Centering Migrants’ Perspectives in the EUDI Wallet Debate in Germany

Executive summary

This report explores the intersection of migration and digital identity in Germany by examining the lived experiences of migrants, focusing on their identification needs and the challenges they face in navigating Germany’s complex bureaucratic system.

Ongoing public and private sector discussions regarding the potential and challenges of implementing wallet-based digital identity solutions complement migrants’ perspectives. This report contributes to the current EUDI Wallet debate by centering migrants’ perspectives and offers insights on how to bridge the gap between digitalization and the systemic inequalities in Germany’s migration system.

The report analyzes crosscutting challenges experienced by migrants and the identification-related barriers they face when accessing essential services like housing, healthcare, social benefits, education, integration programs, financial services, and mobility. These challenges arise from a bureaucratic system that is both rigid and fragmented, where identification requirements vary across sectors and administrative bodies, often leading to arbitrary and inconsistent experiences.

To better understand the role of identification in migrants’ lives, the report maps key identification touchpoints throughout the migration journey before coming to Germany, on arrival, and while living in Germany, and tracks the identification documents migrants need throughout these processes. Additionally, the report relays the case for digitalization from the perspective of migrants, while also highlighting the challenges for practitioners in the digital identity sector and the German government regarding the design and implementation of a digital identity wallet.

A central component of this study is an assessment of the potential role of the European Digital Identity (EUDI) Wallet in addressing these identification challenges. Hopes are that, if effectively implemented, the EUDI Wallet could provide a secure, user-friendly, and widely accepted digital identity tool, improving efficiency and restoring trust in government digital services across the EU. This research on Germany reveals a lack of strategic vision and political commitment to previous digital identity projects. Despite digital identity being a core pillar of the country’s broader digital transformation strategy, the Wallet has been at risk of becoming just another initiative in a fragmented landscape of solutions until now. In light of the 2025 federal elections that occurred during this research, the question arises as to whether previous implementation gaps can be overcome under the leadership of the new Ministry for Digital Transformation and Government Modernisation (Bundesministerium für Digitales und Staatsmodernisierung [BMDS]).

Interviews with key stakeholders in the digital identity sector highlight an absence of coherent policies, coordination gaps between government entities, and a lack of engagement with the specific identification needs of migrants. While the German implementation of eIDAS 2.0 has been accompanied by a participatory architecture and consultation process, this research shows that migrants’ voices and (potential) user perspectives more broadly are underrepresented in this context. Significant hurdles remain to inclusive identity innovation, including issues of interoperability, accessibility, and institutional resistance to change. Without careful
design and implementation, the risk of further entrenching exclusion and administrative bottlenecks remains high.

Finally, this report concludes by providing migrant-centered recommendations for the German government, digital identity practitioners, and civil society stakeholders for the design and implementation of digital identity tools and services, and recommendations for resolving the key challenges that migrants experience in Germany regarding gaining access
to public and private services.

Introduction

Identity documents organize people’s lives. From ID cards to passports, driving licenses, health insurance cards, employee IDs, student, library, sports and other membership cards, every day people use a variety of identity documents to prove their identity as citizens, travelers, employees, owners, drivers, customers, and so on. 1

Typically, there is more than one way to interact with these identification touchpoints, especially as the digitalization of identification practices keeps evolving. Government services are increasingly available online. Loyalty schemes use QR codes. Fingerprints and faces can be scanned for access control, payment and other mobile applications offer alternatives to physical credit cards and public transport tickets.

This report takes such identification touchpoints and the processes in which they are embedded as analytical entry points for understanding a country’s identity ecosystem and people’s experiences around matters of identification. 2 Specifically, this report explores the identification needs of migrants in Germany and how existing and emerging identification practices shape their everyday lives.

Digitalization in this context is a double-edged sword. 3 On one hand, digital identity policies, tools, and procedures promise to simplify processes, make services more easily accessible to more people, and increase efficiency, and thus the reliability and trustworthiness, of both the public and private sector. In Germany, a country often ridiculed for its fax-obsessed bureaucracy, there is almost universal agreement that (only) digitalization can change things for the better. On the other hand, new identification practices risk creating new inequalities and dynamics of exclusion or deepen existing patterns of marginalization, often to the detriment of those who find themselves already in a more vulnerable position. In this respect, the more than 14 million migrants in Germany 4 represent an important group to take into consideration when talking about the possible consequences that technological change could initiate.

Despite its more than a century-old history of labor and forced migration, 5 Germany only began to see itself as an immigration country in the early 2000s. Prior to this, migration was often framed as a temporary phenomenon. The longstanding “guest worker” (Gastarbeiter) narrative implied that migrant workers would eventually return to their countries of origin. This perspective has shaped decades of policy and legislation that have largely excluded migrants from full participation in social, political, and economic life. At the same time, migrants have been included in centralized data collection efforts from which people born with German citizenship are excluded, as there is no other centralized database comparable to the Central Register of Foreigners (Ausländerzentralregister [AZR]) in Germany. 6

In late 2023, German Chancellor Olaf Scholz declared: “We have now introduced stricter controls on our borders with neighboring countries, as we have just informed Brussels. And we want to reduce the incentives for remaining here irregularly. … We must finally deport on a large scale those who have no right to stay in Germany.” 7 This statement marked a stark contrast to the decision of previous Chancellor Angela Merkel during the 2015 “long summer of migration,” 8 when she suspended the Dublin Protocol to allow asylum seekers to cross the border into Germany and famously reassured the German public with the words “Wir schaffen das [We can do it].” 9

Although Germany’s much-discussed Willkommenskultur (“welcome culture”) has always been far from reflecting the lived realities of the country’s migration system, 10 Germany has undergone a fundamental political shift in recent years. In early 2025, Germany’s conservative Christian Democrats accepted that they would vote with the far-right Alternative for Germany (AfD) in their parliamentary proposal for a closed-borders policy agenda, reflecting a wider European shift towards increasingly restrictive border, migration, and asylum policies.

Today, Germany’s commitment to Schengen and the right to asylum is facing increasing political and public scrutiny. Anti-immigrant sentiment is gaining traction, as evidenced by the fact that the AfD included the concept of “remigration” in its election program for the 2025 federal elections, 11 and by the party winning 20.8% of the vote. 12

Against this backdrop, this report raises the question of the extent to which Germany has been and will be able to use technological innovation to (re-) shape its identity ecosystem in a way that fully embraces the diverse needs and life experiences of all the people living in the country. Or, in the words of the overarching project to which this report contributes: How can identity innovation be inclusive? 13 To answer this question, this report takes stock of Germany’s identity ecosystem and its current (re-)configuration in light of a new digital identity tool: the EUDI Wallet. In doing so, this report foregrounds the experiences of migrants from the Global South in Germany: how they move through different identification touchpoints, what their identification needs are, and what challenges they face in accessing public and private services. Focusing on migrants from the Global South centers the experience of those who are often most excluded from consultation processes, marginalized by systems, and face additional bureaucratic hurdles in their access to rights and services.

The EUDI Wallet is a type of mobile application that, according to the eIDAS 2.0 regulation, 14 all EU Member States must make available to their citizens, residents, and businesses within the next two years. Each Member State is required to provide at least one EUDI Wallet, either by developing their own or by certifying one or more EUDI Wallet applications. To ensure interoperability, all EUDI Wallet iterations are to be based on a common set of standards, technical specifications, guidelines, and best practices. If all goes according to plan, by 2027 all EU citizens and residents will be able to download an EUDI Wallet to their smartphone and use it to identify themselves and access public and private online services anywhere in the EU. Users will then be able to add, store, and present credentials 15 via their EUDI Wallet when, for example, opening a bank account online or applying for government benefits.

It remains to be seen how the EU’s overarching vision for “a secure European e-identity” 16 will inform concrete technological and design choices for the EUDI Wallet across Member States. The EUDI Wallet, its various features, and iterations are currently being tested in real-world scenarios across different EU sectors and markets. More than 250 private and public stakeholders are involved in these EU large-scale pilots. However, many aspects of this mega-project are still under development. This is particularly the case in Germany, where the government-backed EUDI Wallet (hereafter the German National Wallet) is being developed through a participatory architecture and consultation process.
This is both a challenge and an opportunity for this report. On one hand, this research discusses issues that have not yet been fully explored and, in this sense, can only present a snapshot of this development process. On the other hand, it is precisely because the German National Wallet is still under development that the questions and issues raised here can contribute to the national discussion on this topic, from which we hope that lessons can be drawn beyond the German context.

Compared to other digital identity paradigms, wallet-based models are generally grouped under the label “user-centric” “decentralized identity,” 17 enabling users to “control” when, how, and with whom they share personal information during digital interactions. 18 Many smartphone users already have private sector wallet applications on their phones, such as the Apple Wallet. Other governments have introduced wallet solutions into their country’s identity ecosystem, such as Ukraine’s Diia app, and international organizations like UNHCR and WFP are adapting decentralized identity management components for humanitarian aid purposes. 19 In this sense, eIDAS 2.0 and the EUDI Wallet reflect a broader global trend—but with the added challenge that each EU Member State has its own identity ecosystem that, in order to provide and integrate the EUDI Wallet, has to undergo a transformation that speaks to each country’s specific infrastructure and dynamics, while also speaking to and aligning with the EU’s vision of an EU-wide interoperable digital identity landscape, ultimately contributing to the EU becoming “digitally sovereign in an interconnected world.” 20

Just as the EUDI Wallet is “necessarily built with an embedded set of values that affect outcomes,” 21 each country has a legacy of national systems and structures that reflects certain norms and priorities and how they have evolved over time. As such, the emerging EUDI Wallet landscape both represents and shapes contemporary understandings of (digital) citizenship and what social, political, and economic transactions and activities might look like in the future, both within and across Member States. But this emerging landscape does not exist in a vacuum and is itself influenced and constrained by national and regional factors. It is from this perspective that we inquire into wallet technology’s many promises for individual users, bureaucrats, and businesses—promises of digital sovereignty, interoperability, efficiency, convenience, comfort, user empowerment, and privacy protection. Can the EUDI Wallet deliver on these powerful promises? Does the emergence of these new digital identity tools have the potential to redress existing power imbalances and inequalities? And what can we learn from participant-led research about inclusive thinking around innovation?

In Germany, the EUDI Wallet is another step in a 15-year process of digitalizing the country’s identity ecosystem. It will build on Germany’s existing eID infrastructure. In 2010, Germany introduced national ID cards (Personalausweis) with an electronic identity (eID) function for German citizens aged 16 years and over. The electronic residence permit (elektronischer Aufenthaltstitel [eAT]) for non-EU and non-EEA nationals, introduced in 2011, also has an eID function, as does the eID card for EU and EEA citizens that was introduced in 2021. However, only 22% of people living in Germany use the existing eID infrastructure. A recent survey found that about one-fifth of respondents thought eID was too complicated and saw no benefit in actively using it, and 30% of respondents were not aware of any potential use cases for the eID function. 22

Given this low user acceptance, the EUDI Wallet is emerging as a beacon of hope in the German public debate on digital identity. However, amid the growing enthusiasm for this new application, important issues remain unexplored. The low usage rate of the German eID is well known and has been thoroughly documented. 23 At the same time, there is a lack of specific information on how migrants experience the German identity ecosystem and eID, suggesting a need for more nuanced engagement with how their perspectives may differ or overlap with the experiences of people with German citizenship. As the EUDI Wallet builds on existing eID infrastructure, migrants’ experiences of the German identity ecosystem in its current state are an important starting point for understanding how the EUDI Wallet might affect different population groups. Will everyone benefit equally from this innovation?

That said, experiences of study participants show that there are currently much more fundamental issues of accessibility at stake in Germany—issues that are unlikely to be addressed by the EUDI Wallet unless its introduction is embedded in broader reforms for a more just and inclusive society. Findings highlight the lack of very basic things, such as the availability of public information in multiple languages. While this report identifies areas of improvement, the range of accessibility issues also highlights the danger of pinning hopes on a technological change that is unlikely to deliver unless major structural changes are also made.

By placing the lived experiences of migrants at the center of the German debate on the EUDI Wallet, this report sheds light on the ways this digital identity tool intersects with broader struggles for rights, mobility, and belonging in an increasingly restrictive border- and migration-control environment, both in Germany and across Europe.

Methodology

This report provides a comprehensive analysis of Germany’s identity ecosystem and the national potential for digitalization by incorporating the perspectives of those responsible for its design, development, and maintenance, as well as those who are directly affected by them, specifically migrants.

This dual approach documents not only the structural challenges of Germany’s identity ecosystem but also its human impact. The study explores the factors driving the digitalization of identity documents and systems and examines how they function in practice, rather than merely in theory. As such, the research draws on insights from qualitative interviews with both migrants and “experts.” 24

Given Germany’s federal system, procedures and practices can differ from one state to another. While most migrant interviews took place in Berlin, one was conducted with a participant based in Hamburg. Moreover, participants interviewed in Berlin had diverse journeys; some resided in other states before arriving in the capital. Additionally, the writers completed a thorough process of research to compare information provided by participants in Berlin with the situation in other states. As such, while the majority of participants are based in Berlin, findings pertain to the broader Germany identity ecosystem.

Participants were selected based on their migration experience using a purposive sampling method to capture a wide range of migration statuses and journeys. Most research participants have had more than one legal status during their residence in Germany; the experiences reflected in this study cover interviewees’ current and previous legal statuses and experiences. All participants have “Global South” citizenships; they are originally from Syria, Palestine, Jordan, Lebanon, Afghanistan, Ukraine, Mexico, Peru, Nigeria, Uganda, and the Gambia. To protect participants’ identities, names and national origins are not used. Countries of origin are only mentioned if essential for the information provided. Participants are referred to as “Current legal status_year of arrival to Germany.” A list of migrant interviewees can be found in Appendix 1.

The qualitative interviews aimed to understand migrants’ identification needs at different stages of their migration journey, as well as migrants’ current experiences with and expectations of digitalization. The process consisted of in-depth narrative interviews in which participants could freely narrate their experiences, highlighting the issues important to them; specific follow-up questions were asked as needed. These in-depth interviews provide the opportunity to examine policies and procedures from below, assessing the impact on the lives of those who are often excluded from the debate. 25 Sixteen qualitative in-depth interviews were conducted with migrants of different nationalities and various legal residence conditions in Germany. Conversations took place in German, English, Arabic, and Spanish; they were recorded, transcribed, and translated by the researchers.

Migrants’ experiences and perspectives are complemented with interviews with government, (fin-)tech, and other institutional representatives involved in current debates and initiatives around wallet technology and its implementation. The authors conducted ten expert interviews, two of which were joint interviews, with twelve public and private sector representatives. Interviewees were selected on the basis of their professional experience in the field of public sector digitalization and the development and implementation of digital identity wallets in Germany. The expert interviews aimed at inquiring into and mapping out various dimensions of the German identity ecosystem and its ongoing transformation. They followed a semi-structured format, consisting of guiding questions while leaving space for a free-flowing conversation. With the exception of one, all expert interviews were conducted in German, transcribed, and subsequently translated. Interviewees’ institutional affiliation is mentioned if essential for the information provided. Participants are referred to by the sector in which they work and an assigned number, based on the order in which interviews were conducted (e.g., Science & Research_3).

The experts interviewed for this report live all over Germany. However, during the course of this research, Berlin emerged as an important focal point for networking and knowledge exchange on digital identity. Selection and recruitment of participants, as well as the overall thinking behind this report, was informed by events in Berlin—their agendas, speaker line-ups, and the conversations they facilitated—such as the European Identity and Cloud conference, the Smart Country Convention, the Digital Society Conference, and the second Funke EUDI Wallet Prototypes conference.

Background

Migration in Germany: Identification practices, legal statuses, and identity documents

The German Federal Statistical Office reports that 24.3% of Germany’s population has a history of immigration. 26 This figure includes those who have immigrated to the country since 1950, as well as their direct descendants. Germany’s history as a country of immigration can be traced back to the country’s colonial times, with rates of labor migration peaking in the 1950s and 1960s. Following West Germany’s industrial boom, local labor shortages were addressed by recruiting “guest workers” (Gastarbeiter) from several countries, including Italy and Turkey. 27 Between the 1970s and 1990s, both West and East Germany also received forced migrants, including Vietnamese, Polish, Turkish, Kurdish, Lebanese, Palestinian, and Yugoslav people fleeing conflict or persecution. 28

Previous political discourse and policies in Germany did not acknowledge this rich history of migration; instead, they considered both labor and forced migration to be temporary. It was not until the 2000s that immigration reforms were enacted, marking a paradigm shift towards recognizing the principle of jus soli (right of soil) in the acquisition of citizenship, implementing “integration measures,” and gradually liberalizing migration policies relating to skilled labor. 29 In 2015, Germany announced that it would open its borders to people seeking asylum; that year alone, 890,000 asylum seekers arrived in Germany. 30

Between 2015 and 2019, throughout a phase of “legislative hyperactivity,” tens of amendment laws were put in place in an attempt to manage the resulting political and administrative crisis. 31 Most notably, these amendments restricted asylum seekers’ access to refugee legal status and to family reunification, and limited their freedom of movement. Since December 2021, another series of laws and amendments have come into effect, widening migration possibilities for skilled workers, offering further possibilities for those holding a toleration status (Duldung), and facilitating access to citizenship. The Act to Modernize Nationality Law (Gesetz zur Modernisierung des Staatsangehörigkeitsrechts) allowed for dual nationality and sped up the naturalization process; previously, Germany was known to have one of the strictest legislations in terms of citizenship in Europe.

These recent reforms should not be taken as an indication of a general openness to migration in Germany. On the contrary, for several years public discourse has been marked by increasingly strident calls for border controls and deportations, in line with a wider European shift toward increasingly restrictive migration and asylum policies, such as the EU Pact on Migration and Asylum. 32 Another widely discussed example in this regard is the so-called “payment card” (Bezahlkarte) for asylum seekers, introduced through an amendment to the Asylum Seekers Benefits Act (Asylbewerberleistungsgesetz [AsylbLG]) in 2024. 33

Non-EU/EEA migrants have different titles, rights, and obligations in Germany depending on the purpose of their residence, including: work, education, and family reunification (to join a German national, an EU citizen, or a third-country national). Moreover, forced migrants who apply for asylum in Germany may be granted refugee protection, asylum, or subsidiary protection if their application is approved. If not, they might receive either a total rejection and compulsion to leave the country or a national ban on deportation (nationales Abschiebungsverbot). More information on these different protection-related legal titles can be found in Appendix 2. Correspondingly, there are several types of official identity documents in Germany for which migrants can apply. Appendix 3 gives an overview of identity documents for both people with German citizenship and people with a migration legal status.

