Conceptualising the European digital identity wallet ecosystem as a complex adaptive system: towards an analytical framework

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Abstract
The European Digital Identity (EUDI) Wallet is widely framed as a regulatory and technical implementation project under eIDAS 2.0. Despite substantive political commitment and technical effort, the wallet ecosystem develops slowly, exhibits fragmentation, and raises concerns about public control and market dominance. This paper advances the argument that these difficulties are structural rather than incidental. With this insight, we developed an analytical framework to identify key sources of complexity. Using an intrinsic case study approach and drawing on Turner et al. synthesis of Complex Adaptive System (CAS) characteristics, we distinguish between substantive complexity (inherent in the governance object) and process complexity (arising from governance arrangements). The analysis indicates that the EUDI Wallet manifests the defining characteristics of a CAS, wherein systemic complexity emerges from the dynamic interactions among substantive, process-oriented, and hybrid mechanisms. The paper's main contribution is a theoretically grounded framework of CAS indicators for digital identity ecosystems, illustrated with empirical examples from the EUDI Wallet context. This framework provides the conceptual foundation for subsequent empirical research on governance tensions and adaptive strategies and offers a diagnostic tool for policymakers and practitioners.

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