated 21 July 2026 [EUDI Wallet ARFTechnical draft]. The ARF is technical documentation and must not be presented as legislation.
What companies should do this month
- Identify cross-border company procedures that currently require powers of attorney, apostilles or translations.
- Clean the business-register data that will feed the EU Company Certificate.
- Record authority as scope, representative, representation type, validity and revocation state.
- Keep adopted duties separate from Business Wallet and EU Inc. proposals.
- Follow the deadline explorer and the relevant role guide.
Nothing in the Directive requires a company to buy a wallet or power-of-attorney product now.
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.
- Official data EUR-Lex, National transposition measures communicated by the Member States concerning Directive (EU) 2025/25 (CELEX 32025L0025). https://eur-lex.europa.eu/legal-content/EN/NIM/?uri=CELEX:32025L0025. Retrieved 2026-09-03.
- Proposal European Parliament Legislative Observatory (OEIL), procedure 2025/0358(COD) — Establishment of European Business Wallets (COM(2025)0838). https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2025/0358(COD). Retrieved 2026-09-04.
- Proposal Council of the European Union, European business wallets: Council adopts negotiating position. https://www.consilium.europa.eu/en/press/press-releases/2026/06/09/european-business-wallets-council-adopts-negotiating-position/. Retrieved 2026-09-04.
- Proposal Proposal for a Regulation of the European Parliament and of the Council on the 28th Regime Corporate Legal Framework — EU Inc.. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52026PC0321. Retrieved 2026-09-04.
- Technical draft European Digital Identity Wallet — Architecture and Reference Framework (ARF). https://eudi.dev/. Retrieved 2026-09-04.
Cite this page
Rob Prime, “State of the EU digital power of attorney: September 2026”, EUDIPOA, published 2026-09-04, last verified against its sources 2026-09-04, https://eudipoa.com/updates/2026-09-state-of-eu-digital-poa.
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 — September report published from the official legal, proposal and technical records.