Here the crux of the problem is laid bare. If EUDI Wallets are to deliver the degree of assurance that makes them useful, then the binding of the individual to their wallet must be sufficiently robust. But no method of binding that provides equal assurance to biometrics, according to NIST (among others). For those without modern devices and government-issued ID documents, in-person verification comes the closest, but is generally slower and more cumbersome than remote processes. In other words, the AEPD is calling for an equivalent alternative that does not exist.
Source: www.biometricupdate.com