The digitalization of German bureaucracy

Europe’s largest economy and export “powerhouse,” globally “known for vast factories and fine-tuned engineering,” 34 has long struggled to bring its public sector into the digital age. Germany’s reputation for efficiency clashes with headlines about its paper-based bureaucracy and continued reliance on the fax machine, 35 a decades-old “love affair” of both the public and private sector. 36 According to the 2024 eGovernment MONITOR,three out of ten people living in Germany prefer to interact with administrative authorities in analogue rather than digital form—a digital gap of 31%. 37 And, according to a 2024 Special Eurobarometer survey, only 70% of the German population said that the digitalization of daily public and private services makes their lives easier, a figure below the EU average of 73%. 38 Data from the EU Digital Economy and Society Index suggests one reason why this might be the case: Germany receives below-average scores on almost all indicators used to measure the digitalization of public administration. For instance, the score for online provision of key public services (measured by the share of administrative steps that can be completed online for major life events) is 78.94, compared to the EU average of 82.32. Here, Germany ranks 17th of 27 EU countries. 39

Germany’s digital lag is attributed to several factors. The country’s multi-level system of federal and regional authorities results in highly complex legislative and administrative processes for decision-making and implementation. Public administration lacks the necessary digital competencies and skills and is therefore overly reliant on external IT expertise. Germans are said to have a deep-rooted mistrust of technology, which is reflected in the country’s strict privacy and data protection laws. 40 For instance, a 2023 public opinion survey about facial recognition and other digital technologies found that 30% of respondents were strong “digital doubters.” These individuals either strongly or somewhat oppose the use of digital technology and are not convinced of its effectiveness or usefulness, including the perceived benefits of more convenience, efficiency, and security. 41

In discussions of the relationship between Germany’s lack of digital prowess and public concerns about data privacy, the country’s history of totalitarianism usually takes center stage. Public debates about privacy and data protection often refer to the Nazi regime, as in the case of the mass protests against the 1983 Population Census Act (Volkszählungsgesetz), 42 which was eventually challenged before the German Federal Constitutional Court (Bundesverfassungsgericht). 43 The Federal Constitutional Court’s census verdict (Volkszählungsurteil) introduced the concept of informational self-determination into German jurisprudence: the constitutional anchor for data protection rights in Germany, developed in close connection to the idea that every person should have the right to develop a free and self-determined personality. 44 In 2008, the general personality right was also the reference point for the constitutional court’s ruling against government surveillance of personal computers, establishing the so-called “IT right.” 45

The basic rights and their precedence over all other laws are commonly understood as a reaction to the experience of National Socialism. 46 Similarly, Germany’s federal structure was written into the Basic Law as an additional institutional barrier against a too powerful, potentially abusive central government. 47 During the Cold War and since reunification, the East German surveillance state has served as a counter-example to emphasize the democratic foundations of the Federal Republic and is often invoked in public debates about the privacy implications of digital technologies. 48

However, viewing the origins of privacy, data, and information law in the Federal Republic solely through the lens of its Nazi past distracts from the fact that, in the 1970s and 1980s, West Germany was one of the most technologically advanced countries in the world. Privacy laws and the census boycott were a response to technological change and Germany’s pioneering use of computers and databases for the collection of personal information. 49 The Central Foreigners Register (Ausländerzentralregister [AZR]), “one of the first and largest migration databases of modern liberal states,” was among the first public administration databases that West Germany switched to electronic data processing. 50 Introduced in the 1950s, the AZR centralized the records gathered by local foreigners’ authorities (Ausländerbehörden) and made this knowledge accessible to various authorities at the federal, state (Länder), and local level. While the Federal Constitutional Court’s census verdict affirmed that data collection practices at the time lacked an inadequate legal foundation and needed further safeguards, the AZR nevertheless remained relatively free of regulatory constraints. Only in the 1990s was the volume, usage, and accessibility of the AZR database comprehensively regulated by law. 51 Today, the AZR stores detailed information on all persons without German citizenship who live or have lived in Germany (for at least three months; for work, education, travel, or humanitarian reasons), as well as people who have applied for a visa with German authorities (whether the application was successful or not). The AZR contains approximately 26 million records 52 accessible at varying levels to more than 16,000 authorities and agencies, including foreigners authorities, police and law enforcement agencies, intelligence services, job centers, youth welfare offices, and courts. 53 It is one of Germany’s biggest automated databases and, as the Federal Administration Office (Bundesverwaltungsamt) puts it, “the central information hub” for all migration and asylum matters. 54

First, the AZR raises questions about the extent to which all people in Germany benefit equally from the legal protections afforded to them in theory. 55 The census verdict established a series of safeguards for the right to informational self-determination, rendering principles such as purpose specification, proportionality, and data minimization legally binding. 56 By contrast, legal regulation and later reforms of the AZR have not led to restrictions, but rather to greater access to the database and its data. Back in 2020, authorities were already performing an average of around 260,000 data queries per day in the AZR. 57

Also, the AZR illustrates the Federal Republic’s pioneering role in digital, data-based migration control 58 and challenges the widespread view that Germans’ critical attitude towards technology, triggered by the country’s authoritarian past, best explains current grievances about the disheveled state of German bureaucracy. Indeed, the Federal Republic’s renowned commitment to privacy, data, and information laws originates from a time of technological experimentation and advancement. This commitment, however, has never been extended to fully encompass all people living in Germany. Instead, the increasing access to, and widening scope of, personal data stored in the AZR has further exacerbated the risk of data protection and privacy violations for migrants. While the EUDI Wallet models a different vision of digital identity management, it does not render the AZR or other existing centralized registers obsolete. In fact, the issuance of various credentials will be based on information held in public registers, some of which are centralized and some of which are not. As such, the AZR is also an important reminder that the EUDI Wallet, if successfully implemented, will coexist and overlap with other digital systems and tools designed for different purposes, each of which may (re)configure interactions around identification touchpoints in different ways.

Mapping identification touchpoints

Identification touchpoints—points of contact between the public and/or private sector and individuals before, during, and after their migration journey—occur when individuals (or their legal guardians) register for or renew identity documents, such as a passport, national ID card, or birth certificate, but also when they are required to provide these and other documents to verify their identity and prove that they “qualify” for access to particular services, benefits, and places.

Many identification touchpoints are relevant to anyone coming to and living in Germany, regardless of national origin, and bureaucratic complexities could generally be simplified by easier, fully digital access to public and private services. Nevertheless, the ways interactions around identification touchpoints are experienced may vary, and, conversely, digital services may offer specific advantages, such as multiple language options.

To assess whether and how the EUDI Wallet could improve migrants’ encounters with the German state and its identification practices, this report dives “into the dense jungle of German documentation, registration, and data management practices.” 59 The following sections trace multiple lines of movement: migrants’ journeys as they navigate life in Germany, the paper trails that almost inevitably follow and intertwine with their experiences, and Germany’s path towards implementing the eIDAS 2.0 regulation. We take stock of current challenges in the ongoing overhaul of Germany’s identity ecosystem and how they intersect, overlap, and at times compete with migration-specific needs and concerns. Against this backdrop, we critically discuss what we currently know about the EUDI Wallet and consider how the status quo described here might be affected by this new digital identity tool.

Germany has decided to follow a dual approach in implementing eIDAS 2.0. Besides the German National Wallet, it will also be possible for non-governmental entities to develop wallet solutions and get them certified as EUDI Wallets. 60 Many details around the German National Wallet and the ongoing transformation of the country’s identity ecosystem remain to be seen. However, certain basic design features and functions have already been revealed and demonstrated publicly, including the issuance of a core set of personal identification data from the German national ID card via an NFC-enabled smartphone. 61

That the EU’s vision for a new common approach to digital identity takes the form of the EUDI Wallet mirrors a global trend: Over the past decade, wallet technology has evolved from a niche innovation to a widely known feature of everyday finance and consumer transactions, providing virtual containers for digital payment cards, boarding passes, transport and event tickets, loyalty and rewards cards, as well as mobile keys unlocking cars, doors, and other access control points. At the same time, the EUDI Wallet is set to broaden the scope of wallet functions and their application, also integrating government-issued documents like ID cards, driving licenses, and other types of digital documents and certificates (e.g., educational and professional qualifications, disability pass, gym membership, library card) and ensuring their interoperable use across 27 countries. Based on international standards for verifiable data exchange, the EUDI Wallet represents one distinct iteration of a decentralized identity management model, a model often associated with the concept of self-sovereign identity (SSI). 62 While international observers and commentators predict that the influence of the EUDI Wallet could extend well beyond European borders by encouraging the adoption of digital identity wallet approaches geared towards alignment—and ultimately, interoperability—with the emerging EUDI ecosystem, 63 numerous new approaches, mechanisms, and standards are still being developed. Any entity looking to develop a digital identity wallet thus faces a number of design choices including but not limited to cryptography, distributed ledger, and blockchain technology, as there is by no means a single, globally dominant approach but various implementation pathways.

The powerful promise of decentralized identity management approaches is to give users control over their data, enabling them to decide what information to share and with whom. EUDI Wallet–based interactions would therefore look very different and could offer specific advantages over currently popular identity and access management strategies such as social login, where convenience usually comes at the cost of privacy and security. 64

An EUDI Wallet can hold multiple government-issued or other digital credentials, provided and guaranteed for by different “issuers.” This includes a core set of personal identification data, often referred to as “the PID,” functioning as the EUDI Wallet’s “basic identity.” 65 One of the key privacy-enhancing features of the EUDI Wallet is selective disclosure—the process of sharing only the personal information required for a transaction, while keeping all other data private. For instance, in a scenario where proof of age is required, an EUDI Wallet user can confirm that they are over 18 without having to share further personal information such as their first and last name or their date of birth. Using the EUDI Wallet, users will also be able to decline a request for information sharing if, for example, they do not agree with the specifics of a data request, and they can track all transactions via a dashboard. Meanwhile, for issuers and relying parties—government, private sector and non-government entities that issue digital credentials and/or request and verify them—data exchange based on cryptographically signed attributes promises to enable information sharing in a completely digitalized, tamper-proof, and cost-efficient manner. Businesses, public institutions, and other entities are thus promised improved efficiency and comfort from becoming stakeholders in the emerging EUDI ecosystem. 66

German eID infrastructure is considered to be very secure but complex and challenging to use, with termination rates for identification attempts via the federal eID application AusweisApp ranging between 44 and 47%. 67 Therefore, hopes are high that a more user-friendly and fully digital identification option would improve access to digital services, reinstating trust in the functioning of the German state. 68 However, implementing the EUDI Wallet is a EU-wide transformation process, requiring agreements on common standards and specifications at the technical level and at the governance level, coordinated action to ensure cross-border trust, and mutual recognition of different procedures, documents and certificates. Ultimately, the potential benefits of the EUDI Wallet increase and multiply with the number of use cases and ecosystem participants, making the success of the EUDI Wallet dependent on the trust, acceptance, and contribution of many and diverse people in each EU Member State.

In Germany, the Federal Ministry of the Interior and Community (Bundesministerium des Innern und für Heimat [BMI]) was initially in charge of the overall EUDI Wallet project and commissioned an interdisciplinary team from the Federal Agency for Breakthrough Innovations (Bundesagentur für Sprunginnovation [SPRIND]) and other institutions to develop the German National Wallet through a “transparent and participatory architecture and consultation process.” 69 This process is supposed to stimulate open exchange and synergies between experts from different backgrounds, involving relevant stakeholders as early as possible in discussions about data protection and privacy, security, trust frameworks, and interoperability, as well as user experience (UX) and user interface (UI) design. Since the project’s launch, various workshops and consultation formats have been held online and offline. A working group on the topic of “Ecosystem Governance and Operating Models” took place for several months, 70 and a series of exploratory end-user interviews were conducted and presented. 71 In addition, SPRIND funded the “FUNKE EUDI Wallet Prototype” innovation challenge for over 15 months, providing close to 4 million euros in total to selected wallet development teams across three stages. 72

However, when talking about future users of the German National Wallet, one question that is rarely at the center of these considerations is how and to what extent migrants from outside the EU will be able to benefit from it, particularly with regard to their interactions with immigration authorities and other gatekeepers of access to public and private services, infrastructure, and opportunities. As the following sections illustrate, in this regard, there is a lot of room for improvement in Germany. When we talk about tracing paper trails and how they intertwine with migrants’ journeys and experiences, we mean it literally. In particular, the digitalization of the German public sector has been lagging for years. The complexity of the country’s bureaucratic legacy is a well-known pain point for anyone living in Germany. This complexity is only exacerbated when systems, procedures, and those responsible for managing them encounter people whose documentary history does not exactly match existing rules and requirements, many of which predate the days of digital statehood.

The following pages map important identification touchpoints throughout the migration journey, both to establish them as points of reference and to illustrate the sheer number of requirements that must be met to participate in German society, as well as their many interdependencies. Such an overview is helpful in thinking about migrants’ interactions with the German identity ecosystem and possible future changes. But such an overview needs further contextualization, which requires a nuanced understanding of how migrants from different backgrounds and circumstances experience Germany’s identity ecosystem as it currently operates. Thus, it is key to listen to and prioritize the insights of real people who have to navigate this complexity.
Interactions at identification touchpoints can be arbitrary, though they are cloaked in a veneer of bureaucratic objectivity. Migrants might deal with street-level bureaucrats 73 who are willing to be flexible and helpful. Other times, migrants might experience discrimination or be subjected to undue scrutiny. At the same time, there are cross-cutting issues that point to wider patterns of exclusion and discrimination within the German state and society—patterns to which not all people are equally vulnerable. In particular, a person’s nationality, gender, socioeconomic background, and religion—and, in any given situation, how others will judge their name, their presence, and their words in the light of these categories—are likely to influence migrants’ experiences in Germany. Which structural issues related to identification can wallet technology realistically improve? Which issues might it complicate? Who will be most affected by such changes, or the lack thereof? If these questions remain unanswered, digital wallets risk becoming disconnected from practical needs and concerns of different, at times marginalized user groups, including migrants, as well as issuers, relying parties and other stakeholders in the emerging EUDI ecosystem.

Overview of potential identification touchpoints

Before coming to Germany

For individuals from outside EU/Schengen traveling to Germany whose country of origin does not have a visa waiver agreement with the EU for short-term travel or need to apply for visa for work or other purposes

1. Start visa application process.
   • Make an appointment at the embassy and prepare required documents. 74 Apart from the general eligibility requirements (proof of identity, proof of financial resources, no grounds for deportation), the information required depends on the type of visa for which the individual is applying (e.g., a work visa for qualified professionals comes with no German language requirements, a visa for vocational training requires at least level B1 German language skills). There are three broader categories of national visa (visas for employment, visas for study/training/education, visas for family reunification), each of which is further specified in different visa titles, plus the Schengen visa for short-term travel. For example, to obtain a qualified professional visa, an individual must, among other things, prove that they have the equivalent foreign academic or vocational qualification (or prove the comparability of their foreign qualification), have a concrete job offer in Germany or a valid employment contract, and, if over the age of 45, prove that they will earn an annual gross salary of at least €53,130 (as of 2025). 75
   • Submit visa application. Increasingly, it is possible to submit an online visa application via the Consular Services Portal. In this case, all submitted information and documents undergo a preliminary review. The applicant will receive information on which original documents they need to present at their in-person appointment. 76
2. Bring required original documents to the appointment and pay the application fee. Applicants over the age of 12 also need to submit biometric data (ten fingerprints and a facial image).
3. Plan journey to Germany. Provide passport number and other personal information to the transport company (e.g., airline).

For individuals from outside EU/Schengen whose country of origin has a visa waiver agreement with the EU

Visa-free entry is only possible for up to 90 days of short-term travel. Visa-free short-term visitors cannot pursue any economic activity. If a person wants to start working immediately after arriving in Germany, they will need to enter the country on a visa that allows them to do so.

1. Plan journey to Germany. Provide passport number and other personal information to the transport company (e.g., airline).
2. Apply for ETIAS travel authorization. The European Union’s Electronic Travel Information and Authorization System (ETIAS) is expected to be introduced by the end of 2026. Obtaining an ETIAS authorization will then become mandatory for travelers from visa-exempt third countries for short-term stays in the Schengen Area.

For individuals seeking asylum/humanitarian protection

There are only very limited opportunities to apply for resettlement. If an individual cannot obtain a visa or has no other authorized means of traveling to Germany, they will be forced to make this journey in an “irregular” manner.

Arriving in Germany: The first months

For individuals from outside the EU/Schengen with or without visa requirements

On arrival in Germany, pass through border control, where the person may be required to produce documents other than “just” their passport and travel authorization (visa title or ETIAS).

In the future, individuals will have to register in the EU’s Entry-Exit System (EES). This process involves the registration of biographical information, four fingerprints, and a facial image of all non-EU citizens crossing into EU territory, as well as date and place of the border crossing. 77

For individuals from outside EU/Schengen with a visa who intend to stay longer than the visa’s validity period

1. Prepare necessary documentation to apply for a residence permit and make an appointment with local immigration authorities (in Berlin: Landesamt für Einwanderung [LEA]). This may include, for example, applying for the recognition/evaluation of academic or other professional qualifications. The fee for issuing the residence permit is usually paid at the appointment by card. Cash payment is often not possible.
   If any of these documents have already been submitted during the visa application process, this does not automatically mean that they do not need to be resubmitted. Whether documents can be submitted digitally (e.g., as a PDF by email or uploaded via a web platform) depends on the local immigration authority.
2. If the application is submitted while the applicant’s visa is still valid, but cannot be processed in time, a Fiktionsbescheinigung (fictional certificate) will usually be issued. In this case, the applicants’ stay in Germany is extended until a decision is made on the application. 78 By law, the immigration authorities are expected to process an application within three months, otherwise the applicant can sue them (Untätigkeitsklage/action for failure to act). 79

People who entered Germany on a visa may have more time to make an appointment and apply for a residence permit than people who entered on a visa waiver, depending on how long the visa is valid. According to the LEA website, the application should be submitted no sooner than six weeks before the visa expires. 80 However, it may take longer than six weeks to process an application.

For individuals from outside EU/Schengen who entered on a visa waiver and want to stay in Germany longer than 90 days, for education, work, or other reasons

1. Make an appointment at least six weeks before the 90-day short-term travel period ends to apply for a residence permit at the local immigration authority and pay the application fee. In Berlin, this application is processed by the LEA.
2. In addition to the general eligibility requirements, the documents required throughout the application process vary depending on the specific residence permit the person is applying for. These generally include: a valid passport, a recent biometric photo, the current visa title (if required), proof of financial means (e.g., bank statement as proof of sufficient funds, proof of parents’ income, etc.), tenancy agreement and/or Meldebescheinigung/Anmeldung, proof of health insurance, educational certificates, proof of language skills (e.g., B1 German certificate) or the intended acquisition of language skills. The fee for issuing the residence permit is usually paid at the appointment by card. Cash payment is often not possible.

Whether documents can be submitted digitally (e.g., as a PDF by email or uploaded via a web platform) depends on the local immigration authority.

For people seeking asylum/humanitarian protection

1. On first contact with one of the German authorities responsible for registering people as asylum seekers (federal police, regional/local police, asylum center, BAMF or regional/local immigration authorities), individuals undergo an identification procedure. If they are over the age of six, their fingerprints are taken. These data are transmitted to the AZR). After this first step, the individual receives the Ankunftsnachweis (“proof of arrival”), which acts as a provisional residence permit.
2. Once a person has formally applied for asylum, they receive the Aufenthaltsgestattung. This acts as a provisional residence document, valid until a decision has been made on the asylum application, and allows them to receive social benefits under the AsylbLG. The Aufenthaltsgestattung has to be renewed regularly until a decision has been made on the application. It is issued for up to six months while a person is living in an asylum accommodation and for up to twelve months afterwards.
   In order to apply for asylum, individuals need to provide immigration authorities with various documents to “make their case.” If they do not have certain documents with them, such as their passport, this is likely to delay the overall process and could potentially also have other negative consequences. 81
3. Participate in “integration measure” (e.g., German classes), if eligible.
4. Get access to financial services. People seeking asylum usually do not qualify for a “regular” bank account, only for a so-called Basiskonto (Basic Account). 82 To apply for a Basiskonto, individuals must provide a valid proof of identity and fill out an application form. Although the Bezahlkarte was initially conceived as a means of promoting financial inclusion for asylum seekers and reducing bureaucratic workload, 83 it has since evolved into a tool for restricting their financial behavior.

