Financial Law Review, 2026, Issue 42 (2)/2026, pp. 20-44, https://doi.org/10.4467/22996834FLR.26.006.24197

In market practice, the term ‘digital wallet’ covers solutions with different legal functions. It may denote a container for tokenised payment credentials, a stored-value wallet holding funds, an identity wallet, or a crypto-asset wallet. In the future, it may also serve as an access point for central bank digital currency, notably the digital euro. PSD2 contains no horizontal definition of the digital wallet. Its legal classification therefore depends on the function performed. This article develops a regime-based typology of digital wallets under EU law. It distinguishes pass-through credential wallets, staged wallets combining funding and payment functions, crypto-asset wallets assessed under MiCA, and identity wallets governed by eIDAS and the European Digital Identity Framework. It also examines the emerging link between identity and payments in the context of the proposed Digital Euro Regulation, including interoperability between digital euro front-end services and EUDI Wallets. The article maps licensing requirements, outsourcing structures, including under DORA, and the boundary between technical services and regulated AIS/PIS. It argues de lege ferenda for a more coherent functional taxonomy of digital wallets, clearer criteria for distinguishing technical interfaces from regulated payment services, and greater consistency between EU payment law, crypto-asset regulation, digital identity law, and the future digital euro framework.