By: Sanna Wong-Toropainen
The European Union (EU) has introduced a regulation that mandates all EU Member States to provide a digital identity wallet, called EUDI, to all citizens. The wallets are intended to provide a free alternative to strong identification, in comparison, for example to bank-provided strong identification applications that many use in Finland, and to serve as tools for sharing verified attributes, such as academic certificates, with employers and public authorities. On this topic, we were able to take part in a workshop organised by the city of Espoo and MyData Global on 24 September in a pre-event to MyData Conference in Espoo, that focused on ideating pilots for how the digital identity wallets could be specifically used to facilitate immigration procedures, and through smoother entry into the country, help attract talented workers to Finland.
Digital identity wallets for a better migration journey?
In the event, it was discussed that Finland is known for a certain degree of bureaucracy that makes it difficult for a migrant worker to get settled. For instance, you need to have a social security number and an address to open a bank account. If receiving those is delayed, your first paycheck could also be delayed. Similarly, if you are not able to rent a house immediately, you cannot register a city as your domicile, and if you do not have a domicile, you cannot apply for a daycare spot for your child. These are just some examples of the things that a migrant worker needs to sort out within the first weeks of work, and how they are interconnected. The hope now is that with digital identity wallets, the user journey could be more efficient and frictionless, similar to a Norwegian pilot in which visa processing time was reduced from 37 weeks to three days. The digital identity wallet made it possible to securely process and share sensitive personal data and identification documents.
Misinformation and mistrust
However, the EU digital identity wallet was proposed already in 2021 as part of renewing the EU-wide electronic identification and trust services framework (eIDAS) and while the promise of great user control over data has been at most parts welcomed, the wallet has also faced skepticism and a whole lot of misinformation.
Last year, for example, I discussed with Euronews journalist James Thomas about the misinformation and conspiracy theories around the EU’s digital identity wallet. The EU has presented the wallet as a voluntary, free, and privacy-preserving tool, however, the theories on how governments will surveil citizens through the wallet have persisted in the social media since the early days of the proposal. The narratives of surveillance or loss of control seem to appear “algorithmically catchy” and as such catch attention, which is also illustrated in Finland.
In 2021, the Finnish government proposed a national digital identity to reduce reliance on bank-provided logins. Public consultation got 633 replies, most of them negative, because many feared government surveillance through the digital identity. Later research by Kallio & Uotila (2023), however, showed that 67% of responses contained misinformation or unsubstantiated claims. The law was eventually repealed in 2023 following a government change, with rumours that the repeal was linked to the law’s potential to help migrants access services remotely (read enter Finland). However, because the EUDI is harmonised EU law, Finland will now need to in any case provide a digital identity to all its citizens by 2026.
Digital identity as a politicised issue
The rumours and the repealing of the digital identity laws nevertheless demonstrate how digital identity has become a politicised issue. On the one hand, it can democratise access, especially for marginalised groups like migrants who do not have access to digital identity and strong identification, which is needed in today’s world to access most if not all public services online. On the other hand, it can serve as a tool of control, determining who gets to enter the digital public sphere (think about Finland repealing digital identity law).
This tension is also visible in Finland’s broader migration policies, which include laws like a “three-month unemployment rule” obliging migrants who lose their job to find new employment within a three-month period, with employers required to notify immigration authorities. At a public discussion, migration researcher Quivine Ndomo warned: “Once employers know your existence depends on that job, it becomes easy to put you through things you cannot say no to.”
Here, automated decision-making (ADM) adds another layer. Finland’s ADM law allows the Immigration Service to automate tasks such as cross-checking wages in the income register, flagging cases with no reported income. While efficiency is a goal, such systems risk reinforcing existing vulnerabilities if not carefully designed. You can read more about it here.
Designing trustworthy digital identity wallets
The EU frames the wallet as a tool of empowerment: giving individuals granular control over what data to share, and with whom. But this framing has its own problems. In practice, the regulatory burden shifts to individuals, who must make informed, often technical decisions about data sharing and its consequences, as I have argued in my article. The question, therefore, is how prepared we are to make these decisions on a daily basis, often without time and thorough understanding of which databases our information ultimately ends up in. Moreover, rights under the GDPR, such as right to be forgotten, depend on the legal basis chosen by the organisation processing the data. Even if you share information through the wallet, the extent of your rights still depends on decisions made by companies or authorities, not just by you.
In conclusion, while digital identity wallets can reduce barriers and create more efficient digital ecosystems that could also help make migration processes faster, the design of the wallets and the supporting regulatory framework need to be carefully crafted to support fundamental rights, such as the right to privacy and the right to good governance.
Ongoing research, such as that conducted in the Trust-M project and presented through its publications, investigates how trustworthy and inclusive digital public services (often employing AI) can better support migrant integration, offering empirical and design insights that should inform the development of digital identity systems. See Trust-M publications here: https://trustmproject.aalto.fi/publications/