For anyone coming to Germany for a shorter or longer period of time

• Finding a place to live and register an address with the Citizens’ Office (getting an Anmeldung/Meldebescheinigung). To apply as a tenant, landlords will usually ask for the three most recent payslips, a Mietschuldenfreiheitsbescheinigung (proof that the applicant has no rental debts, signed by the previous landlord), a Schufa credit rating, a copy of the Personalausweis, eAT or passport, and a proof of address showing that the person has lived at the address given on the Mietschuldenfreiheitsbescheinigung. The Anmeldung/Meldebescheinigung is an essential document required for many other processes.
• Getting a SIM card. As of 2017, SIM cards must be registered and the SIM card holder must undergo an identification process, either in person or via the German eID infrastructure, VideoIdent or PostIdent. Either way, this process requires a valid identity document, such as the Personalausweis, an eAT or a passport, sometimes in combination with an Anmeldung/Meldebescheinigung. Which documents are accepted also depends on which identification processes are offered at the point of sale.
• Opening a bank account. The procedure depends on the bank and the type of account. In general, individuals must undergo an identification procedure, either in person, via eID, VideoIdent, or PostIdent. Which documents are accepted also depends on the identification procedure. Generally, applicants will be required to provide proof of residence in Germany and information on their income, which may include the German tax identification number or, for students, university enrollment certificate. Non-German citizens will also be asked to provide information about their immigration status/residence permit. 84
• Get (health) insurance.

Living in Germany

For individuals from outside EU/Schengen who entered Germany with or without a visa and have applied for a residence permit

• Apply for residence permit while visa is valid (see above). Make an appointment to collect residence permit once it has been granted. The residence permit is usually issued as an eAT in cheque card format. In some cases, it is still issued as a sticker that is glued into the passport. Additional provisions (e.g., relating to employment) are usually recorded on an additional fold-out sheet of paper (Zusatzblatt). Both the eAT/sticker and the Zusatzblatt refer to each other. Depending on the expiry date of the initial visa, the residence permit may be issued more than a year after first arriving in Germany.

For people who have applied for asylum/humanitarian protection

• In 2024, the “average” asylum procedure lasted around eight months. While their asylum application is being processed, all applicants must live in an official asylum accommodation for some time. This time period can vary considerably, with a general maximum of 18 months. Families are supposed to leave the accommodation after a maximum of six months, while others must stay for longer than 18 months. During their time in the accommodation, individuals are subject to Residenzpflicht—applicants cannot leave their assigned area of residence without requesting permission to do so, thus suffering from a drastic restriction of their mobility rights. The Ankunftsnachweis/Aufenthaltsgestattung indicates whether a person is subject to the Residenzpflicht. Once a person has left the accommodation, they are generally no longer subject to the Residenzpflicht (if they have been in Germany for at least three months), meaning that they are still required to live in the area to which they have been allocated (Wohnsitzauflage), but can visit other places in Germany without having to ask for permission. If they want to live somewhere else, for example to be reunited with family members, they must apply for relocation.
• Although theoretically possible (after three months at the earliest), it is not very common for applicants for protection to apply for a work permit and enter the labor market before they have been granted asylum. As soon as a person has been granted asylum, they must register with the Jobcenter and take part in “integration measures,” if they have not already been doing so.
• Only after 36 months are asylum applicants eligible for “regular” social welfare benefits and health insurance. Until then, they are granted social benefits under the Asylum Seeker Benefits Act.

For anyone living in Germany for a longer period of time

• Interact with federal/local authorities on a variety of issues (e.g., converting one’s driver’s license, applying for child benefits, etc.). People who have applied for asylum (but have not been granted a residence permit yet) are only entitled to social benefits under the Asylum Seeker Benefits Act.
• In Berlin, in particular, many people don’t find long-term accommodation straight away and have to keep moving (each time going through the application process and, if successful, registering their new address with the Citizens’ Office).

Identification documents: What are they and what do they mean?

Based on interviewees’ accounts, there is a multitude of government-issued and non-government-issued documents that migrants bring along from their home country or receive from institutions in Germany and/or a transit third-country that may indicate their identity. Each document relates to multiple identification touchpoints. Individuals may need to interact with authorities (in Germany or elsewhere) to obtain/renew these documents. Access to a particular service/benefit may depend on one or several of these papers. For example, registering an apartment in Berlin requires a valid identity document, a move-in confirmation from the landlord and, depending on the individual case, several other documents. All documents that interviewees mentioned are listed in Appendix 4.

Migrants who came to Germany through a visa often bring the same documents that they provided to the German embassy upon applying for the visa. They anticipate the possibility of being asked for these documents again at the border and expect to submit them partly or fully when applying for a residence permit.

For some participants who sought asylum in Germany, the more identification documents they bring with them from their country and submit to German authorities, the better they can prove that they fit the asylum criteria: A passport proves their identity and country of origin. A military service certificate might prove that they did not do military service and hence did not actively participate in combat.

“When I came to Germany, it was important for me to provide the ID, passport, military service certificate, and anything that could be helpful for my asylum application. Providing all the documents I got with me from Syria was important especially at a time when I could have been granted subsidiary protection instead of asylum.”
—Citizenship_2017

Asylum seekers, especially those affected by conflict or who had to flee urgently, sometimes do not have the opportunity to bring these documents. Some asylum seekers who travelled to Germany with no identification documents at all either attempt to obtain them while in Germany (for example, by going to the embassy of their country of origin to request a passport) or get their identification delivered by family in their country of origin. These options are not always possible or safe—in many cases, participants reported that they could not reach the university in their home country to ask for their education certificates due to ongoing conflict.

ID documents can be lost or damaged on the way to Germany or confiscated by authorities in a transit third country. One participant shared that their passport was left with the authorities of another EU country that issued a decision to deport them. They arrived in Germany with only a national ID. Based on migrants’ experiences, national IDs do not have the same value to German authorities as a passport in terms of confirming a migrant’s identity.

The identification document provided to asylum applicants after they register with the German authorities, commonly referred to as Ausweis, allows asylum applicants to identify themselves and receive benefits. Asylum applicants must visit the relevant administration, wait for their turn, and show their Ausweis to receive benefits on a monthly basis. These requirements and the rights of migrants, including asylum seekers, vary depending on the policies of each German state.

What migrants call an Ausweis or ID card in the interviews varies depending on the person’s legal status. For example, those with a valid residence permit use the term when referring to proof of their residence permit, either the eAT or a sticker glued to their passport. Those applying for asylum or awaiting a decision regarding their residence in Germany consider the piece of paper that they receive as part of the process as their Ausweis.

Based on migrants’ experiences, becoming a citizen is primarily a practical decision. A German passport affords many privileges, chief among them freedom of movement. Many interviewees had either applied for German citizenship or expressed their desire to do so in the future.

“The day I will feel the passport will be the day I will be traveling outside of [the EU] and feel the priority of this red book in your hand. Until now, I did not know the [value] of this passport. This is the only thing I can care about, the freedom that you would get to travel with it outside of this country or this world. For me that’s the only thing, it doesn’t change anything. I am still who I am, and maybe I am still even more proud African. [laughs] I don’t want to be a proud German.”
—Citizenship_2014

However, this perception is also shaped by the experiences migrants have had in Germany. A participant who was victimized by the German state expressed a high degree of distrust in the safety afforded by gaining citizenship. Even though they are eligible for German citizenship, they don’t plan to pursue it.

“We don’t really have any advantage, even with the document and the other things they give us because you could lose this anytime. And that’s why I tell most of my friends who think they have German passports, I tell them ‘Bro, one mistake you could lose this, so always plan for the worst. Don’t think now you have this and are very popular in Germany. You could lose it and go through what we went through.’ So the document doesn’t really help us.”
—Parent visa_2000

How do migrants store their identification documents?

People are usually aware that identification documents are essential, particularly when migrating to a new country, and they take various precautions to protect and preserve them. Asylum seekers coming through several transit countries reported that they kept their original official documents in several plastic bags so that they do not get wet or damaged. When in Germany, participants carry identification documents in their wallet or store them in a binder at home if they are not required for everyday use. Most interviewees said that they also keep scanned copies of the documents on their phone, laptop, or a drive. Some also keep digital copies of official documents with a family member as a precautionary measure. Therefore, providing practical alternatives to carrying physical documents, particularly passports, could alleviate the stress experienced by migrants when managing and keeping track of their paperwork. However, this would only be possible if migrants could be sure that they would not be required to produce any number of documents at random. The eAT is a case in point.

Migrants receive their residence permit either in form of the eAT, a separate card, or as a sticker in their passport. The rationale as to why one would receive a sticker and not an eAT is not clear to migrants. One participant, a student, applied for a renewal of their residence permit with the support of the university where they are enrolled:

“I realized that [the bureaucrat] was going to put it as a sticker on my passport, the residence permit. And I found it weird because for me, it should be a card. So I asked them, why is that? Their answer was that because I applied through the university, I got it as a sticker. If I had applied myself, I would have gotten a card. And for me, it just didn’t make sense as an explanation.”
—Student_2021

In the case of the sticker, migrants feel at times forced to carry their passports, as it holds their residence permit and is the only document they have that shows under which regulation they are allowed to stay in the country. This causes a sense of insecurity—what happens if they lose their passport? Many who receive the eAT carry it in their physical wallets while storing their passports at home.

Receiving a sticker instead of the eAT also excludes migrants from accessing the German eID infrastructure. Before the eAT was introduced in 2011, it was standard practice in Germany to issue residence permits as stickers. These residence permits did not instantly lose their validity with the introduction of the eAT. However, if reissuance was necessary (e.g., upon the permit’s or national passport’s expiration), legally, the previous documents had to be replaced with an eAT and by 30 August 2021, at the latest. 85 In this way, the immigration authorities were granted a ten-year transition period to allow them to gradually implement the switch to the eAT. However, a draft of the Passport and Identity Document Modernisation Act, 86 adopted into law in 2023, pointed out that Germany’s ongoing practice of issuing stickers has not been in line with EU law establishing a uniform format for residence permits for third-country nationals. 87 With the passing of the Passport and Identity Document Modernisation Act, two changes came into force. First, stickers may only be issued in exceptional circumstances and for an extension of the authorized stay with a maximum duration of one month. Second, the transition period for switching to the eAT (30 August 2021) was removed from the legal text as the date had passed. The corresponding section now states that residence permits may be reissued as an eAT if the holder can demonstrate a legitimate interest in the reissue. 88

These legal changes notwithstanding, in practice immigration authorities do not always give out eATs and they often refuse to reissue passport stickers, particularly in the case of the Berlin LEA. Although the website of the Berlin LEA states that new permits have been issued as eATs since February 2020, 89 exceptions continue to be made. For example, in 2022, the BMI issued a document on how to implement the EU’s decision to grant temporary protection to those fleeing the war in Ukraine, 90 in which the BMI gave the federal states discretion to issue residence permits in the form of stickers “if, due to the exceptionally high number of applicants from Ukraine, it was no longer possible to issue residence permits in card format as eATs in accordance with the established procedure.” 91 The Berlin Refugee Council described this decision as “special arrangement for the Berlin LEA, because Berlin does not want to issue eATs due to ‘work overload.’” 92 In addition, the Berlin LEA does “only in exceptional cases” reissue residence permits as eATs ahead of expiration: “The mere possibility that additional [digital] functions are available or can be used with an eAT is not sufficient.” 93 While exact data on how many people have been issued a residence permit sticker instead of an eAT in Berlin and throughout Germany is not available, these examples illustrate that migrants are faced with many challenges in accessing their rights and services due to the different administrative practices of the more than 600 decentralized immigration authorities. 94

What identification documents do migrants carry in their everyday life?

Trust in the protection provided by identification documents significantly influences how individuals relate to them and whether they choose to carry them. For non-citizens, uncertainty about which documents may be requested by authorities often leads to carrying more documentation than necessary, a cautious approach shaped by their experiences and precarious status. By contrast, some participants would carry merely a picture on their phone of their document(s).

“Do I carry my Blue Card around? I have a picture of it, so I save it at home. On specific days when I need to go to a place that asks for ID, I will carry it. I don’t carry my passport. The passport stays at home.”
—Blue Card_2024

Others carried around in their everyday life more documents than is perhaps necessary, like in the case of having a Zusatzblatt. However, the need for the Zusatzblatt was unclear to many participants, though everyone with a residence permit obtains this document. One participant with a freelance visa was asked for it on more than one occasion, but most participants reported that they had no use for it.

“When I got my residence permit I was very, very happy. It was a card and it was for three years. And it came also with a supplement. So basically a piece of paper where it’s written based on which law I got this permit.”
—Student_2021

“I got the card with some supplement. The only time I use it is when I’m travelling, because the border control people want to see it. And once I got a job and they asked me for it to know how to work out the tax and work thing.”
—Freelance visa_2000

The practice of carrying multiple identification documents, such as both a residence permit and a passport, reflects the inconsistent requirements individuals often face in different identification touchpoints. While the eAT should suffice in most everyday situations, some authorities or individuals insist on seeing the passport as well. This inconsistency, often driven by biases or arbitrary enforcement, creates a sense of uncertainty and compels individuals to carry additional documentation to avoid complications.

“I still carry the two [Aufenhaltstitel and passport]. My passport is inside my bag, and the other one in my wallet. So sometimes when there are some certain places you just need the ID card, while some people still want to see the passport. If they don’t see the passport they don’t accept it. […] Some people just do it just because they can do it or because they want to do it. Normally the ID card is already enough, but some people just want to see it.”
—Parent visa_2000

This experience of inconsistency is exacerbated while traveling within Europe, a point which also relates to mobility, as discussed later in this report.

“I don’t understand when I do and when I don’t have to have it, and how to use it. I know it’s one thing that I need to enter and leave the EU. But it’s very weird because sometimes just by showing my passport they let me pass, sometimes I have to show both. For me it is not very clear how. It seems to me that the immigration cops sometimes decide yes and sometimes they decide no.”
—Work visa_2021a

Taking into account some of the points mentioned here, the EUDI Wallet could offer certain benefits for non-EU migrants coming to live in Germany, especially with regard to the fragility of paper documents and concerns about their damage and loss. The EUDI Wallet will provide a virtual container for a variety of documents, independently of private sector cloud services (e.g., Google Drive, iCloud). At the same time, discussed in more detail below, in Germany the EUDI Wallet’s basic identity, the PID, is expected to be issued via the existing eID infrastructure, that is, on the basis of identity documents issued by German authorities. 95 No clear information is available on how documents from outside the emerging EUDI ecosystem will be integrated and used via an EUDI Wallet (e.g., a passport or a birth certificate issued outside the EU). Currently, we must assume that migrants from outside the EU will not be able to carry and present all their documents digitally via the EUDI Wallet, at least as long as the question of global interoperability across different identity ecosystems and wallet solutions has not been tackled. How beneficial people will find the EUDI Wallet for their everyday life is thus not just a technology issue. Usability actually depends on the interplay and integration of various components of global, regional, and national identity ecosystems—not least on whether and how public authorities promote and deal with the issuance and acceptance of digital credentials, a challenge that has already negatively impacted the rollout of existing eID infrastructure in Germany.

Germany’s identity ecosystem and how it currently operates: Hopes and challenges

Since the entry into force of the revised eIDAS regulation in May 2024, EU Member States have been facing an ambitious timeline. According to the regulation, Member States must make at least one EUDI Wallet available 96 to their citizens and residents within 24 months of the adoption of the accompanying implementing acts, which set out the core functionalities and certification rules for EUDI Wallet solutions. Originally scheduled to be adopted by 21 November 2024, the first five implementing acts were finalized on 28 November, published in the Official Journal on 4 December, and entered into force on 28 December 2024. 97 The official EU Digital Identity Wallet account announced the “huge news” on social media platform X and promised that “citizens can now expect wallets by the end of 2026.” 98

Expectations for the arrival of the EUDI Wallet are indeed rising. In Germany, few people use the eID function of the Personalausweis. A recent representative survey found that around 35% of German-speaking adults in Germany have an identity document with an activated eID function. 99 Another study estimates that 39% of Personalausweis holders have an active eID function, while 22% of Personalausweis holders have actively made use of it. 100 This could also hinder the EUDI Wallet’s widespread adoption in Germany, as users will need an identity document with an active eID to get issued a PID and thus be able to access the full range of EUDI Wallet functionalities.

The low acceptance of the German eID infrastructure has been attributed to a number of factors, such as the lack of use cases, the cumbersome nature of the whole set-up and its various components, and concerns about privacy and data protection. An interviewee with over ten years of research experience in digital identity recalls the launch of the eID function in 2010:

“There was a lot of fear involved. And also, I think there was not really, it was not clear why we actually need that. Why do we need a ‘digitaler Personalausweis’ [digital ID card]? Even though people were using the internet, I think it was not really clear why we needed these secure digital identities back then.”
—Science & Research_7

Similarly, a digital identity expert from one of Germany’s leading digital industry associations highlights the lack of relevant use cases that could motivate people to actively use the country’s national eID infrastructure, especially for those with an ID card issued before 2017, when eID activation was an opt-in feature.

“Yes, there are certain government services … for those it is possible [to use the eID]. But now the next question: How often do you have to register a new address? Yes, exactly and there are very, very few use cases. There are practically none that you use regularly where you can identify yourself with the eID. And another problem was that until 2017, the Citizens’ Offices offered to activate the eID function. Then you asked the question ‘what do I need it for’ and the answer was that you don’t actually need it. There is actually no really good reason to activate the eID [if it is not activated yet]. There just isn’t. It’s still just one of a number of ways to identify yourself.”
Business & Industry_1

The role of public authorities was mentioned several times when it came to the question of why so few people in Germany still use the eID.

“I talked to everyone about it and none of them even knew it [their Personalausweis/national ID card] had an eID function. Some of them were even advised not to activate it. That was also the challenge, or when they asked [about the eID], they were given no useful answers at the Citizens’ Office.”
—Science & Research_6

Regarding the development and implementation of use cases, this chicken-and- egg dilemma is often cited by experts as a reason for the eID’s lack of success. The same interviewee raised concerns about the role of value creation and economic interests in the early development phases of the German identity ecosystem and with regard to the introduction of the eID:

“When I talked to these stakeholders, they said, ‘Yes, we’re trying to build something particularly secure here.’ But we’ve created such big hurdles that we just can’t get people who want to build the use cases on a voluntary basis. Unfortunately, in a capitalist logic, there is no such thing as intrinsic motivation.”
—Science & Research_6

As these interviews show, Germany’s eID infrastructure is not considered user-friendly enough for widespread implementation. Meanwhile, the low number of users generates little interest among stakeholders in implementing use cases, particularly in the private sector. Consequently, as is the general consensus among experts, the eID currently offers limited potential for the further digitalization of access to public and private services.

Taking a closer look at a key component of the eID function, the personal PIN code that users need to operate it, it becomes clear that, although many consider the German eID infrastructure to be highly advanced in terms of cybersecurity, access depends on limited offline resources, creating bottlenecks cannot be resolved by wallet technology. In order to authenticate themselves online, users must possess either the Personalausweis, the eID card for EU/EEA citizens, or an eAT with an active eID function, as well as an NFC-enabled device or special card reader, and have downloaded the so-called AusweisApp (“ID app”). Every time users want to identify themselves online, the AusweisApp requires them to tap their identity card and enter a six-digit PIN code. Users can set this PIN code using a preliminary Einmal (“one-time”) five-digit PIN code that they receive via a corresponding PIN letter handed out after the identity card has been applied for in person. If users forget their six-digit code or if they lose the letter before going through the set-up process, they will need to request a reset, requiring them to go to their local Citizens’ Office.

