The Federation of German Consumer Organisations (Verbraucherzentrale Bundesverband — vzbv) has submitted recommendations to the German Bundestag demanding significant improvements to privacy safeguards surrounding the nationwide rollout of digital identity systems. The appeal focuses on the “d-you” application—the official national digital identity wallet scheduled for rollout in Germany in January 2027 under the European Union’s eIDAS 2.0 regulatory framework.
The mobile application is designed to allow citizens and resident foreign nationals to store national ID cards (Personalausweis), electronic residence permits (eAT), driving licenses, and other official credentials directly on smartphones. However, consumer advocates warn against the risks of commercial user profiling.
- What happened: Consumer federation vzbv submitted expert recommendations ahead of parliamentary deliberations on the state digital wallet “d-you”.
- Core demands: Protections against excessive data harvesting by private businesses, prohibitions on unified commercial profiling, and guarantees preserving physical cards and paper documentation.
- Who is affected: All residents in Germany utilizing public administrative or commercial services requiring identity verification.
The “d-you” Digital Identity System
The “d-you” national wallet is being developed pursuant to EU directives establishing cross-border digital identity frameworks (EUDI Wallet). The service aims to consolidate verified official documents into a secure mobile interface:
- identity verification when dealing with public authorities (Bürgeramt, Jobcenter, tax authorities Finanzamt);
- presentation of digital driver’s licenses and motor vehicle registration certificates;
- age and residency verification for apartment leasing, bank account onboarding, or employment contracts;
- secure storage of university degrees and professional qualification certificates.
The EU-wide and nationwide launch in Germany is scheduled for January 2027. Once deployed, credentials stored in the wallet must be recognized across all European Union member states.
Consumer Protection Concerns: Commercial Profiling Risks
The vzbv emphasizes that the administrative convenience of mobile identification must not compromise personal data protection standards. Ramona Pop, Executive Director of vzbv, stated that the legislative framework moving through the Bundestag requires mandatory statutory safeguards.
The consumer federation highlights four principal requirements:
- Data minimization principle (Datensparsamkeit): The application must transmit only the minimum information strictly required for a transaction. For example, during age-verification checks, the application should confirm that the user is 18 years or older without revealing their full name, exact date of birth, or home address.
- Prohibition of tracking (Anti-Tracking): Commercial entities (online retailers, car-sharing services, booking portals) must be technically prevented from linking separate user actions into unified behavioral profiles.
- Voluntary adoption: The statutory framework must guarantee non-discriminatory access to government services and private transactions for individuals choosing standard plastic ID cards or paper records.
- Decentralized user control: Cryptographic authentication keys and sensitive metadata must remain securely stored on the user’s personal hardware rather than consolidated in centralized databases.
Parliamentary Hearings: Balancing Law Enforcement and Privacy
Concurrently, the Bundestag Committee on Internal Affairs held expert hearings on related draft legislation concerning expanded investigative powers in digital environments (Stärkung digitaler Ermittlungsbefugnisse).
Testimony reflected conflicting views: law enforcement representatives advocated for broader access to digital footprints to investigate serious crime, while legal scholars and bar associations cautioned against infringing upon constitutional telecommunications secrecy and fundamental privacy rights.
The upcoming rollout of the “d-you” digital wallet marks a major development in German public sector digitalization; however, through January 2027, the platform remains under technical development and legislative review. Existing physical electronic residence permits (eAT) and passports retain full legal validity. Residents are not required to take any action pending the official platform release and operational guidelines from the Federal Ministry of the Interior.