On June 29, 2026, Liudmyla Rabchynska — Ukraine's former Deputy Minister for Digital Transformation, architect of the Diia platform, and since February 2026 Director of Global Regulatory and Government Affairs at IDnow — delivered a pointed warning to European policymakers: the EU Digital Identity Wallet is being built for governments, not for people.
"I see the risk that governments of member states continue to treat it like another infrastructural product," Rabchynska told Biometric Update. The wallet, she argued, must instead be "an instrument that should relieve the lives of citizens." Assuming that citizens will adopt it simply because it appears in an app store, she said, would be "a big mistake."
She would know. Under her leadership, Ukraine's Diia platform reached 23 million active users — roughly 81 percent of the country's adult population — by making government invisible. Not digital. Invisible.
A Platform Built to Disappear
Diia's design philosophy was not to port paper bureaucracy onto a screen. It was to eliminate the experience of bureaucracy entirely. The team drew inspiration from Amazon's one-click checkout: the fastest transaction is the one you barely notice making. The goal was to make state interaction "super invisible and super quick," in Rabchynska's framing.
The results are documented by Ukraine's own Digital State portal: over 70 digital public services and 33 digital documents are now accessible through a single smartphone app, including a world's first AI assistant on a government portal. During Russia's full-scale invasion, Diia was repurposed within weeks to register internally displaced persons, process financial assistance claims, and document property damage — all without rebuilding from scratch. That agility came directly from its original design discipline: a citizen-centred architecture is also a resilient one.
Rabchynska's move to IDnow — a Munich-based identity verification company operating at the centre of the EU's eIDAS 2.0 implementation market — is itself significant. Her appointment in February 2026 brought hands-on government platform experience into a private sector role focused precisely on helping European businesses and regulators navigate the EUDI Wallet ecosystem.
The Steelman Case for Infrastructure-First
To be fair to Brussels, the EU's task is categorically harder than Ukraine's was. Diia operates within a single jurisdiction with one government, one legal system, and the political authority to mandate digital document recognition across the country. The European Union must build a wallet that works seamlessly across 27 member states, multiple languages, divergent legacy identity systems, and strict GDPR-governed data minimisation requirements.
The eIDAS 2.0 framework — formally Regulation (EU) 2024/1183 — represents a genuine attempt to standardise this complexity. Mandating open-source reference implementations, requiring the Architecture and Reference Framework as a common technical baseline, and running large-scale pilots involving over 550 organisations across 26 member states is not irrational. Interoperability standards are infrastructure, and in a multi-sovereign environment they must come first. The EU Commission's commitment is clear: every member state must make a certified wallet available to citizens, residents, and businesses by the end of 2026.
Where the Approach Falls Short
The problem is not the existence of technical standards. It is what happens when technical standards become the end goal rather than the enabler.
A survey of experts by Biometric Update in December 2025 found a growing consensus that "availability" would not mean the same thing everywhere by the end of 2026. Bulgaria had not yet passed the enabling legislation needed to build a wallet. The Netherlands signalled it would likely miss the deadline. Projections suggested between 30 and 50 national wallets across the bloc by December 2026 — most of them not yet cross-border interoperable, defeating a central purpose of the initiative.
The GSMA added a structural dimension in May 2026, warning that unresolved business and compliance challenges risk stalling private-sector investment in the ecosystem. Service providers face "significant investment costs tied to trust infrastructure, cybersecurity, and eIDAS2 compliance" with no clear business model to recoup them. Without that private-sector integration, citizens would find few services to actually use their wallets for — and without use cases, voluntary adoption stalls. You can mandate that a wallet exist. You cannot mandate that anyone finds it useful.
The Voluntary Adoption Problem
Diia's rapid growth was not accidental or purely organic. The Ukrainian parliament legally equated Diia documents with their physical equivalents, creating immediate real-world utility: a driver who once needed a laminated licence could use the app at a police checkpoint instead. The value proposition was tangible from day one, embedded in law and in everyday life.
The EUDI Wallet is explicitly voluntary for users. This changes the design calculus entirely. UX experts from 13 member states, working within the EU's own pilot workshops, identified three core adoption challenges: building citizen trust in the ecosystem, raising awareness of available credentials, and smoothing the onboarding experience. None of these are infrastructure problems. All of them require design thinking — the kind of thinking Rabchynska applied at Diia and is now urging upon European regulators from the outside.
What the EU Should Borrow From Kyiv
The single most transferable insight from Diia is that the correct design question is not "what documents can we make digital?" but "what experiences can we make disappear?" Those are different briefs that produce radically different products.
A digital driver's licence stored in a wallet that still requires a multi-step verification flow at a car rental counter has digitised the bureaucracy without eliminating it. A Diia-style approach asks: what does the citizen need to prove, what is the minimum interaction required to prove it, and how do we reduce that interaction to near-zero? The answer shapes everything from button placement to partnership terms with private verifiers.
The EU has portions of this right. eIDAS 2.0's selective disclosure requirements — allowing users to prove they are over 18 without revealing their birthdate — are sound privacy policy and good UX simultaneously. The Eurasia Foundation is now funding a project to translate Diia's architecture into an internationally reusable model, with Germany's BMZ and GIZ involved, signalling that governments beyond Ukraine are paying attention.
The gap is in political culture at the member state level, where procurement timelines, interoperability checklists, and certification requirements crowd out the basic question: will anyone actually want to use what we are building?
Rabchynska's career arc — from Ukraine's most-used government platform to advising European regulators from a private identity company — positions her June 2026 warning as more than advocacy. It is a case study in what citizen-centric digital governance looks like in practice, measured in users rather than implementations. Europe has until the end of 2026 to release wallets. It has considerably less time to decide whether those wallets are built for checkboxes or for people.