During the height of the COVID pandemic, it was possible to request a reset online and receive a new letter with a new Einmal-PIN code via postal services. To save costs, this service was suspended at the beginning of 2024. 101 As German digital civil liberties platform and news site netzpolitik. org wrote in early 2024 about the “PIN Rücksetz” (PIN reset) dilemma:

“The classic game of Jenga requires patience and skill. With a steady hand, players must remove individual pieces from a stacked tower of blocks and place them on top. Patience and a sure instinct are also required when it comes to digital policy in this country. One wrong decision can quickly bring down what has been painstakingly built. In December last year, the German government managed to remove a key building block of its digital strategy in one fell swoop, putting the whole project at risk.” 102

Similarly, during the COVID pandemic, it was possible for eAT holders and Personalausweis holders whose identity card was issued before 2017 to activate their eID function online (meaning that they would subsequently receive the PIN letter via post). When the eID function was first introduced in 2010, each Personalausweis holder could choose whether to activate the eID function—a decision that, as described above, is widely seen as a reason for its low uptake. The 2017 Law for the Promotion of the Electronic Proof of Identity (Gesetz zur Förderung des elektronischen Identitätsnachweises) established that every Personalausweis would be issued with the eID function activated. For citizens over the age of 24, the Personalausweis is valid for ten years, so that until 2027, many identity documents without an automatically activated eID function will still be in use.

For eAT holders, on the other hand, the eID function is still not automatically activated. Now that activation of the eID can no longer be requested online, people need face-to-face appointments to do so. In Berlin, wait times for such an appointment vary depending on whether the activation is for a Personalausweis or eAT. For the Personalausweis, Citizens’ Offices offer this service on a drop-in basis, without the need for an appointment. The official Berlin government services website ServicePortal Berlin specifies that the LEA is responsible for holders of an eAT and further: “Please use the contact form to get in touch with the relevant department.” 103

This seemingly simple step creates additional barriers for potential eAT holders wishing to engage with the German eID infrastructure. The expat website All About Berlin has a whole section on “How to contact the Ausländerbehörde” that explains how to use the contact form (both for applying for a residence permit and for any other type of enquiry/appointment). 104 All About Berlin advises anyone wishing to contact the LEA to write in German and to include copies of relevant documents with their request, and warns of slow responses. Behind the contact form lurks an indefinite waiting period; there is no way of knowing when a response will be received. According to recent reports, tens of thousands of people in Berlin are waiting for their residence permits to be issued, renewed, or extended. In the case of a further 42,000 people, it is unclear why they contacted the LEA, as their emails have not even been opened yet. 105

Bureaucratic practices vary between municipalities and federal states in Germany. However, there is a common theme: Immigration authorities across Germany report massive workloads and, as a result, delays in processing applications. While local context matters, for example, in terms of financial resources, staffing, catchment area, and the scope of work, there are cross-cutting issues. These include federal regulations and reforms said to increase the administrative burden rather than reducing it. When asked at a public panel at the 2024 Smart Country Convention about the added value of the latest revision of the Immigration Act for Skilled Workers (Fachkräfteeinwanderungsgesetz [FEG]), the director of Berlin’s LEA answered without beating about the bush:

“To put it very simply, [there is] none […] This law […] does not, on balance, contribute to speeding up or facilitating procedures or improving processes.”

In the same breath, he mentioned as a positive development that the work of the authority had been made easier in relation to the issuing of visas and residence permits, by “taking them out of the race”:

“There are individual regulations [of the FEG] that help us a lot, for example, that we as a domestic immigration authority are no longer involved in visa procedures, that we as a player are no longer involved in this process, that helps us. And the second thing is that certain visas will be issued for a whole year, or have been issued for a whole year for some time now, so that we will only see the client who immigrates after a year, when they have already largely settled in their job and in the city. These are two things that help a lot because they ensure longer validity periods and because they take us out of the race. But everything else leads to much greater complexity.” 106

The first year after arrival in Germany is full of interactions with the public and private sector that require various forms of identification in one way or another, including obtaining a residence permit. Longer visa validity periods shift the interaction timeline between visa holders and local immigration authorities, and are thus framed here as a way of reducing the pressure on immigration authorities, who now see their “clients” after they have settled. For migrants who come to Germany on a visa, however, this shift means that they have later access to a residence permit and the security of a long-term perspective in Germany. While the decision to prolong visa validity may seem like a small change to simplify things for immigration authorities, in the complexity of the German identity ecosystem, changes in one area can have unintended, sometimes far-reaching consequences in other areas. Later access to a residence permit also means later access to the eAT and certain digital public and private services. As in Germany part of the EUDI Wallet functionalities will build and rely on the existing eID infrastructure, longer visa validity periods will have a much greater impact on a much greater number of issues than perhaps originally envisaged.

It remains to be seen how the next federal government will tackle the workload of immigration authorities 107 —and whether Germany will find more ways to put less work on the shoulders of its municipalities. In one interview, local government representatives from the city of Wiesbaden explained that ever since the introduction of the eID function, they had to invest considerable resources in helping the residents of their municipality set up and use it, including time slots solely dedicated to activating and/or resetting eIDs. Interestingly, a few years ago, inspired by the onboarding processes long offered by banks, Wiesbaden introduced video identification to provide online access to certain government services and considers it a big success. For those online services where the city offers both identification methods (access via video identification or via the eID function), the numbers seem to speak for themselves. Of online users, 90% chose video identification, compared to 10% who preferred the eID option. Video identification has the advantage that people can use it on an ad hoc basis and that it does not specifically require a German ID card, PIN code, or the like. Similar trends are evident in representative data from 2022, according to which 38% of the adult population in Germany have used video identification at least once, compared to 8% who have used the eID once or more. 108 While video identification also has its own issues, especially in terms of costs and privacy, these figures signal that people’s interest in digital identification options is indeed high if they are designed differently from Germany’s existing eID infrastructure.

Along similar lines, SPRIND has emphasized the urgent need for less fragmentation and more coherence in all things digital identity:

“Currently, the security and data protection level of the eID function is high, but only 22% of people have used this function at least once. Instead, identity verification procedures with a lower level of security and privacy are used much more frequently, such as ELSTER or video and photo identification solutions. Although these procedures are also complex, they are less complicated to use than the eID function of the national ID card. Instead of […] a single approach, several different identification methods […] are being developed, which are not interoperable with each other. The majority of citizens find this diversity complicated, which fundamentally reduces the acceptance of such procedures. The diversity of solutions also undermines data minimisation and security, but above all economic efficiency […] This recent development highlights the urgent need for a uniform approach to digital credentials in EUDI Wallets in an interoperable ecosystem.” 109

It is against this backdrop that expectations for the arrival of the EUDI Wallet are rising.

What would the EUDI Wallet change?

Given the mounting pressure Germany is under to digitalize and modernize, it is perhaps not surprising that calls for improvements to existing systems and research into new digital identity solutions have preceded eIDAS 2.0 and the EUDI Wallet. One interviewee describes how interest in digital identity wallets and SSI has grown alongside the rising interest in blockchain and distributed ledger technology (DLT):

“Throughout the 2010s, the pressure certainly started to rise. And there was the feeling that it’s too complicated. Digitalization in the public sector is not really working well. Then came the blockchain hype […] and then this push: Everything should be digital […] Everyone has to do something with blockchain. So, also the identity projects.”
—Science & Research_7

The EU’s increasing emphasis on digital sovereignty and legally binding regulatory timelines have further fueled this momentum, an interviewee who was closely involved in coordinating digital identity projects funded through the Schaufenster Sichere Digitale Identitäten, a government-funded innovation competition and research program, recalls:

“When I joined […] it didn’t feel like the topic [of digital identities] was on the agenda anywhere […] the topic wasn’t that prominent. And it was similar when the ‘Schaufensterprojekte’ was launched, when we had already noticed this trend towards self-sovereign identities. That’s why there was this research program, and Germany was also one of the pioneers here, it has to be said, at least as far as government-funded programs are concerned. So even before the eIDAS regulation was to be amended, it was recognised: the issue is relevant […] Then it was decided […] that there should be a so-called European Digital Identity Wallet. And suddenly, the topic [of digital identities] has moved up the agenda everywhere.”
—Business & Industry_3

Because of their association with blockchain and DLT, SSI and digital identity wallets have become entangled with visions of a radical shift away from centralized structures: SSI, for some in the digital identity expert community, gives users the power to “own and control” an identity that “cannot be taken away from them” and “is intrinsically theirs.” 110 However, not all SSI models use cryptography in the way that blockchain and DLT are renowned for. 111 Research shows that wallet-based identity management models and ecosystems are more heterogeneous and ambiguous than the PR around them may suggest, meaning that loosely defined concepts like self-sovereignty and data sovereignty can be open to different socio-technical interpretations. 112 Realistically, the EUDI Wallet cannot function independently of existing centralized public registries and other types of databases when credential issuance relies on them. 113 That said, the EUDI Wallet debate has clearly been influenced by the hype and value-laden expectations surrounding blockchain and SSI, particularly given the EU’s renewed bid for digital leadership:

“The clock is ticking a bit when we talk about the whole issue of [digital] sovereignty.”
—Business & Industry_3

Although the EUDI Wallet is still a work in progress—or perhaps for that very reason—it is seen as a potential game changer for digitalization in Germany, a country that is perceived to be falling further and further behind. In 2022, Germany’s previous government declared “secure and user-friendly digital identities and modern registries” to be a cornerstone of the country’s digital progress in the coming decade. 114 However, despite significant government investments in upgrading Germany’s eID infrastructure, previous attempts to realize a fully mobile digital identity solution have resoundingly failed. In autumn 2021, the Federal Chancellery (Bundeskanzleramt) released the “ID Wallet” app, only to take it offline a few days later due to security concerns. 115 The second time, with the “Smart eID” project, the BMI planned to anchor the country’s existing eID infrastructure via secure elements in smartphones (instead of the chip in the identity cards). 116 After more than 90 million euros had been invested, the pilot phase was cancelled in 2023 because certain smartphone vendors did not want to provide access to their secure elements. These chips were also only available in more expensive smartphone models, effectively excluding a large enough portion of smartphone holders from this approach. With the implementation of eIDAS 2.0, the federal government seems determined to overcome these previous shortcomings: 117

“We want citizens to be able to prove their identity quickly, securely and easily directly via their smartphone—without the need for an additional card or reader. This will make it much easier to prove their identity in everyday life, when applying for a job, when doing online banking or when dealing with the authorities. The EUDI Wallet will guarantee the highest security standards and protect users’ privacy. The EUDI Wallet will be available free of charge and will contribute to digital inclusion, as everyone— regardless of their financial situation—will have access to digital services.”
—Nancy Faeser, Federal Minister of the Interior and Home Affairs 118

Indeed, Germany’s participatory approach to implementing eIDAS 2.0 appears to be rooted in a commitment to learning from past failures, strengthening public acceptance of the EUDI Wallet and, in this way, digital inclusion. Since the official launch of the architecture and consultation process in July 2023, the project team has continuously documented and shared insights into its architecture choices for the German National Wallet via OpenCoDE, an open-source platform where theoretically anyone can comment, raise issues, and give input. 119 The open-source documentation of the development process is intended to serve as a reference implementation and basis for discussion for all other considerations related to the emerging EUDI Wallet ecosystem, stimulating growth and diversification. 120 In addition to insights gathered from expert interviews, this documentation also informs our assessment of the EUDI Wallet’s potential to promote digital inclusion for everyone in Germany.

One issue that we have identified with regard to digital inclusion is the question of PID issuance: How can users receive the core set of Personal Identification Data (PID) into their Wallet? And to what extent does the EUDI Wallet’s user-experience depend on the PID?

The eIDAS Regulation was developed to foster trust in digital transactions between and among EU Member States by establishing a shared basis for interoperability in electronic identification. 121 Member States build trust in this emerging EU-wide digital identity ecosystem by committing to the same standards and procedures when issuing electronic identification and assessing its security. 122 In this sense, an individual must first be vetted and vouched for by a Member State before being granted access to the eIDAS realm: “Only Member States’ competent authorities can provide a high level of confidence in establishing the identity of a person and therefore provide assurance that the person claiming or asserting a particular identity is in fact the person he or she claims to be.” 123 According to this logic, when someone is issued a German national ID card, eAT, or ID card for EU/EEA citizens—all of which are issued at assurance level “high” (or “LoA high”)—this document proves that the German authorities have a high level of trust in that person’s identity. For the onboarding to the EUDI ecosystem, eIDAS 2.0 stipulates that users should (initially) be identified “by relying on electronic identification means issued at assurance level high.” 124 To comply with this requirement, 125 PID issuance in Germany will be done via the existing eID infrastructure. 126 Therefore, at least as currently planned only people with German government-issued identity documents with an active eID function will be able to use the full range of EUDI Wallet functions. However, it remains unclear to what extent users will be able to benefit from having an EUDI Wallet without a PID. A digital identity certified according to LoA high can also be used for use cases that would only require the user to authenticate their identity according to LoA substantial or low, meaning that an EUDI Wallet with PID enables a maximum number of use cases:

“[This] is of course nice in theory, but obviously more difficult in practice. Because this hurdle from substantial to high in terms of effort, certification costs, etc., is exponentially higher compared to the added value. Because it is not necessarily the case that LoA high covers 50% of the use cases, so that an equal distribution takes place.”
—Government & Administration_2

One interviewee working for the German EUDI Wallet project team highlighted that many use cases could be implemented at a lower level of assurance:

“The only credential you will present at LoA high will be the PID. You will never present your bachelor’s or graduate degree at LoA high.”
—Government & Administration_2

But if a good user-experience will depend on the PID, then the high LoA requirement will create significant barriers for many people. As previously mentioned, many people in Germany have not activated the eID function of their identity document. For migrants with an eAT, the activation process is potentially more cumbersome, as it involves the perpetually backlogged immigration authorities. For migrants with a sticker in their passport instead of an eAT, it is unclear whether and how there might be an alternative PID issuance process available for them. Also, non-EU nationals would be excluded, at least temporarily, from PID issuance when they first arrive in Germany and have to go through different administrative procedures to apply for a residence permit and receive an eAT—a process that, as detailed above, can take up to a year, and even longer in certain asylum and Duldung cases. Thus, when non-EU nationals first arrive in Germany, no matter their migration status, they are unlikely to immediately benefit from any advantages that the EUDI Wallet might offer.

This issue was raised by the Federal Office for Migration and Refugees (BAMF) during an EUDI Wallet open online consultation in October 2024, where the BAMF problematized the exclusion of asylum-seekers from the EUDI ecosystem. 127 During this online consultation, the German EUDI Wallet project team signaled that they consider this question to be highly relevant. According to one interviewee working for BAMF, the agency is in touch with the project and may be able to start working on the integration of asylum seekers into the emerging EUDI Wallet ecosystem before the official launch of the app:

“We are now also registered as beta users. So we may be able to use [the EUDI Wallet] sooner.”
—Government & Administration_12

This suggests that Germany’s participatory approach to implementing the EUDI Wallet and its various consultation formats do indeed create new opportunities for exchange and adaptation, potentially improving the Wallet’s user experience through this iterative process. One could argue that, because of these consultation formats, a potential user group that was not previously at the forefront of the discussion is now at least included on the agenda. At the same time, the question remains as to how exactly the identification needs of asylum seekers will be taken into account and incorporated—and whether their integration into the EUDI Wallet ecosystem is at all likely to improve their experiences of German bureaucracy in a meaningful way. In any event, asylum seekers’ access to the EUDI ecosystem will depend on the registration and identification procedures carried out by BAMF and other German authorities, as well as the digitalization of identity documents that are currently issued in paper form as part of the asylum procedure (Ankunftsnachweis, Aufenthaltungsgestattung, Duldung). This would mean that BAMF would act as issuing authority, as one BAMF IT expert explained:

“Personally, I would say that we will have achieved a great deal if we succeed […] in making it possible that the architecture of the German EUDI Wallet is designed in such a way that not only people who have an eID can use it with level of assurance high, but that it is also possible for people who currently still have paper-based proofs of identity, where we as the issuing authority could perhaps also issue something digitally, just not with LoA high, of course […] our ‘customers,’ if you can put it that way, it would help them a lot if they could also use this ecosystem, because it would enable them to do an incredible number of things, because they can participate in this development and use these credentials in other ways.”
—Government & Administration_9

BAMF’s potential future role as issuing authority emphasizes once again that labels such as “decentralized,” “user-centric,” or even “self-sovereign” do not mean that users will manage their identity data in isolation from and independently of existing state structures and bureaucratic practices.

Users’ access to the EUDI Wallet and its full range of functions depends on the degree to which Member States’ authorities, such as BAMF in Germany, regard and declare them as trustworthy. Accordingly, it is not foreseen that identity documents issued outside the EU can be used for PID issuance, only “high confidence” documents issued by EU Member States.

“Unambiguously identifying third-country nationals—always extremely difficult. There are enough states that don’t have a birth register, there are enough states where identification is linked to how long you’ve had a bank account, because there’s simply no official record.”
—Representative, Federal Ministry of the Interior 128

Interviews repeatedly demonstrated that this question of trust is the fundamental issue when it comes to thinking about potential cross-border interactions between the emerging EUDI Wallet ecosystem and non-EU identity ecosystems. At the same time, issues of global interoperability are currently not at the heart of the eIDAS debate, at least in Germany. One interviewee emphasized that eIDAS was written for the EU, much like the regulation itself speaks of “trusted digital identities for all Europeans” 129 :

“It is a European regulation that is primarily aimed at European citizens.”
—Business & Industry_3

The eIDAS regulation and the EUDI Wallet reflect a European understanding of secure and trustworthy identities, meaning that interoperability between this EU-wide digital identity ecosystem and other “outsider” ecosystems will require translation and certification schemes; an agreement on a common trust architecture. In this context, several interviewees referred to the Ukrainian Diia app, which German authorities are finding difficult to navigate, precisely because there is no framework to ensure interoperability.

“It was so terrible. People were fleeing because of this terrible war and when they came to Germany they didn’t carry their paper files under their arms. Instead, they packed the things they needed to live and this app was on their mobile phone and the documents were in it. They took it for granted—and rightly so—that this was where they got their documents. Then they came to Germany and we administrators said, ‘What you have in the app is not enough for me. Where is your university certificate that says you have a master’s degree to get a job here?’”
—Government & Administration_4

However, while global interoperability was discussed as important, promising, and desirable, interviewees described it as a dream of the future, especially as the path towards EU-wide interoperability is already perceived as “bumpy”:

“Of course, if we can manage to, I don’t know, take information from the Ukrainian Diia app, for example, it would be an incredible added value if we could somehow manage that […] if we could understand and interpret the data in a way that says: this has confidence level Y for us. But we’re not there yet. And I believe that will only come when the EUDI starts to fly, when it is live and people start to use it. Once the basics are in place, then we can think about how we can take this even further from the EU context: How can we communicate with other ecosystems? This is now our EU ecosystem and we need to make sure that we can actually make it as interoperable as it is intended to be. I’m afraid it’s going to be a bit bumpy.”
—Government & Administration_9

The fact that there are still challenges at EU level to ensure interoperability between all EUDI Wallets demonstrates that interoperability, whether global, regional, or multi- or bilateral, is an inherently political issue. As one interviewee noted, the necessary technological standards and protocols already exist and continue to be developed. However, working towards cross-border interoperability requires different stakeholders from different contexts to find common ground and establish agreements and frameworks for recognizing and validating certificates and credentials across jurisdictions:

“If a verifier has to accept credentials from many different countries, it is of course much more technically demanding than if a verifier only accepts credentials from Europe. In Europe, that is why we have agreed on a tech stack—so that it is not so complicated […] But I think the even bigger challenge is deciding and translating when and how something is comparable […] I believe that we are relatively far advanced in terms of the technical protocols for interoperability and the whole trust infrastructure is still relatively far behind.”
—Government & Administration_10

EU-wide interoperability is already an ambitious goal, and global interoperability is even more challenging. However, the issue should not be overlooked, especially given its relevance to how international mobility and migration will be managed and regulated in the future. Many countries around the world are currently investing in the development of digital wallets and credentials (e.g., US states bringing mobile driver’s licenses and state IDs to Apple and Google Wallet, 130 or Bhutan’s launch of its new decentralized national identity system 131 ). There are various forms of collaboration and exchange where governments, the private sector, international organizations and donor agencies, foundations and NGOs work together (e.g., global standards organizations such as ISO or the OpenID Foundation).

