Electronic Identification in Poland: PESEL, Trusted Profile, mObywatel and Their Legal Status
What electronic identification means under Polish law
Electronic identification in Polish law is a legal mechanism for confirming a person’s identity using electronic data and technical tools. In certain administrative and legal procedures, it replaces the physical presentation of documents or personal appearance.
This concept originates from EU law and is primarily regulated by:
- Regulation (EU) No 910/2014 (eIDAS) on electronic identification and trust services,
- the Polish Act of 5 September 2016 on Trust Services and Electronic Identification, which implements eIDAS at the national level.
Under eIDAS, electronic identification means the use of electronic data that uniquely identifies a natural or legal person. Polish law further introduces national electronic identification schemes and trust levels (low, substantial, high), which determine in which procedures a given identification method may be used.
Main electronic identification tools in Poland
Trusted Profile (Profil Zaufany)
The Trusted Profile is a free, state-run electronic identification tool designed for communication with public authorities.
It allows users to:
- confirm their identity in public e-services,
- submit applications, requests, and complaints,
- sign documents electronically within public administration systems.
An electronic signature made using the Trusted Profile is legally equivalent to a handwritten signature only in procedures where the law explicitly allows it. It is not a universal civil-law electronic signature, but rather an official identification mechanism created for public administration.
Qualified electronic signature
A qualified electronic signature is based on a qualified certificate and provides the highest level of legal certainty.
It:
- uniquely identifies the signatory,
- has the same legal effect as a handwritten signature under civil and administrative law.
Its legal force follows directly from the eIDAS Regulation and Polish trust services legislation. Unlike the Trusted Profile, a qualified signature can be used both in the public sector and in private legal transactions, including contracts, powers of attorney, and corporate documents.
Electronic ID card (e-Dowód)
The Polish electronic ID card contains a secure electronic chip and certificates that allow:
- authentication in electronic services,
- use of a personal electronic signature.
This solution primarily concerns Polish citizens, but it is important for understanding the overall architecture of Poland’s electronic identification system.
mObywatel and mDowód
mObywatel is a government mobile application that provides access to digital documents, including the mDowód.
Polish law establishes the principle of legal equivalence, not exclusivity: digital documents shown in mObywatel are equivalent to physical ones, but they do not replace them entirely.
The mDowód:
- is a separate electronic document,
- is legally equivalent to a national ID card within Poland,
- does not eliminate the validity of the physical ID card.
PESEL: identifier or electronic identification tool?
Legal nature of the PESEL number
PESEL (Powszechny Elektroniczny System Ewidencji Ludności) is an 11-digit personal identification number assigned to individuals registered in Polish public systems.
Its structure includes:
- date of birth,
- gender indicator,
- control digit.
PESEL is a registry identifier, not an electronic identification tool under eIDAS.
PESEL as an attribute, not a means of identification
PESEL:
- is not a technical authentication tool,
- cannot independently confirm a person’s identity in electronic systems,
- is used together with other identification mechanisms such as the Trusted Profile, electronic ID card, qualified signature, or bank-based eID.
In digital public services, PESEL functions as a reference number in state registers, not as proof of identity or intent.
Where PESEL is used
In the public sector:
- healthcare,
- taxation,
- social insurance (ZUS),
- social benefits,
- residence registration,
- business registration and administration.
In the private sector:
- banking,
- insurance,
- employment,
- telecommunications.
Electronic identification of foreigners in Poland
Foreign nationals who have a PESEL number may use electronic identification tools under the same legal principles as Polish citizens, provided that a given administrative procedure allows it.
In practice, this means that foreigners with PESEL can:
- create a Trusted Profile,
- use ePUAP and login.gov.pl services,
- submit applications and sign documents electronically.
For Ukrainian citizens, a simplified PESEL + Trusted Profile mechanism was introduced, but no legal provision makes the use of these tools mandatory.
Can an authority refuse a case due to lack of mObywatel?
General rule
Refusing to process an administrative case solely because the applicant does not use mObywatel is unlawful if the law allows:
- paper submission,
- in-person filing,
- or alternative electronic identification methods.
This follows from the Polish Code of Administrative Procedure and sector-specific regulations.
Permitted channels for submitting applications
Administrative matters may be submitted:
- in writing (paper form),
- orally to the record,
- electronically via ePUAP or login.gov.pl
(using the Trusted Profile, electronic ID card, qualified signature, or bank-based eID).
mObywatel is one technical option among several, not an exclusive channel.
Practical risks
If a public service is technically available only through mObywatel, the authority remains obliged to provide an alternative way to exercise the right.
A refusal based on the lack of mObywatel may constitute:
- administrative inaction, or
- an unlawful refusal, both of which may be challenged.
Changes after 1 July 2025: what actually changed
What changed in practice
- Student ID cards: the mobile version in mObywatel became the default form; a physical card is issued upon request.
- New services in mObywatel, including:
- applications for ID cards,
- reporting lost or damaged passports,
- access to residence registration data.
What did not change
- The Trusted Profile, electronic ID card, bank-based eID, and qualified signatures remain core electronic identification tools.
- No general obligation to use mObywatel was introduced.
- The Trusted Profile has not been abolished; announced changes concern future reforms, not current law.
Common myths without legal basis
- The Trusted Profile is not mandatory.
- mObywatel is not the only acceptable identification tool.
- mDowód does not eliminate physical documents.
- Foreigners with PESEL (including PESEL UKR) are not legally obliged to use mObywatel or the Trusted Profile.
Conclusion
PESEL, the Trusted Profile, and mObywatel serve different legal functions and are not interchangeable:
- PESEL is a registry identifier,
- the Trusted Profile is a state electronic identification mechanism,
- mObywatel is a technical platform for accessing digital documents and services.
Polish law is based on the principle of alternative access channels, not forced digital exclusivity.
Ukrainian version of this article
Contact For professional assistance regarding Polish immigration, residence procedures, and administrative compliance, you may contact me via Telegram: @aleks_dokumenty