Even if the current focus of all eIDAS-related activities is on national and EU-wide implementation, the future horizons of digital identity are much broader and should be strategically addressed at this stage. In this context, the following section highlights the tension between future-oriented planning and the often-Kafkaesque way in which migrants experience the existing eID infrastructure in Germany and other digitalization efforts in the area of borders, migration, and asylum.

Current identification challenges

For digitalization efforts to effectively address the real challenges that people, including migrants, face in terms of identification, it is crucial to first understand existing identification practices and barriers. Without this foundation, the introduction of a digital wallet risks overlooking key issues and reinforcing existing obstacles.

Migrant experiences

The following section explores current identification challenges based on the experiences of migrants living in Berlin/Germany. The first section focuses on cross-cutting challenges, meaning shared experiences among migrants dealing with German bureaucracy. The second section deals more specifically with challenges regarding access to both public and private services as a migrant in Berlin/Germany.

Cross-cutting challenges

Verification and authentication delays

The verification process undertaken by German authorities to authenticate documents submitted by asylum seekers, especially passports, for the purpose of confirming their identity and country of origin can be notably lengthy. As a result, the ID document provided by German authorities to asylum seekers in the meantime may state that the person’s nationality is “unclear,” which could prevent them from accessing certain rights. One interviewee, who came from Syria, had the right to access language classes during their asylum application phase based on a law that allowed asylum seekers who were highly likely to be granted asylum to participate in BAMF-paid language classes. But they could not exercise this right, despite providing authorities with their national ID, passport, and military service certificate.

“I provided everything which could prove that I am from Syria, and yet the first ID document I received when I filed my application for asylum stated that my nationality was ‘unclear.’ They needed time to examine the passport and other documents that I provided to verify whether they were real. So until then, my nationality was ‘unclear’ to them. So when I applied for the integration classes, my application was rejected because my nationality was ‘unclear.’ I couldn’t participate in the integration classes until my Ausweis said that I was from Syria.”
—Citizenship_2017

In exceptional cases, applicants may be refused an identification document until the examination of their passport is finalized. As such, they may be given a paper stating that their passports are being examined. In the case of one interviewee, such a paper was the only identification document they had for several months. This situation subjected them to considerable distress as they considered that showing this paper instead of an ID is an indication that people should be suspicious of them.

“They took my passport, and at that moment the suffering started. [At the LAGESO] they told me that they couldn’t start processing my asylum application until the examination of my passport was done. I had to wait. They didn’t even give me an ID. They only gave me a piece of paper which stated that my passport was being examined. It was an indictment paper more than anything. I felt that it was an indictment paper. It was so difficult. I was unwell for three months. I was scared to get out and or to go anywhere where I could be asked for an Ausweis. I was really unwell.”
—Citizen_2015

Indeed, the form and content of the identification documents provided to migrants not only impacts their mobility and rights, but also their well‑being.

Unclear and inconsistent administrative requirements

Laws, requirements, and processing times relating to residence permit or citizenship applications are generally unclear, and applicants are unable to track their application. Lack of clarity may cause confusion and stress for migrants, who try to cope by overplanning, preparing more documents than needed, regularly following up, and bringing German-speaking acquaintances to the relevant administration. As such, privilege, in this case, is for a migrant to have friends or acquaintances who are lawyers or knowledgeable about the processes and can advise or support. Those who have the financial resources may afford to assign a lawyer to follow up on administrative procedures, which reinforces inequalities among migrants from different economic backgrounds. Yet, even those with privilege are affected by the unclarity.

“So I applied. I asked them how long it would take. They said that they didn’t know… that I would receive something in the post. As I said, the process was not difficult, but I was in the dark. You cannot really call or follow up. I was emailing the lawyer every week to ask for news, and she always said that she didn’t have any.”
—Blue card_2022

Discriminatory and arbitrary bureaucratic practice

Migrants in Berlin report frequent experiences of discrimination when dealing with public administrators and bureaucrats at refugee accommodations, the Berlin Immigration Office, and the Bürgeramt. These experiences are not merely uncomfortable on an individual or interpersonal level—they can have a marked effect on migrants’ trajectories in the country.

The lack of clarity regarding necessary documentation explained above is a contributing factor to these discriminatory experiences. One participant recounted being dismissed and lectured about a requirement to show the supplement to their residence permit, despite initially being prepared with all documents required according to the official webpage. This supplemental document has never been requested in other administrative processes that the participant navigated. This experience left a lasting impression, highlighting how bureaucratic procedures can become tools of exclusion and control for marginalized groups.

Many interviewees shared how their processes or treatment could vary from one bureaucrat to the other, highlighting how their interactions with bureaucrats have shaped their access to rights and services. This lack of clarity lends itself to arbitrary decision-making by bureaucrats, which one participant described as dehumanizing:

“It makes you feel very vulnerable. Knowing that anything can really fail you in the face of the system. Why? Because they can just pull you out at any time, right? This is… it kind of dehumanizes you, right?”
—Freelance visa_2017

Participants reported discriminatory treatment by bureaucrats based on their country of origin, ethnicity, or religion. For example, one participant, a woman who wears the hijab, shared experiences of bureaucrats being rude or unhelpful. Another female participant highlighted that she experiences less discrimination than her peers, precisely because she doesn’t wear a hijab.

“It all depends on the employee, I think. They either like you or they just don’t, and make your life difficult. I feel that some do not want to accept women who wear the hijab.”
—Asylum applicant_2021a

Language and communication barriers

Official information shared on governmental services and rights is presented in a complicated manner and uses language that is perceived as difficult, including by German speakers. Many participants reported that they struggle to understand information displayed on governmental websites, or even letters sent to them by German authorities.

“I would like them to be aware that many bureaucratic applications are very complex to use. They also sometimes employ weird language.”
—Citizenship_2017

Even using digital translation tools might not be enough to learn how to fill out forms that are originally available in German, nor to understand how processes take place.

“There’s a website, something like ‘Berlin expat’ or something like that, where they translate and explain, in English, some of the official documents in German. And so I used that to help me translate the Anmeldung forms, because otherwise they’re in German. And even if I translate them on Google Translate, it would only give me what they mean in German, but it wouldn’t explain the process.”
—Student_2021

Another participant recounts being made to sign documents by migration officials in German when they first arrived in Germany, without being able to read any of the documents, as they did not yet speak the language.

Limited accessibility of bureaucrats

Communication with street-level bureaucrats is necessary to have more clarity on procedures and requirements; yet, communication with them is often limited and difficult. Migrants report that it is often unclear how to reach authorities in case of questions. Additionally, reaching street-level bureaucrats by phone or email is often not possible, as calls and emails are left unanswered; reports suggest that it might be easier to apply for some state services in Berlin by fax. 132 That said, the Berlin LEA has recently settled for an approach where all communication is channeled through a contact form. 133

When administrators are reached, bureaucrats sometimes insist on communicating in German, which is highly challenging for migrants who haven’t yet had the time and opportunity to learn the language. As a result, migrants lack clarity on processes, experience often unnecessary delays that cause high levels of anxiety and fears, and are excluded from important rights and services.

Reliance on physical documentation

Germany’s administrative processes rely heavily on physical documents. Given that documentation requirements are unclear and inconsistent, migrants do not always know which specific documents they need for the processes and end up storing a large number of documents for undetermined periods of time.

“Papers, documents … Every time I went to an administration, I took with me a bag full of papers. I bought that bag specifically for that. After some time, the papers could no longer fit in the bag. It was only later on that I knew which documents to take with me to appointments. After three or four years, when I started working, I realized that I had too many papers and documents. So I spent some time categorizing them, look [shows the researcher four large archival ring binders].”
—Citizenship_2017

Compulsory passport requirements

To access some services, migrants need not only a valid residence permit, but also a valid passport. Following this logic, one interviewee explained that, in Germany, the residence permit proves that the person is allowed to stay in the country, while the passport is the official proof of identity. This is the case, for example, when opening a bank account.

In some cases, subsidiary protection and the temporary residence permit accompanying it are tied to the beneficiary’s valid national passport. This is a challenge because some beneficiaries—fleeing wars to which their government is a party—fear visiting their government’s embassy and/or would not want to contribute to financing the same government that pushed them to flee. In the case of Syria, the Syrian passport is very expensive and can sometimes be made valid for short periods of time only. That said, many Syrians with subsidiary protection were forced to apply for a passport from the Syrian embassy:

“The [case handler responsible for my permanent residence application] insisted on the Syrian passport. In the end, I had to prioritize my well-being and comfort, and subsidiary protection was not safe for me. There was a lot of information circulating about it, and about possible deportations. I was scared to death. Literally two days before my appointment, as I had lost hope, I went to the Syrian embassy in Berlin, paid 735 euros and was granted the passport after one or two days, exactly on time for my appointment. The passport was valid for 2.5 years. 735 euros!”
—Citizen_2015

Duplication of efforts in document submission

Administrative procedures are not only tied to governmental institutions in Germany. They also involve German embassies in countries of origin. Participants who came to Germany on a visa stated that in order to apply for a residence permit, they had to submit the same documents that they had submitted to the German embassy in their home country upon their visa application, which seemed like a duplication of processes.

Additionally, some documents needed in Germany—such as education diplomas or birth certificates—require translation as well as certification or authentication by the German embassy or consulate in the applicant’s home country, which entails further costs, additional delays, and other challenges. For instance, one interviewee described how the security or political situation in migrants’ home countries could impact the processing of documents at the German embassy:

“At the time, the situation in [my country of origin] was not great, appointments were difficult to get and embassies were not always open.”
—Blue card_2022

Differential treatment depending on country of origin

Differential treatment, involving the provision of additional services and/or smoother procedures for migrants from specific countries, has led to an increased sense of injustice. Many participants—particularly those who had applied for asylum at some point—compared the lengthy and complex procedures that they experienced to the facilitated processes granted to Ukrainians upon their arrival in Germany in 2022. Some even argued that some rights, such as language learning and refugee housing, were taken away from them in order to be granted to Ukrainians.

Delays in finding appointments

Most participants mentioned strong difficulties in finding appointments online to access various government services, including applying for a residence permit, applying for unemployment, and getting an Anmeldung. These delays have caused them to feel insecure and led them to delay other steps in their lives, such as opening a bank account or starting employment, among others.

Additionally, those who lose their residence card experience long delays before they are provided an appointment at the Ausländerbehörde to be granted a new card. One interviewee could only have an appointment three months after contacting the Ausländerbehörde; during that time, they only had a police report and a scanned version of their lost residence card. These delays limit migrants’ access to services, as well as their mobility and ability to travel during the time when they do not have the actual residence card.

Dependency on solidarity networks

Given the challenges listed in this section, some migrants rely on the solidarity of other migrants to navigate the German system. Migrants have a long history of self-organization in Berlin and in Germany, and these solidarity networks often fill the gaps left by the government. Moreover, migrant-created social media groups (WhatsApp and Facebook groups, for instance) are often cited as a source of information for migrants.

“[…] connection to the solidarity [movement]. This is how I got my connection to Berlin. I came to Berlin, I joined this movement. I got to know the people. I broke the isolation by myself. Thanks to good people, everywhere you go you meet nice people. This is how I got a space where I was living, I got a job here, and my status has changed, based on all of these things.”
—Citizen_2014

While solidarity networks have had a positive impact on migrants’ experiences navigating systems, excessive reliance on them increases the risk of misinformation and the propagation of rumors; it also, potentially, creates dependencies that can become vulnerabilities.

Specific challenges

Housing

Getting an Anmeldung is challenging for migrants and even for nationals. In Germany, there is an Meldepflicht, 134  a regulation requiring all people residing in Germany to register their residence address; and all bureaucratic processes require an Anmeldung: opening a bank account, getting health insurance, getting your tax ID, having access to ELSTER (tax software), etc. Berlin has made it more difficult to get an Anmeldung. Previously a sublet contract would be enough; now, confirmation of move-in by the landlord is required. 135 This limits access to an Anmeldung for those in a precarious living situation, and has led to the commercialization of registered addresses through classified ads. 136 This further disenfranchises already marginalized migrants.

“I think the hardest part was getting the Anmeldung appointment. I had to check [the website] all the time to get an appointment. I had heard about this before coming to Germany, I already set up an appointment, because I knew how difficult it is.”
—Blue card_2024

Here again, migrants often rely on the solidarity of others, at times managing to get an Anmeldung through friends in order to obtain this very central document to navigate German bureaucracy.

In Berlin, there is also student accommodation, which can be hard to access due to the high demand, but that is open to students regardless of their citizenship. Generally speaking, one loses access to student housing once they are no longer a student. One participant highlighted their experience asking for an extension to their stay in student accommodation after graduating and being on a work-seeker visa, highlighting how some of these decisions are left to the arbitrary decision-making of bureaucrats:

“There is a lot of discretion in the process, right? I mean, of course, if some other person who is a little bit more, more stuck to the norm or is a little bit more fearful. It’s really screwed up. No? I mean, you probably get thrown out and they’re like, ‘No, that’s just the way the law works.’ It’s like, well … not really, there’s a lot of discretion on the part of [the bureaucrat]. So this one showed me that there was a lot of flexibility, this understanding, but you don’t know it, you have to look for it, right?”
—Freelance visa_2017

After lodging their application for international protection, asylum seekers are usually required to stay in refugee accommodation centers assigned by the state. The duration of this obligation has been regularly amended over the years; currently, it can reach 18 months. 137 It is possible to get a legal exception for this requirement based on the applicant’s health status, but this too is very challenging:

“Normally there is this law that while you are in the asylum process, you are not allowed to have an apartment. But that was an exception when you’re ill. I was pregnant and I had a lot of problems and also psychological problems, depression […] I was actually able to get this exception, this approval from the social welfare office that I could get an apartment and then we submitted our applications with all the cooperatives. But it was difficult. They didn’t want it to be so easy for us to get this apartment or they didn’t show us really nice apartments. Always the fifth or sixth floor. And very bad stuff like that. And then it worked out in the end. When my child was born. He was a week old and we moved. So exactly one week old.”
—Refugee status_2019

Migrants who receive benefits from the Sozialamt face increased difficulties in finding housing, which also relates to delays in disbursing social benefits.

“I would find an apartment, but then as soon as the landlords would know that I’m registered with the Sozialamt, they would reject me. This happened many times.”
—Asylum applicant_2021a

Healthcare

While most research participants are currently based in Berlin, some have had experience living in other German states. Similarly to other rights and services, access to healthcare for asylum seekers and Duldung holders may vary between states and at times between municipalities. 138 While some participants reported having all of their health needs covered, others commented on the “catastrophic” lack of healthcare access. Indeed, in some states, this access is basic or limited, as medical care is mediated by the Sozialamt and associated with state control.

“During the asylum process when you’re sick, you go to the social [worker], you ask them, ‘I am sick. Then the social [worker] will give you a note that you have to go to Sozialamt to get a Krankenmeldung. Then you go to a doctor and get treatment. So we were not even having insurance. The first six months […] none of us was issued a card, electronic. To a point, I remember, I got sick one time, I went to the Sozialamt. And the Sozialamt told me, I first have to go find a doctor. I find a doctor, they give me the sick note. So then, interestingly, I go to a doctor, but the doctors will not attend me without having this from the Sozialamt. It was a crazy thing. They would just make you frustrated. Every state has its own way of treating asylum seekers and processes.”
—Citizen_2014

In addition to complicating and delaying people’s access to healthcare, reports suggest that such practices promote bureaucratic arbitrariness by case workers at social welfare offices and significantly increase administrative burden on social services. 139 Berlin is one of the federal states that issues health insurance cards to asylum seekers, allowing them to see a doctor without permission from the authorities. Yet, in refugee accommodation there is virtually no access to mental health services. Asylum seekers might be able to gain access to mental health services through NGOs (such as Diakonie) rather than provided by the state directly.

Moreover, navigating the German healthcare system is often frustrating for migrants in general. Depending on whether you are insured publicly in Germany or have private insurance, you might face different challenges in Berlin, including for the latter having to pay high fees in advance while waiting to be reimbursed. While these challenges also affect citizens, migrants often find themselves in a more precarious position due to limited resources, smaller support networks, and language barriers that further restrict their access to healthcare.

Social benefits

Research participants who have applied for asylum during their residence in Germany narrated their experience receiving social benefits prior to receiving a residence title. Asylum applicants and Duldung holders report delays in receiving social benefits from the Sozialamt, which impacts their ability to buy food and essential goods, and to secure housing. Migrants with these legal statuses usually face increased restrictions on and limited opportunities for employment.

“For seven months, the Sozialamt did not disburse my rent. I was so embarrassed in front of my landlords. I was so embarrassed. I told them [the bureaucrats]: ‘Seven months? Really?’ They said that they were very busy. They wouldn’t pay my benefits, they wouldn’t pay for my insurance. I had enough at that point! I threatened to take them to court. It is only then that they paid. And still, I had to pay 80 euros as penalty because of this delay.”
—Asylum applicant_2021a

Migrants who have experienced unemployment were also asked about receiving benefits from the German Federal Employment Agency. One participant in the process of requesting citizenship reported that they were advised by their migration lawyer not to ask for unemployment benefits— even though they have been contributing to them for years and would be entitled to them—because of fears that this would negatively affect the process of obtaining citizenship. It’s important to highlight, in this context, that the right to a permanent residence permit and to citizenship in Germany is highly reliant on proving one’s contribution to pension insurance; moreover, regardless of one’s employment history, they may be ineligible to either title if they are unemployed at the moment of their application.

One participant with refugee status noted that they experienced structural racism when registering as unemployed: they would not get an appointment to speak to their case worker for months, creating a lot of uncertainty about whether or not they would have access to unemployment benefits.

“These are problems that I have that have nothing to do with my legal status through my asylum process, but rather these are problems I have because of my name, my identity as a migrant.”
—Refugee status_2019

Education Those who are granted international protection in Germany can receive support from job centers to have their educational qualifications recognized through the Service Center for Professional Recognition (Zentrale Servicestelle Berufsanerkennung). This process typically requires submitting university transcripts, course descriptions, and original diplomas. Other migrants who come to Germany on a work visa are required to go through the same process after arriving in Germany. However, many refugees face significant barriers, such as being unable to obtain these documents, which often forces them to start their education or training from scratch. In many cases, migrants’ education and experience is devalued, as the system evaluates it to be less valuable than a German diploma in the same discipline. Even when migrants’ credentials are recognized, they may not fully align with German standards, especially for professions requiring state licenses like teaching, medicine, or law. As a result, many must undertake additional education, such as university courses, apprenticeships, or advanced training.

Informal skills acquired through practical experience in professions like carpentry or plumbing are generally not recognized in Germany. Since these jobs often do not require certification in other countries, skilled workers may struggle to meet German requirements, which include language proficiency and formal training. This makes returning to their profession particularly challenging for experienced individuals unaccustomed to formal education systems.

SIM cards and phone data privacy

Buying SIM cards has become increasingly restrictive since 2017, as it now requires individuals to show a valid form of ID. This change has particularly impacted undocumented migrants, restricting their access to SIM cards. As smartphones are one of the primary channels of communication to their families and community back home, the impacts of having restricted access are more than just an inconvenience. The shift limits the independence previously associated with easily obtaining a SIM card without bureaucratic barriers.

“When I came to Germany, we didn’t need to register your SIM card. That’s independence. So now you start registering the SIM card, to put the address, all these kinds of things. Now most of the people who don’t have papers, don’t buy a registered SIM card. That means they always change their number. They no longer have that independence of just going to the place, you register your PIN and you just get the number, you know.”
—Parent visa_2000

Most work visa or Blue Card holders did not report any particular challenges registering for a SIM card. Both Ukrainian participants got SIM cards in Europe, but decided to continue to use their Ukrainian numbers and services, since they are also cheaper than German/European providers.

Language and integration courses

For those seeking protection or who have received protection in Germany, access to state-funded integration courses (which constitute both language courses and “orientation” courses) are mediated by BAMF. Access is prioritized according to country of origin and legal status.

“We arrived to apply to an integration course. Without even opening our envelope, he asked, ‘Where are you from?’ ‘From [country of origin].’ And he said, ‘People from [country of origin] have less access.’ So you don’t have an opportunity for an integration course. My [country of origin] is classified as a safe country. So there’s priority given to other countries. This was when it was clear to me that even in an integration course there is a bias to say who’s eligible and not. When I became regularized, I remember, they put on my passport, it said ‘Verpflichtet zur Integrationskurs.’ 142 This was crazy. It was written on my visa. So you would see that it was literally that I am obliged to take an integration course.”
—Citizen_2014

Such differential access to the courses has a significant impact on migrants, as delays in starting courses lead to increased communication issues, delays in pursuing education, delays in finding employment, among other consequences. Moreover, sufficient German language knowledge is required to be eligible to apply for a permanent residence permit and German citizenship.

Access to financial services

Access to digital banking can be restricted based on the kind of documents one receives. Some migrants spoke about not being able to open bank accounts in two different neobanks 143 which are frequently used by migrants, since they can be opened online. While for a “Bank A” account you still need an Anmeldung, you can open a “Bank B” account without it, and getting an Anmeldung can at times be very challenging for newcomers to the city. However, one is required to scan an ID document to open a bank account through these services. Some migrants faced difficulties registering for digital banking services because the systems did not recognize the sticker in their passport as valid identification, requiring additional steps and delays.

“I really don’t know if I’m planning to return here or not because it’s hard to predict right now what will happen. And so from what I understood based on my answer, the person who I was talking to, she decided to provide me not with the plastic, like a permanent resident, but the visa sticker in the passport. Which is not a big deal, but sometimes it becomes [a problem] when I do something for some digital procedure, this plastic sticker is not recognized by some banks. So then I have to go through a more complicated, longer procedures with letters and emails.”
—Special protection_2023

Migrants who are in the process of seeking asylum in Germany can be restricted in their access to online banking services.

“When you’re in the asylum system, you’re not free, you’re not free to choose by yourself. The Sozialamt will control all these things. So this would bring us the digital thing, they control all the digital of you. So you’re not even allowed to have your online banking. You can have a Sparkasse account, but you’re not allowed to have online banking.”
—Citizen_2014

Some asylum seekers who received a temporary ID document reported that, while they were able to open a bank account at Sparkasse Bank with this ID document, their peers with the same status were rejected at the same bank.

Another challenge with accessing financial services for migrants relates to how administrative processes in Germany are tied to one another in a cycle. For instance, this manifests in the relation between having a bank account and having insurance, or having a bank account and having an Anmeldung/housing.

“My problem was that I couldn’t apply for my residence permit without having insurance. And I couldn’t have insurance without a bank account. And I couldn’t open a bank account because I don’t have insurance. It was a disaster, and I had to go from bank to bank to figure out which one can open an account for me without insurance. It was annoying.”
—Work visa_2021b

“You need an Anmeldung [to open a bank account]. And of course, finding a house when you don’t have a bank account or a job [is not possible]. Really, this all contradicts each other!”
—Freelance visa_2020

Limiting access to financial services is also at times employed to exert control over migrants. For example, in 2023, Germany decided to introduce the Bezahlkarte für Geflüchtete 144 —a payment card for asylum seekers and those with Duldung status. Rather than receiving cash payments, in some municipalities asylum seekers are provided with this debit card. The Bezahlkarte für Geflüchtete has been critiqued, as it aims to control how asylum seekers spend the little financial support they receive from the government. For example, through this system in some cases cash payments abroad are no longer possible. In the municipality of Märkisch-Oderland, the stated intent of this debit card system was to “create a deterrent effect” and reduce migration to Germany. 145 In Hamburg, an initiative led by migrants “No to the payment card!” called for asylum seekers who received this debit card to buy vouchers in major stores and exchange these for cash. 146 However, the application of this payment card is uneven across Germany: for example in Hannover the same payment scheme for asylum seekers and Duldung holders is framed as a SocialCard. The SocialCard in Hannover allows for financial autonomy, as it’s possible to make both card payments and cash withdrawals, and there’s no state control over how funds are spent. 147 This might cause some confusion, since this SocialCard in Hannover is also a Bezahlkarte as in Hamburg, but with very different implementations and effects for those receiving this social benefit.

While the use of a Bezahlkarte or SocialCard did not come up in interviews, as it has not yet been implemented in Berlin, it is relevant when considering the limitations regarding access to financial services as an asylum seeker in Germany.

Discrimination also occurs when opening banking accounts. This can manifest in inconsistent and culturally insensitive requirements, leading to frustration and exclusion. For example, one individual described being asked to provide an Anmeldung from their apartment in their country of origin—a document that does not exist in their home country. This demand was not only confusing but distressing, causing the individual to abandon the process entirely in tears. In contrast, when they later sought assistance at another bank, where they specifically requested an English-speaking staff member, the process was smooth, and no unnecessary or inappropriate documentation was required. However, even in this case, limitations remained, such as being issued a bank card unsuitable for online purchases, highlighting inequities in access to certain services.

Some financial services, such as the possibility of payment by installment, are often not available for migrants. It is not clear in this case whether payment by installment was not available for all on a temporary residence permit or only for some:

“I went to [a shop] to buy a phone. And there was an offer to pay by installments with zero interest rate. When I went to the counter, they asked me for my passport and residence permit, and then they told me that my application was rejected. So I told them that I have money, so what is the issue? They said: ‘Honestly, it’s not about the money, it’s about your ID card.’ So basically as a foreigner, without a blue card, good luck with buying things by instalment. It’s not for people like me.”
—Freelance visa_2020

Access to credit is limited based on legal status, and this can have far-reaching consequences for migrants trying to build a life in Germany.

“At my salary level, I would be considered a top [earner] in Germany, right? But still, I don’t have access to certain financial services. I have a bank account, but I went to apply for a credit card—a real credit card, not a prepaid one. And they didn’t give it to me. They just told me, ‘Well, you don’t have permanent residence or you’re not a national.’ And that, for example, is a disadvantage, isn’t it? If I really wanted to have a real life in Germany, for example, buy a car in this country or take out a mortgage on a house or whatever, I can’t do that.”
—Freelance visa_2017

Access to mobility

The Berlin Brandenburg airport website asks travelers to “make sure [they] know which identity documents are required, according to [their] destination.” 148 This is not as straightforward as it might seem. Based on the experiences of research participants, it is not clear which identification documents migrants should carry when traveling inside the EU. Some report being asked for the residence card only, while others have been asked to show their passports. One participant was refused to board the plane on a flight to Italy, for instance, because they didn’t carry their passport. As a strategy, some migrants always take their passport when traveling.

In recent months, a new automatic passport control system called EasyPass was put in place at the Berlin Brandenburg airport. Most research participants have never tried using this service. A few of those interviewed, with a valid residence permit, have tried Easypass and shared that it rarely worked.

“Have you tried it? I tried it so many times, like six or seven times. It only worked once. And it has nothing to do with my passport, because you scan the ID [residence title]. I find [the service] to be useful, but it has only worked once. I stopped trying, because when it doesn’t work out, I have to stand in line again for the ‘human’ passport control, and I miss my spot in the queue.”
—Blue card_2022

Some participants referred to the limitation to traveling outside of Germany or the EU based on the expiration date of their documents—not their status but the documents themselves. For example, a residence permit may be valid for three years, but the ID document expires on a yearly basis, creating additional costs and stress and limiting their mobility.

“Every time I renew it, but it’s absolutely unnecessary because I have to make an appointment at the Ausländerbehörde to do the same process. I mean, it’s not even like you mail it in and you get your new ID back. You have to make an appointment and you have to say ‘I need this renewed’ and they are going to renew it now. It is not an interview procedure or anything like that. But if I am traveling and this document expires—not the permit, not the period of residence, but the document—if this document expires, I might have problems when entering the country at the border office.”
—Freelance visa_2017

This challenge can be linked with another mentioned earlier, the requirement that some migrants, namely some of those who have subsidiary protection, to have a valid national passport. One participant with subsidiary protection told the researchers that they refused to be forced to renew their passport at their origin country’s embassy. When asked how that impacted their mobility, they said that they could move freely in Germany with their residence card and expired passport, but they could not travel outside of the country without a valid national passport accompanying the residence card. Additionally, to retain their status migrants cannot be outside of Germany for more than six months.

These challenges highlight the complex and often fragmented identification landscape that migrants must navigate in Germany. They include both cross-cutting barriers that affect access to rights and services throughout a person’s stay, as well as specific issues tied to housing, healthcare, social benefits, education, SIM cards, language and integration courses, and mobility. Understanding these existing difficulties is crucial: efforts to digitize identification—such as the introduction of the EUDI Wallet—must be informed by the lived experiences of those most affected. If not carefully designed, digital identification systems risk reinforcing or deepening existing inequalities. However, they also hold the potential to alleviate some of these challenges—if inclusivity and accessibility are prioritized from the outset. Drawing on the key issues identified in this section, the recommendations presented in this report aim to ensure that digital identity initiatives promote rather than hinder equitable access.

Insights from practitioners in the digital identity sector

Where are we headed?

The establishment of the new Federal Ministry for Digital Transformation and Government Modernisation (BMDS) makes this an interesting time to evaluate the future potential of the EUDI Wallet, consider its inclusivity, and address any potential challenges to its implementation. When this research began, responsibility for the German project to implement the EUDI Wallet lay with the Ministry of the Interior (BMI). However, it is now the responsibility of the BMDS. In the short time that the new ministry has existed, the EUDI Wallet has already played a prominent role in outlining Germany’s future vision with this new ministry and its new emphasis on digitalization. These developments are bringing new impetus to the EUDI Wallet project and to the goal of digitalization and state modernization in Germany overall.

Interviews with experts demonstrate that previous attempts to digitalize the German public sector and bureaucracy have lacked strategic vision and high-level political commitment. Interviewees acknowledged that, in theory, digitalization has long moved to the top of the political agenda in Germany, and that, as a consequence, related topics such as digital identities are gaining traction beyond the designated expert community. As previously mentioned, digital identities and registry modernization already were key projects in the digital strategy of the previous German government under Olaf Scholz. However, as one interviewee pointed out, such policy commitments risk being seen as empty promises if they are not followed by concrete and visible actions, leading to a sense of “disenchantment with politics.”

“Legislative processes are all well and good, but it still needs some kind of publicity campaign [showing that] it’s still important to us, this idea of infrastructure. That it really needs to be promoted like a road and repaired again and again. And again and again. Yes, we just have to keep working on it. And that’s not the case at all with digital identities and the whole issue. It always falls behind.”
—Science & Research_6

In this context, the same interviewee criticized the decision to stop offering the postal option for PIN reset and activation (PIN Rücksetzdienst) for the eID, describing it as a step backwards:

“And then, of course, there are always steps backwards, as is now the case with the PIN Rücksetzdienst, which has been discontinued. And these are factors that make you think, okay, why are you putting so much time and energy into this?”
—Science & Research_6

Access to the German eID infrastructure currently is a prerequisite for accessing all functionalities of the German National Wallet, but, as mentioned before, usage figures for eID are comparatively low. Therefore, the decision to reverse such an investment, which would reduce access barriers, suggests that digital identities are not being prioritized as previously promised. At the very least, this decision raises questions about whether there is a vision or action plan at all for addressing deficits in this area, despite tight budgets. One interviewee specifically addressed the question of funding:

“We have zero euros for the operation. We are currently developing a wallet that we cannot operate at a federal level. And the mindset is changing very, very slowly.”
—Business & Industry_1

As the same interviewee pointed out, in 2024, financing for the development and implementation of the German National Wallet was coming from EU funds. At this point, there was no clear indication how the operation would be financed in the future, or what economic benefits stakeholders in the ecosystem can expect after the application is launched. The experts interviewed agreed that such uncertainties could threaten the overall success of eIDAS 2.0 and the EUDI Wallet. On one hand, the EUDI Wallet is seen as an opportunity to streamline Germany’s fragmented digital identity landscape, where various cross-sector and sector-specific identification methods coexist, but are not interoperable and offer different levels of security and privacy. However, concerns were raised that the German National Wallet could fail to meet growing expectations precisely because it is currently only one of several (planned) digital identification methods and there is no guarantee for its success:

“Once again, a new means of identification is being added with the wallet and the others are simply being left standing […] this whole list, online ID function, PostIdent, ELSTER and then the wallet is to be added […] We can’t be serious, we’re simply building yet another new solution and not with the aim of replacing the others.”
—Science & Research_6

Without a functioning ecosystem providing different services, and if EUDI Wallets remain just one identification solution among many, experts expect it to be less likely that users will see the application as an asset in their everyday lives and adopt it. However, without a large user base, businesses will be most likely less inclined to adapt to the application. In order to overcome this chicken-and-egg problem, targeted measures must be taken to ensure technical functionality and added value.

In the coming years, it remains to be seen what stance Karsten Wildberger, head of the newly established BMDS and former CEO of Ceconomy AG and Managing Director of Media-Saturn-Holding, will take on the topic of the EUDI Wallet. In his first speech to parliament, he said: “The establishment of this ministry is more than just an administrative act; it is an important decision for the future of our country. It is about creating a modern, digital Germany with efficient processes and administration.” 149 His vision for the “digital next Germany” that he described to parliament suggests that the EUDI Wallet is to become a central component of Germany’s “new digital foundation,” an outlook that he has repeated at other public functions. 150 These latest developments demonstrate that the EUDI Wallet is embedded in a dynamic context. The establishment of the new ministry and the new minister’s apparent enthusiasm for the EUDI Wallet could open up a window of opportunity within Germany’s complex, traditionally slow and cumbersome structures, particularly given the growing global interest in digital identity wallets and the potential for Germany to establish itself as a leader in this field.

Although the EUDI Wallet has gained new political momentum, rising expectations of its potential to accelerate Germany’s digital transformation, unresolved issues regarding funding, interoperability and long-term adoption continue to cast doubt on its ability to deliver on these promises. In the face of such uncertainties, research suggests that public participation and collaboration processes between the government, industry and civil society can play a critical role in fostering trust and establishing the foundations for sustainable and inclusive transformation processes. 151

The “identity bubble”: Too exclusive to be inclusive?

Participatory approaches, well known from wind energy and other infrastructure planning projects, can help to bolster public acceptance. However, research suggests that “simply inviting people to participate” in planning and development processes is no guarantee that different public perspectives, values, and concerns will be successfully represented. 152

The architecture and consultation process for the development of the German National Wallet and the EUDI ecosystem is iterative and offers several ways for the private sector and the public to engage with the project and provide feedback. On one hand, all architecture proposals (current and previous versions) are available online and open for comments. The German project team is also organizing a variety of engagement formats such as Open Online Consultations, workshops, and working groups on specific topics (e.g., use cases, privacy and data protection, wallet ecosystem, etc.). Additionally, the team is coordinating the Funke EUDI Wallet Prototype innovation challenge that started in spring 2024. Alongside the EU Large-scale Pilots currently being coordinated by various consortia and implemented across Member States, each workstream is expected to generate ideas and insights that will inform the overall development process in Germany. This approach was positively highlighted by several interviewees.

“Then it was decided that the eIDAS regulation should now be revised, that there should be a so-called EU digital identity wallet […] and since then a lot has happened in Germany. You have this consultation process at the operational level and also in dialogue with civil society and so on. I think that is in principle very good, and I think that only a few Member States do the same, that they deal with the issue in this way.
—Business & Industry_3

“In general, those that were involved, they were super motivated to have this open, it’s a super transparent process.”
—Science & Research_7

At the same time, interviewees feel that the consultation process has so far had limited success in bringing a diversity of voices into the conversation. Since the EUDI Wallet is still in development, there are more opportunities to provide input at this early stage. However, it is more challenging for individuals lacking specific knowledge on this topic to participate. Additionally, participating in public engagement formats is resource intensive. This may explain why business and industry stakeholders have been more involved than civil society and local government representatives:

“So, the consultation process—I would say, without having an exact figure, that 85% of those involved are [private] companies.”
—Business & Industry_1

“In these you also have to see who is able to participate there. These are organizations that have the money, and that have incentives and have money to be a part of that. So what I have seen is that it is mainly profit-driven organizations that participate there, so lobbyists from industry, which also makes sense because they have to build it [the Wallet ecosystem]. But it would have been nice to get a broader range of civil society in there. Just because something is open for everyone, it doesn’t mean that everyone can afford to participate.”
Science & Research_7

“Where I think there is sometimes still a need for coordination is the involvement of the municipalities. In my opinion, they are not yet strongly represented.”
—Business & Industry_3

However, although digital identity wallets are often described as user-centric, a truly user-centric design needs to consider the needs, concerns and interests of a diverse range of end users from the outset of the technological development process. As one interviewee argued:

“Technical aspects are super important. But so are these nontechnical aspects and user experience. And I see, especially for the EU digital wallet, you can say a lot. But to live up to your words is important. And from my experience, you do not fulfill the goal of user-centricity if you don’t include the user from the beginning.”
—Science & Research_8

According to another interviewee, “inclusivity [of the EUDI Wallet] has not been prioritised in any way”:

“It’s really always the last thing to be digitalised as an add-on. And it’s kind of stupid that it always comes to mind afterwards: Oh yeah, that’s right, we should do that. But it’s actually something that should always be considered in parallel.”
–Science & Research_6

In theory, public engagement can help align and enrich technological design processes. However, the success of this approach depends on how effectively it incorporates a variety of voices. The German architecture and consultation process for the German National Wallet is heavily influenced by the participation of private companies. At the same time, the “identity bubble,” as the digital identity industry was referred to repeatedly by interviewees, was said to lack diversity. This poses a challenge for inclusive design and demonstrates the need for more effective involvement of civil society in such processes, particularly organizations and movements advocating for and led by marginalized groups and individuals.

Migrants’ concerns about digitalization

Data protection and location tracking

When a researcher told one participant about the existing eID app, they were very excited and wanted to try it right away. When they tried to download the app on their phone, they discovered that the app requires access to the device, which discouraged them from continuing the process. This situation illustrates fear, that some participants expressed, for their privacy. A similar concern was raised regarding increased state control if the digitalization would allow for accessing location services.

“When it comes to migration, it can also be a mechanism to control people’s data, which is also sensitive to me. I don’t know if I would even be willing to give my information to this digital wallet freely, if I am for example in this kind of threat to be deported or give my data to authorities. It gives me mixed feelings about the whole setting. As a privileged migrant, I will be fine to have everything here.”
—Citizen_2014

One participant shared that they felt great risk of having such an important and personal feature on their phone, as they fear that someone could access their personal data if their mobile phone is hacked or stolen.

“I don’t have the eID app. I’m too afraid of getting hacked and then they would know everything about me. I have information about my address, my banking numbers, and everything on my phone. It would be a disaster if my phone was hacked.”
—Citizenship_2017

In general, interviewees expressed clear concerns about the potential for data breaches by individuals or groups, as well as increased surveillance by the German state—particularly in light of recent political developments that have heightened fears around restrictions on freedom of movement, expression, and protest. These concerns were especially present among those with precarious legal status or past experiences of state repression. In addition, the researchers emphasize that surveillance and data access by home country governments—especially for people fleeing persecution and political refugees—represent an equally serious and often overlooked risk.

For many, the idea of storing sensitive personal data in a digital identity system raises fears not only about privacy but also about safety and political vulnerability across borders.

Validity of physical documents over digital ones

Participants were asked about their experiences with other digital apps. Particularly, many praised the insurance application, describing it as practical, easy to use, and time-saving. Other apps mentioned included those used for banking, payments, and public transportation services. That said, even when they have the apps on their phone, participants generally report that they still carry the physical cards when available, particularly bank and insurance cards.

Gaps in AI-driven decision-making

As reported by one participant, increasing reliance on AI-driven tools in migration and identification processes may lead to exclusionary outcomes. These systems often lack the flexibility to accurately interpret diverse document formats and contexts, particularly those originating from the Global South. Without human oversight or mechanisms to override AI-generated errors, such tools risk replicating or even deepening the systemic barriers migrants already face:

“There needs to be a lot of care with applications of AI that can be used to make critical decisions with this type of digital information. For example, in [country of origin] our documents are very beautifully [designed]. But if this document goes through a German AI reader [maybe] my paper will not be read as valid. So let’s say, you scan your passport, and it tells you it is not valid because of XYZ, and if they are not going to have someone standing next to them who can override this, they are going to leave people in the same situation they are in now, where people are waiting to get an appointment and no one is able to get an appointment.”
—Work visa_2021a

These legal and procedural gaps—where systems are designed to function in a certain way but fail to do so in practice—are at the heart of the concern. The fear is that digitalization will be seen as a fix-all solution, when in reality it often masks rather than resolves the structural issues migrants face.

Digital tools, especially those driven by AI, may improve surface-level efficiency, but they cannot replace the need for systemic reform. When confronting the underlying inequalities and institutional gaps embedded in public services, digitalization risks entrenching the very problems it aims to solve.

Deepening exclusion through digitalization

A participant who has long been an advocate for the migrant community in Berlin expressed concern about the possibility for digitalization to perpetuate existing systemic forms of exclusion of migrants rather than address needs based on their lived experiences, despite their being a rich history of migrant self-organization in Germany and Berlin.

Confusion about existing eID services

Many interviewees did not know about AusweisApp prior to the interviews. One participant, an EU Blue Card holder, described a letter that they received in the post a few days before they were sent their residence card for the first time:

“And this was very weird. I received something in the post that I needed to activate but I just didn’t understand. This e-thing. It was the vaguest thing ever. You receive a letter by post. They call it an ‘electronic card.’ I thought that they meant that I would receive a card with a chip. I waited and waited. They don’t explain. It’s very weird. I didn’t really think that it’s an online thing. I thought it was a card with a chip. Is it? [The researcher explains]. What?! Wow. I didn’t know about this. I thought it would be some card that you would tap. But also there was some drawing on the letter that looked like a card that you tap … Which app is it? Let me try to download it.”
—Blue card_2022

Only a few knew about the online ID app. Some could not understand how to activate it. Others found the activation process too lengthy and complicated.

“First, I received via post a letter that said something like a PIN and a chip and a card or something like that. I remember when I looked at it, I put it on Google Translate at that stage, obviously, I had just arrived. I didn’t speak any German. Even when it was translated, it was such weird language. So I thought that they were telling me that I will receive my card, but there will be a chip in it. I didn’t get it, actually. Afterwards, they sent me the residence card. And then they sent some sort of a PIN also. I asked a friend who was here a bit before me, and he told me what this was. Then he explained that this was for the eID, so I downloaded the app and I tried to actually make it work, but I never was able to make it work.”
—Student_2021

“They also sent me this thing about the electronic residency, which I never used, and is too complicated. I tried to use it and did not find it user-friendly. It’s a disaster. The first time I checked it, I didn’t even want to use it. It has a lot of bureaucracy, a lot of steps that need to be done, and it is not clear what they require from us.”
—Work visa_2021b

There is, additionally, no clarity whatsoever regarding the use of the eID service—What services can be accessed through the eID service? This coupled with the all-too-complicated process of activating an eID make the eID neither useful nor relevant for migrants.

“It is really unnecessary. No, I do not need it. And they never asked me for it anywhere either, right? If I receive an identity document that has digital capability, the minimum I would expect to receive in that letter with that document stating these are the services that you can access using this card. But I don’t have the slightest idea what it would be useful for me to activate this eID, for example. It hasn’t been of any use to me. I haven’t used it at all. I couldn’t install it, so I don’t care, right? I don’t see the value of this service.”
—Freelance visa_2017

The case for digitalization from migrants’ perspectives

While digitalization is often discussed in abstract or technical terms, this section foregrounds the lived experiences of migrants to explore what a meaningful digital identity system could look like in practice. Migrants interviewed in this study expressed both optimism and practical insight about how digital tools could simplify everyday interactions with the state and reduce systemic inequalities.

Migrants report positive experiences with other service apps

Most migrants interviewees use at least one digital app for essential services, most commonly for banking and public transportation. A few more privileged migrants mentioned apps for insurance and the wallet for payments. More digitally literate participants report having used a video identification system to open an online bank account.

“The video option was pretty easy. It tells you what to do, how to carry your passport… and somebody calls you in case there’s an issue. It was really cool. You need to point to certain areas in your visa or residence card. I really loved it because it is such a change, having dealt with Germany’s bureaucracy.”
—Freelance visa_2020

Because they have experience using apps to access services, migrants would be able to adapt to digital innovations in this space; and already existing apps might provide useful guidelines for creating a digital ID wallet.

Streamlined processes and enhanced efficiency

According to interviewees, digitalization may enhance communication and reduce waiting times and delays. Paperwork leads to administrative delays, especially when paperwork must be sent from one state or city to another, which could be reduced through the digitalization of documents.

“Online, things would have been easier and faster. Why should I go and wait in line for five hours when I can actually scan the documents and send them by email? Why should I wait for important documents to arrive by post when they can communicate with me by email?”
—Asylum applicant_2021a

“There were so many delays at the time, especially when you arrive in Cologne, for example, and then apply to Berlin, it used to take a very long time for your papers to arrive from one city to the other.”
—Citizen_2017

Improved document security

There is a risk of physical documents being lost in non-digital procedures. Migrants fear that their physical ID documents would be lost when handed to the authorities.

“I remember being told by people that I shouldn’t hand in my passport until I got an appointment at the BAMF. Because if you provide your passport during the first interview at the LAGeSo, they might lose it. And it has happened before.”
—Citizenship_2017

This risk is even greater in cases where information is only available to people by paper, as is the case with the tax ID.

“Everything that is sent by post is a safety hazard, because you don’t know where the information is. What if you lose the paper? And if you lose it, how do you find it? And if you move apartments …”
—Work visa_2021b

Digitalization may minimize the risk of physical identification documents being damaged. Some identification documents given to more precarious migrants are very fragile, such as the Fiktionsbescheinigung (temporary residence confirmation), Ankunftsnachweis (certificate of registration as an asylum seeker), Aufenthaltsgestattung (temporary residence permit for asylum seekers) or Zusatzblatt (the supplement ID document), which is just a piece of loose paper. Some migrants have had these documents for many years. 153

Minimizing inequalities and differential treatment

Digital systems can standardize procedures and reduce discrepancies in treatment across different migrant categories and neighborhoods. Participants report a difference in treatment between refugees and other migrants at relevant immigration offices.

“The Ausländerbehörde for freelancers is in the same location as the one for refugees, but it’s a different entrance. A friend who is a refugee told me what he went through and I realized that it’s completely different from what I experience. I go in a heated building, I sit down, I wait for my number to appear, I go to an office, I have all this. Whereas they had to go and stand in line for hours outside in the cold.”
—Freelance visa_2020

Participants also report a difference in treatment between those who are granted an EU Blue Card and work permit holders. The following quote came as a result of a conversation between a Blue Card holder and a work residence permit holder when one of the two was being interviewed:

“There is another very indicative example which shows you the difference between how different groups are treated. If you have a Blue Card to pick up, you can pick it up whenever you want. They tell you that you feel free to come starting a certain date and do not impose a specific time or appointment. With the work permit, you have a very specific appointment. You have to be there at a very specific time, and be careful not to be late by a minute!”
—Work visa_2021b

Some participants reported experiencing different administrative treatment depending on the neighborhood where the administration was located in Berlin. That said, reports were contradictory, which may lead one to think that it is rather a difference between different bureaucrats rather than neighborhoods.

“I did [an Anmeldung] three times. The first two times, they spoke to me in German, of course. Last time, [during my appointment in Neukölln where I moved], the employee spoke to me in English, and he asked me why my residency card wasn’t updated to my last address. I told him that in my last appointment in Mitte they just didn’t do it for me. So he said that he would definitely do it. I don’t know if he did it because he was being nice, or if he had to do it as part of the appointment, which the other employee in Mitte failed to do.”
—Work visa_2021b

Cost reduction for migrants

Digitalization is expected to reduce the cost of obtaining residence permits and acquiring identification documents, given that it requires less bureaucracy and it may reduce the need to hire lawyers or third-party services for routine processes.

Enhanced inclusivity and language justice

Increased language justice might be approached through digitalization by making documents available in many languages and increasing accessibility for non-German speakers.

“If it’s going to be digital, then it can be in many languages. If things are in German, there has to be a translator that shows it to you in Russian, Turkish, whatever. If they are going to digitize it, then it needs to be inclusive in a way that understands that we all come from different countries.”
—Work visa_2021a

Language was indeed the one issue mentioned in all interviews. Currently, German authorities generally refrain from providing translations of official documents, citing concerns such as legal liability and the binding nature of non-German texts. However, digitalization offers an opportunity to present documents in multiple languages to enhance user comprehension, while maintaining the German version as the legally binding reference.

Migrants’ reflections show that digitalization holds real promise—if done right. Digital innovation cannot be detached from social realities; For migrants, usability is not just a technical feature—it is about language justice, data protection, affordability, and equitable treatment. Their input makes clear that successful digital systems must be grounded in their everyday experiences. A user-centric design is therefore not optional, but essential: only by building with migrants, not just for them, can digital identity solutions truly support inclusion and justice.

Conclusions and recommendations

Digitalization offers significant potential to transform migrants’ everyday lives and their access to essential rights and services, promising faster processes, enhanced security, reduced costs, greater inclusivity and equality, and a reduction in disparities. For migrants navigating a bureaucratic landscape riddled with complexity, delays, and risks of discrimination, strategic investments in digital infrastructure and user-centric design could create fairer and more accessible systems.

However, digitalization of government and administration must contend with inherent tensions and broader systemic inequalities, in particular where digitalization efforts overlap with the realities of contemporary migration governance and global borders.

In Germany, access to everyday necessities and basic services (banking, housing, healthcare, SIM cards, etc.) is becoming increasingly difficult for people who do not meet official identification requirements. Even for those who have the required documentation, access is complicated and fraught with obstacles. For the ongoing transformation of the German identity ecosystem, these challenges must be taken as a starting point to not merely digitize existing requirements and procedures, but to use digitalization as an opportunity to improve them.

In order for non-EU migrants to access all functionalities of the EUDI Wallet, specifically PID issuance, they must be in possession of an electronic identification document issued by an EU Member State. Any obstacle to the acquisition of such a means risks excluding people from potential benefits of the EUDI Wallet. As this report shows, for individuals who are citizens of non-EU countries, these pathways to inclusion can be of varying complexity, depending in particular on their legal status and country of origin. This means that people without a valid passport or other internationally recognized proof of identity face different barriers to inclusion than people arriving in Germany on a work visa. But in each case, onboarding to an EUDI Wallet would be predicated on a completely different user journey than for people with German citizenship or citizens of other EU Member States. Going forward, it cannot be overstated how important it is to consider the interconnectedness of identification requirements and all aspects of life, and how introductions and changes in one area can have consequences elsewhere, not least for those who cannot or do not wish to use a product such as the EUDI Wallet.

Balancing risks and opportunities

Digitalization is expected to change things for the better. In Germany, where the country is perceived as lagging behind, there is increasing pressure to modernize in particular ways—from the EU, the private sector, civil society and the general population. The EUDI Wallet offers potential benefits for people with and without a migration status alike, such as reducing waiting and queuing times, reducing reliance on physical documents, standardizing data-sharing procedures, and introducing thresholds for how much data can be requested for access to certain products and services. But it also raises concerns about data security and surveillance.

The findings of this research suggest that governments’ digital identification efforts are being associated with other digital technologies that enable new forms of data collections, AI-assisted analysis, and geolocation tracking, and thus risk being perceived as tools of control rather than empowerment, particularly for precarious migrants such as asylum seekers, Duldung holders, and undocumented individuals. These groups highlight the limitations of digitalization in addressing structural inequalities related to borders and migration governance, but also point to how other marginalized and underserved communities may relate to the EUDI Wallet, and digital identity innovations more broadly.

To ensure meaningful inclusion, it is crucial to recognize the knowledge networks and navigational strategies through which different communities, such as migrants, already make sense of and engage with bureaucratic systems.

Migrants often rely on experience-based knowledge shared within their communities to navigate bureaucratic systems, reflecting a deep mistrust of official processes. Digitalization alone cannot replace these solidarity networks, but it can complement them by providing clearer, more consistent, and accessible information. Multilingual digital tools designed to meet diverse needs could bridge the gap between official information and lived realities. Moreover, recourse mechanisms and training sessions may support migrants in raising awareness about the tools and facilitating their use.

Digitalization can also mitigate the risks of everyday racism and discrimination in face-to-face interactions with bureaucrats, which this report suggests are significant factors shaping migrants’ interactions with authorities and other intermediaries. However, it also removes the potential for positive, discretionary interventions by empathetic bureaucrats who may facilitate processes out of goodwill. Striking a balance between reducing the risks of bias and maintaining the human flexibility to address unique circumstances is a critical challenge.

Whether the tension between potential benefits and risks can be resolved will depend, on one hand, on whether and how specific wallet design features are implemented (e.g., mandatory relying party registration). On the other hand, to resolve this tension, more structural issues will also need to be addressed.

Everyday inequalities persist

Digital technologies do not inherently dismantle the inequalities embedded in broader migration processes and might, in fact, reproduce or exacerbate them. More privileged migrants—those with financial resources, social connections, or higher digital literacy—are better positioned to navigate and benefit from digital innovations. The existing cross-cutting challenges highlight vulnerabilities for precarious migrants, including asylum seekers and Duldung holders—and these challenges need to be addressed in order to create a more equitable migration system.

Notably, digitalization was not a priority for all migrant groups. Some EU Blue Card holders and Ukrainian protection holders talked confidently about potential benefits in digital identity tools. But asylum seekers, Duldung holders, and other migrants facing systemic barriers prioritized more immediate concerns such as discrimination in accessing rights. Many among these groups expressed skepticism about digitalization, seeing it as a tool that does not serve “people like me.” This reluctance suggests that digital identity initiatives must be considered within a broader framework of social and legal inclusion, rather than as a standalone solution.

Whose voices shape digitalization

Interviews with government stakeholders and digital identity experts revealed high hopes for the EUDI Wallet and the future of the German identity ecosystem. If, however, this project is not embraced as a political priority and a strategic cornerstone for Germany’s digitalization efforts in the public sector and beyond, it could end up being just one more digital identification option in a fragmented landscape of disconnected digital identification practices. Germany’s decision to develop the German National Wallet through a participatory architecture and consultation process is generally seen as a positive step toward including more voices in the implementation of eIDAS 2.0. However, this report shows that civil society, and in particular marginalized and underserved communities, including migrants, remain underrepresented in this process at this stage.

From a user-centered design perspective, the needs, expectations, and perspectives of users need to be at the heart of the entire development process—and from the very beginning. This is, of course, a complex undertaking for a project that aims to transform the German identity ecosystem and the daily lives of millions of people, businesses, and institutions. Without a concerted effort to bring everyone to the table, the EUDI Wallet risks becoming disconnected from practical needs and concerns of different user groups and stakeholders, including migrants, as well as local municipalities, administrative staff, and other issuers and relying parties, and may end up having unintended consequences, bringing uneven benefits, or being divorced from everyday realities altogether.

Recommendations

These recommendations fall into three categories:

1. Those specific to the EUDI Wallet and ensuring inclusivity of digital identity innovation
2. Those addressing broader issues of public sector digitalization and the use of digital technologies in the area of migration and asylum
3. Those addressing the intersection of social policy with digital identity innovation and public sector digitalization

These three sets of recommendations provide both specific guidance on how to include the lived experiences of migrants from outside the EU into Germany’s ongoing efforts to implement eIDAS 2.0, and a more comprehensive picture of the larger structural issues that influence how migrants relate to the German identity ecosystem—and, if these structural issues persist, that are likely to continue to do so in the future. Taken together, they are a starting point for ensuring that digital identification practices do not deepen existing inequalities, but instead contribute to building fairer and more inclusive societies for all.

For the EUDI Wallet

Existing research on the usability and user experience of digital identity wallets shows that actively involving users and requiring their consent for data sharing does not automatically mean that these wallets are user-friendly. 154 These studies also highlight the important lessons to be learned from user-centered design, an approach that prioritizes users’ needs, expectations, and perspectives throughout the whole development process. 155

These recommendations build on these earlier findings, but also take into account that migrants from outside the EU and the specific scenarios they face have not featured prominently in discussions about the accessibility and inclusivity of the EUDI Wallet, either in academia or policy. So who are the “users” in “user-friendly” or implementing “user-centered design” processes? The following recommendations speak to the need to look beyond the standard use cases and user groups. In this sense, these recommendations are relevant not only for better representation of non-EU migrants in the development of the EUDI Wallet, but also for identifying where points of friction and exclusion might arise for other marginalized groups, and how to address them.

Ensure transparency through multilingual communication.

• Provide clear information in as many languages as possible about the design of the EUDI Wallet and how its features, any risks and/or limitations compare to other available digital identification options, including other non-EUDI wallets.
• Provide a variety of information and assistance formats (e.g., video tutorials, FAQs, helpdesk etc.) in as many languages as possible.

Increase trustworthiness by limiting the risk of “oversharing.”

• Implement (mandatory) relying party registration certificates and a corresponding registry, especially for entities that access the data of individuals who are more likely to find themselves in vulnerable positions, such as migrants.
• Translate relying party registration requirements and certificates into clear visual cues (e.g., a green tick next to the name of the relying party on the wallet user interface, meaning that the organization is registered to ask for the most sensitive data).
• Implement clear visual cues that help users determine what is appropriate data to be shared for a specific service (e.g., red “X” on the wallet user interface when a data request is received from a relying party that is not authorized to request the corresponding data).

Invest in wallet interoperability and ensure data portability beyond the eIDAS ecosystem.

• Develop both an overall and sector-specific strategies for the international use and acceptance of digital credentials (e.g., develop strategy for the use and acceptance of digital credentials in the education sector, including non-EU education institutions and other learning environments).
• Ensure that users can transfer accounts and credentials (transfer the same digital identity wallet to another mobile device or to switch to digital identity wallets from other vendors/governments) to avoid any kind of lock-in scenario.

Consciously address biases and limitations in digital identity wallet design.

• Include potential users and their needs, expectations, and perspectives throughout the whole development process, making a conscious effort to look beyond standard use cases and engage with a variety of potential user groups.
• Build on existing user-centered design research methods, assessing how they reflect preconceived notions of who potential users are, what they do, etc., and adapt them to reflect a diversity of lived experiences, including those of migrants and other marginalized and underserved communities.

Ensure that digital identity innovation accounts for the interconnectedness of identification procedures and requirements across use cases and contexts.

• Implement holistic assessments to identify and mitigate unintended consequences as early as possible and on a continuous basis, also taking into account individuals who may opt out of using an EUDI Wallet.
• Aim for a consistent user experience across use cases and user groups. If similar processes follow different rules, or if different rules apply to different user groups or individual users, this places a high cognitive load on users and is likely to create feelings of frustration and insecurity, similar to the current state of digitalization in the German public sector (e.g., activating the eID function/ resetting the eID PIN code for Personalausweis holders vs. eAT holders).

For digitalization and migration

Non-EU migrants in Germany can access the country’s eID infrastructure once they obtain an electronic residence permit (eAT). Currently, Germany has approximately 6.69 million eAT holders with temporary or permanent residence rights. 156 However, there are no statistics on the extent to which eAT holders actually use the eID function. Interviews indicate considerable confusion about how the eID function works, dissatisfaction with its complexity and lack of usability, and mistrust of digital identification practices and the personal information collected.

The following recommendations aim to ensure that digitalization efforts—including future tools such as the EUDI Wallet—are transparent, rights-based, and responsive to the needs and concerns of migrants. These recommendations draw on the research findings presented in this report about digital identification practices in Germany’s public sector, and on references research participants made to other contexts and examples, such as Ukraine’s Diia app and various digital support apps, chat groups, and information networks for and by migrants.

Raise awareness.

• Implement information campaigns and public interest workshops in as many languages as possible to accompany the rollout of emerging digital innovations. Many migrants lack awareness of existing digital tools and processes, as well as guidance on how to navigate them effectively and safely.

Build on best practices and existing success stories.

• Ensure that digital innovation builds on the digital tools and practices that migrants already use and value (as identified in this report) rather than imposing disconnected priorities.
• Involve migrant-led civil society organizations in technology development and implementation processes.
• Ensure that consultation and participation processes are easily accessible to anyone interested and willing to contribute.

Invest in user-centered, rights-based, and digital-first public services for all migrants.

• Use digital technologies to reduce the cognitive load and administrative burden for migrants (e.g., develop a comprehensive, user-friendly digital platform for migration status-related procedures that allows applicants to create an account to book appointments, submit applications and documents, and track their status).
• Implement digital literacy training and digital capacity-building measures for public administration to ensure that administrative staff are well prepared for a future where information and document submission procedures are increasingly digitalized.

Commit to the responsible use and development of AI in both the public and private sector.

• The use of AI must comply with the principles of the EU AI Act (e.g., data quality requirements for the training, validation, and testing of AI). At minimum, AI systems used in the context of border control and asylum procedures (e.g., for language and dialect identification) should be considered high-risk applications requiring clear oversight and accountability mechanisms.

For social policy and digital identity

The following recommendations are based on the identification-related challenges that migrants currently face in Germany. This report shows that access to social rights and services is deeply shaped by a person’s legal status, their country of origin, and, the specific type of identification document they are issued by German authorities. These factors contribute to unequal experiences of recognition, inclusion, and access. Moreover, this report is grounded in the voices and lived experiences of migrants, who consistently emphasized that there can be no meaningful digitalization without the guarantee of basic rights. Digital identity and access to rights are not separate issues—they are deeply interconnected and must be addressed together. The recommendations below aim to center these realities to ensure that digital identification efforts do not deepen existing inequalities but instead contribute to fairer and more inclusive identification systems.

Clarity of requirements and timelines

• Establish and make publicly accessible clear and consistent guidelines outlining both the specific documentation requirements and the anticipated processing timelines for applications concerning residence permits, asylum, and citizenship.

Standardizing document handling

• Eliminate the arbitrariness in how physical and digitized documents are handled across immigration authorities. Implement clear, unified standards to reduce confusion and administrative burden for both applicants and staff.

Language inclusivity

• Ensure that all guidelines and requirements related to applications and migrant rights are made available in multiple languages. Current materials are often limited to German or English, which many migrants may not understand.
• Use clear and accessible language in official communications to support understanding of rights, obligations, and services. Where legal liability is a concern, provide both the original German version and a non-binding translation for clarity.
• Ensure the sustainability of recent legislative efforts that have expanded access to language and integration courses for certain groups of asylum seekers. Further measures should be introduced to extend this right to all asylum seekers, promoting early and effective integration into society.
• Ensure that migrants have access to translation and interpretation services during administrative appointments and throughout the processing of their applications. Many migrants report communication barriers during these encounters as a key obstacle to accessing their rights and receiving adequate support.
• Provide free, certified, and easily accessible online translation services for migrants to support the translation of foreign documents required in administrative procedures. This would reduce the financial burden and delays migrants face during application processes.

Administrative staffing and representation

• Ensure sufficient staffing in administrative bodies responsible for processing applications related to residence permits, asylum, and citizenship, including the recruitment of individuals with a migration background. Interviews and reports consistently point to a lack of human resources and the underrepresentation of staff with migration experience. 157 Improving both capacity and representation would help reduce delays related to verification, authentication, and procedural processing.

Discrimination prevention and response measures

• Implement mandatory intercultural competency and sensitivity training for street-level bureaucrats to help prevent discriminatory and arbitrary practices. Such training can contribute to reducing unequal treatment and improving interactions between migrants and administrative staff.
• Extend the mandate of existing diversity and anti-discrimination initiatives, such as the LADG Ombudsstelle in Berlin, 158 to ensure accessibility for migrants, including non-German speakers. Increase awareness of available resources, such as the AnDi App, to improve access. These measures would support more effective reporting of and responses to discrimination.

Passport requirement reform

• Eliminate the administrative practice of requiring individuals with subsidiary protection status to obtain passports from their countries of origin (Passbeschaffungspflicht), particularly when these states are responsible for the persecution that led to their displacement. This practice not only endangers the individuals by compelling them to engage with potentially hostile regimes but also may inadvertently finance these regimes through passport fees. 159

Reducing administrative burden

• Reduce administrative burdens—especially the repeated submission of documents—without compromising migrants’ privacy and data protection rights.
• If the Central Foreigner’s Register (Ausländerzentralkartei) continues to be used or expanded, data accuracy must be ensured, access strictly limited to specific purposes, and oversight enhanced. Individuals must be transparently informed about who accesses their data and why. 160

Improving housing access

• Address structural housing barriers by repealing the requirement for Anmeldung as a precondition for accessing social and private services.
• Implement rent control measures and significantly invest in social housing to increase availability and affordability.

Improving healthcare access

• Ensure equal access to healthcare for all individuals, including asylum seekers and undocumented migrants, by introducing electronic health cards (elektronische Gesundheitskarte) in all federal states and abolishing restrictive voucher systems.
• Allow asylum seekers to choose their own doctors, and implement anonymized health vouchers for undocumented migrants to reduce barriers to care.
• To protect individuals from fear of deportation, exclude agencies responsible for facilitating access to health and social services from mandatory reporting requirements to immigration authorities. 161 Currently, access to adequate and confidential health care remains highly unequal and often inaccessible for those with insecure status.

Improving access to basic banking and financial services

• Ensure that all individuals—regardless of migration or citizenship status—can open a Basiskonto (basic bank account) and obtain a debit card without facing arbitrary barriers, and adjust associated fees to align with standard banking costs. Banks should be required to accept both the Ankunftsnachweis and Duldung as valid identity documents, in line with the Zahlungskonto- Identitätsprüfungsverordnung (ZIdPrüfV). Currently, inconsistent implementation of this regulation limits financial inclusion and restricts migrants’ access to essential services.
• Where the SocialCard is implemented, it should be done in a way that respects the right to privacy and promotes financial autonomy and personal freedom. This includes free and unrestricted access to card payments, cash withdrawals, and bank transfers; no spending limits; and no transaction monitoring or analysis by authorities.

Recognizing foreign qualifications

• Reduce barriers to the recognition of academic and vocational qualifications, as well as professional experience, obtained outside of Germany.
• Create accessible pathways for career track changes that take into account migrants’ prior education and work experience abroad. Currently, complex and restrictive recognition procedures prevent many qualified individuals from contributing their skills to the labor market and pursuing meaningful employment.

Data privacy and consent

• Develop a clear protocol requiring street-level bureaucrats to obtain informed consent from asylum seekers before accessing their cell phone data, ensuring data protection standards equivalent to those afforded to citizens.

Ensuring freedom of movement

• Enable asylum seekers and protection holders to digitally request permission to leave their assigned area of residence under the Residenzpflicht.
• Similarly, allow digital requests to change one’s place of residence under the Wohnsitzauflage.
• In the long term, these restrictions—Residenzpflicht and Wohnsitzauflage— should be lifted entirely, as they significantly limit asylum seekers’ freedom of movement.
• Provide clear, multilingual information at all major German airports on acceptable travel documents for different categories of migrants.
• In addition, offer guidance to both border staff and travelers on the use of EasyPass to ensure faster and smoother passport checks. Currently, a lack of accessible information and inconsistent procedures at border crossings can lead to confusion, delays, and unequal treatment.

Rights awareness

• Empower migrants by ensuring accessible and multilingual information about their rights, enabling them to contest mistreatment and discriminatory practices by street-level bureaucrats. As part of this effort, inform asylum seekers specifically about their rights regarding cell phone data privacy to curb overreach by authorities such as the BAMF, particularly in practices like “phone scraping.” Increased awareness is essential for safeguarding dignity, autonomy, and legal protection.
• Increase funding for civil society organizations led by and for migrants that work to raise awareness of migrants’ rights. These organizations have the strongest community reach and play a vital role in supporting and informing migrants, particularly where state services are limited or inaccessible.

Toward a just and inclusive digital future

Digitalization in migration governance must grapple with its dual role as a tool of both empowerment and control. While it holds promise for simplifying processes, reducing stress, and increasing access, it must also address systemic inequalities and avoid reinforcing existing disparities. Policymakers should prioritize inclusive, user-centered design approaches for developing digital identity wallets and other technologies to ensure accessibility for all migrants and meaningful safeguards against misuse and overreach. Importantly, digital identification practices should complement rather than replace physical documentation to account for varying levels of digital access and literacy.

The migration process is inherently shaped by global systems of inequality. Digitalization is not a panacea for these structural challenges. If made transparent, rights-based, and responsive to the needs and concerns of migrants, digitalization may offer an opportunity to create tools, systems, and procedures that are more efficient, fair, and humane. However, realizing this vision requires putting migrants’ needs at the center of technology design, development, and implementation, addressing power imbalances, and balancing the benefits of digital technologies with their potential risks. Only then can digitalization truly serve as a pathway toward justice and dignity in migration governance.

Glossary

AfD: Alternative für Deutschland: Alternative for Germany, a far-right populist political party

Ankunftsnachweis: Literally, “proof of arrival”; a paper document that contains a 2D barcode (digital seal) developed by the Federal Office for Information Security (BSI)

Aufenthaltstitel: Umbrella term for different types of German residence permits, both short and long term

Anmeldung: Residence registration in Germany

AsylbLG: Asylbewerberleistungsgesetz: Asylum Seekers’ Benefits Act. This law regulates the benefits asylum seekers are entitled to receive while their asylum application is being processed. It also regulates their access to basic necessities like food, housing, clothing, and healthcare.

AsylG: Asylgesetz: Germany’s central national law that governs how asylum applications are processed and how international protections are granted (or denied).

Ausländerbehörde: Foreigners Authority/Immigration Office. Authorities responsible for German immigration, residence, and visa matters. Their responsibilities are defined in more detail by the federal states; organizationally, these authorities are embedded very differently at the local level.

AZR: Ausländerzentralregister: Central Register of Foreigners; operated by the BVA, this database stores the personal data records of foreigners. The approximately 26 million personal data records stored in the AZR also include data on 4.47 million EU citizens (as of February 2009). 162

Ausweis: Generic term for identification documents, used to refer to a variety of documents issued by German authorities (e.g., Personalausweis refers to the German national ID card)

BAMF: Bundesamt für Migration und Flüchtlinge: Federal Office for Migration and Refugees

Bezahlkarte: A “payment card” that allows for various restrictions on payments and other financial behaviors (e.g., limits on cash withdrawals) compared to a traditional debit card. Benefits under the AsylbLG that were previously paid in cash or transferred to a basic account are now loaded onto the payment card each month.

blockchain: A type of distributed digital ledger secured by cryptography, commonly associated with its use with cryptocurrencies, but also applicable in other contexts, including identity management.

Blue Card: A work-based immigration permit for skilled professionals from outside the EU intended for people with a university degree and a qualified employment offer. It provides a streamlined path for entering the country and obtaining long-term or permanent residence. It is possible to receive a Blue Card visa to come to Germany, or to apply for a Blue Card while residing in Germany as a work permit (for example, after graduating with a higher education degree).

BMDS: Bundesministerium für Digitales und Staatsmodernisierung: Federal Ministry for Digital Transformation and Government Modernisation

BMI: Bundesministerium des Innern: Federal Ministry of the Interior (previously Federal Ministry of the Interior and Community)

BSI: Bundesamt für Sicherheit in der Informationstechnik: Federal Office for Information Security

BVA: Bundesverwaltungsamt: Federal Office of Administration

Bürgeramt: Municipality/Citizens’ Office

(Digital) Credential: A set of one or more claims about an individual, provided and guaranteed for by an issuing authority (e.g., an academic certificate issued by an educational institution). Digital credentials can attest to a wide range of personal and/or professional data, providing a machine-readable proof of information that characterizes an individual, their qualities, rights, and permissions (e.g., date of birth, nationality, etc.).

Duldung: Literally, “tolerance”; temporary suspension of deportation status issued by German authorities

eAT: elektronischer Aufenthaltstitel: Electronic residence permit issued by German immigration authorities introduced in 2011. This can be a temporary German residence permit, an EU Blue Card, an ICT card, a Mobile ICT card, a permanent German residence permit, or a permanent EU residence permit. eID function Electronic identification feature of the newer generation of certain government-issued identification documents in Germany (Personalausweis, eID-Karte für EU-/EWRStaatsangehörige, eAT). The chip in the card stores the personal data (name, date of birth, nationality, address) and biometric features (photograph and fingerprints) of the card owner.

eID-Karte für EU-/EWR-Staatsangehörige: eID card for citizens of the EU and EEA nationals. This card does not replace a national ID card or passport (e.g., for identification when traveling) and is only intended for enabling access to digital services. The card is issued without a photograph, fingerprints, or signature; visible personal data includes surname, first name(s), and date of birth.

eIDAS 2.0: Commonly refers to the revision of Regulation (EU) No 910/2014, which originally laid down the rules and requirements for interoperability between national electronic identification systems and trust services in the European Union. A key change introduced by eIDAS 2.0 is the mandatory obligation for EU Member States to provide citizens and residents with a European Digital Identity (EUDI) Wallet, enabling secure access to public and private digital services across the EU.

ELSTER: Free web-based German tax software for users to digitally submit their tax returns. The ELSTER certificate can be used as an identification document to access certain digital services.

Fiktionsbescheinigung: Literally “fictional certificate”; a document issued when a decision cannot yet be made on a residence permit application due to missing documents, because the previous residence permit has not expired, or when the outcome of criminal proceedings must be awaited. 163

Kirchenasyl: Literally, “church asylum”; “the last, legitimate attempt (ultima ratio) to assist refugees by granting them temporary protection in a church parish/monastic community in order to achieve a renewed, careful examination of their situation.” It is granted “for people who are threatened with danger to their life, limb or freedom through deportation, or for whom deportation would entail unacceptable hardships.” 164

LABO: Landesamt für Bürger- und Ordnungsangelegenheiten: Berlin State Office for Citizens’ and Regulatory Affairs

LADG Ombudsstelle: Berlin Ombudsman’s office that advises and supports citizens in enforcing their rights under the Berlin State Anti-Discrimination Act.

LAF: Landesamt für Flüchtlingsangelegenheiten: Berlin State Office for Refugee Affairs, founded in August 2016.

LAGeSo: Landesamt für Gesundheit und Soziales: Berlin State Office for Health and Social Affairs, previously the central contact point for refugees in Berlin before it was replaced by the LAF.

(Bundes-)Länder: (Federal) States

LEA: Landesamt für Einwanderung: Berlin State Office for Immigration founded in January 2020; previously a department within the State Office for Citizens’ and Regulatory Affairs.

Meldepflicht: Regulation requiring all people residing in Germany to register their residence address

Passbeschaffungspflicht: Literally, “obligation to obtain a passport”; requires asylum seekers to possess a passport of their country of origin and share it with the immigration authority when applying for asylum. If they do not have one, they are obliged to cooperate in obtaining an identity document (see Sec. 15 of AsylbLG). 165

Personalausweis: Germany’s national ID card. An optional eID function was first introduced in 2010. Since 2017, the Personalausweis has an automatically activated eID function.

PID: Personal identification data (PID) that is the key reference data for the EUDI Wallet, providing basic identity information on the Wallet’s user (such as surname, first name, nationality, and date of birth). In Germany, this PID is expected to be derived from the country’s existing eID infrastructure.

Residenzpflicht: Literally, “residence obligation”; a condition imposed on asylum seekers that requires them to stay only in the area specified by the immigration authority.

self-sovereign identity (SSI): A technical concept and movement seeking to advance user-controlled, decentralized forms of digital identification.

Sozialamt: Social Welfare Office, the municipal or district authority responsible for administering social assistance (“Sozialhilfe”) and related welfare services under German social law. Specific responsibilities and benefits may vary depending on the state and municipality and may include housing benefits, assistance for people with disabilities, or benefits under AsylbLG.

SPRIND: Bundesagentur für Sprunginnovationen: Federal Agency for Breakthrough Innovation, established in 2019 to provide flexible public funding for new products, business models, and technologies, focusing on projects and markets associated with high development risks.

Wohnsitzauflage: Literally “domicile requirement”; a condition imposed on asylum seekers or Duldung holders that regulates their place of residence. Residence must be maintained in the federal state, county, or city in which they are assigned for the asylum procedure. Often confused or used interchangeably with the Residenzpflicht. 166

Zentrale Servicestelle Berufsanerkennung: Service Center for Professional Recognition, established in 2020 to supplement existing advisory services in Germany with a multilingual advisory service for skilled workers residing abroad who wish to apply for professional recognition from there in order to work in Germany in the future.

Zusatzblatt: Additional fold-out sheet of paper that is issued alongside a residence permit to note any additional provisions (e.g., relating to employment).

Appendix 1: Overview of Interviewees

Migrant interviewees

Expert interviewees

Appendix 2: Forms of protection in Germany

Appendix 3: Identity documents and identification practices in Germany

Appendix 4: Participants’ identity documents