On 30 October 2025, the European Central Bank (ECB) quietly closed a chapter that had run for two years. The preparation phase of the digital euro, launched in November 2023 to determine whether a public, retail form of the single currency was buildable, concluded, and the Governing Council voted to move to the next phase. Seven weeks later, on 19 December 2025, the Council of the European Union adopted its negotiating position on the legislative package. Together, those two events converted the digital euro from a research project into a highly advanced implementation programme with a realistic path to issuance in 2029, conditional on the European Parliament and Council adopting the enabling regulation during 2026, and on a final Governing Council decision the ECB says it will take only once the law is in force.
For most of its life the digital euro has been discussed as a technology story: wallets, offline chips, settlement rails. That framing misses the point. The digital euro is a question about the limits of public power over money. How much central-bank money citizens may hold, how private their spending remains, who absorbs the cost of building it, and whether issuing sovereign digital cash actually buys the strategic autonomy its champions promise. None of those questions is technical. All of them are now being decided, in the open, by co-legislators in Brussels and Frankfurt.
What it is, where it stands, why it matters
Not a payments upgrade. A sovereignty question.
Analysis: Ahorro Sostenible views the digital euro as best understood not as a payments upgrade but as the retail flank of a broader European strategic-autonomy programme that also spans, among others, energy, defence and critical technology. The monetary logic and the geopolitical logic have converged, which is precisely why European heads of state called for accelerated progress at the October 2025 Euro Summit. It is the retail-payments prong of the same agenda the Commission pursues on the wholesale side through the Savings and Investments Union, the umbrella project launched in March 2025 that fuses the banking union and capital markets union to keep European savings financing European investment.
The strategic case rests on a single uncomfortable fact: Europe remains heavily dependent on non-European payment infrastructure for a large share of its retail card transactions. ECB and the European Money and Finance Forum (SUERF)’s estimates place that share around 65%, processed principally by US-based schemes such as Visa and Mastercard, and, on ECB and SUERF figures, 13 of the then 20 euro-area countries had no domestic digital payment solution for retail transactions at all. The euro area has since grown to 21 members with Bulgaria’s accession on 1 January 2026.
That structural exposure was tolerable while it looked commercial, but it stopped looking commercial in 2025. In January, a US executive order prohibited the Federal Reserve from issuing a retail Central Bank Digital Currency (CBDC) and directed federal agencies to promote dollar-backed stablecoins worldwide. In July, the GENIUS Act established the first federal framework for payment stablecoins, requiring issuers to hold reserves in high-quality liquid assets, predominantly short-dated US Treasuries, wiring stablecoin growth directly into demand for American sovereign debt. Approximately 99% of stablecoins are dollar-denominated. The contrast across major economies is stark: the United States has banned a retail CBDC and bet on private dollar stablecoins, China has pressed ahead with the e-CNY, and the United Kingdom is still weighing a digital pound, leaving the euro area to choose its own path rather than inherit one. The ECB’s Piero Cipollone put the conclusion in plain terms in a May 2025 speech: overreliance on foreign payment providers leaves Europe “dependent on the kindness of strangers” at a moment of geopolitical tension, and “there is no true sovereignty without sovereign money.”
on non-European rails
first issuance
holding-limit range
The pilot, concretely
Behind the legislative debate, the Eurosystem is already building. On 5 March 2026 the ECB opened a call for expression of interest inviting licensed payment service providers to join a digital euro pilot, a 12-month exercise running through the second half of 2027 in a controlled environment, testing a “beta digital euro” that explicitly will not have legal tender status. Because the regulation is not yet in force, the pilot leans on the existing PSD2 framework: the ECB is testing a public digital currency on a legal workaround while it waits for the co-legislators.
The scope is deliberately modest, and the detail is revealing. Participants are staff of participating Eurosystem central banks, transacting with a small set of merchants that provide everyday services on ECB and national-central-bank premises: cafeterias, restaurants and e-commerce merchants. Four use cases are in scope: person-to-person payments online and offline, and person-to-business at the physical point of sale and in e-commerce. The supporting infrastructure has a name and an architecture, the Digital Euro Service Platform (DESP), providing alias lookup, secure exchange of payment information, settlement, and offline issuance services that individual providers cannot build alone. Its core components are being built not by the ECB alone but by six national central banks selected in July 2025: Banca d’Italia, Banco de España, Banque de France, the Bundesbank, Lietuvos Bankas and the Oesterreichische Nationalbank.
Analysis: two facts from the ECB sharpen Ahorro Sostenible’s thesis. First, the ECB states plainly that the pilot’s purpose is to validate technical readiness and refine the value proposition and go-to-market strategy, not to prove demand exists. Second, the final decision to issue “will only be taken once the relevant EU legislation has been adopted,” and participation in the pilot “will not be remunerated.” The central bank is asking the banks that would distribute the digital euro to fund their own pilot participation, development, integration, certification and end-user support, with no payment and no guarantee of issuance. That is the cost complaint, confirmed from the issuer’s side rather than the banks’.
| Date | Milestone |
|---|---|
| 5 March 2026 | Call for expression of interest opens, with technical, operational and procedural documentation published |
| 14 May 2026, 17:00 CEST | Payment service provider application deadline |
| June 2026 | Eurosystem finalises provider selection |
| July 2026 | Selected providers sign participation agreement and the development phase begins |
| H1 2027 | Provider onboarding and user testing |
| H2 2027 | 12-month pilot operational (beta digital euro, no legal tender status) |
| H2 2028 | Pilot completed |
| 2029 | Earliest possible first issuance, conditional on the regulation passing in 2026 |
The Eurosystem has been here before, which is both the strongest argument for the project and the sharpest question against it. In November 2018 the ECB launched TARGET Instant Payment Settlement (TIPS), a platform that settles instant euro transfers between banks in central-bank money, around the clock, in seconds. The rationale then reads almost identically to the digital euro pitch now: ensuring Europeans keep access to central-bank money as cash use declines, and building a pan-European rail rather than ceding the ground to fragmented national or foreign schemes. TIPS is wholesale infrastructure, banks and payment providers hold the accounts, not citizens, so it settles in central-bank money without giving the public a direct claim on the ECB the way a retail digital euro would. But the continuity is not lost on the Eurosystem: the Banca d’Italia has assessed TIPS as a candidate technical backbone for the digital euro itself. The uncomfortable precedent is adoption. Despite full technical readiness, instant payments languished, fewer than one in ten euro credit transfers were instant in early 2020, until the ECB imposed a reachability mandate and the EU ultimately legislated instant transfers as mandatory from 2024. A capable public rail, it turns out, is not the same as a used one, which is precisely the doubt now hanging over the digital euro.
The holding limit: where stability and usefulness collide
Every serious objection to the digital euro converges on one parameter. A digital euro is a risk-free claim on the central bank. In a banking panic, that is exactly what frightened depositors want, which is why a CBDC large enough to be useful is also large enough to be dangerous. The fear is sharper because Europe’s banking union is still unfinished: banks sit under the Single Supervisory Mechanism, but with no common deposit-insurance backstop in place, supervisors treat any new, frictionless channel for deposit flight with particular caution. The Eurosystem’s answer is a per-person holding limit, combined with a “waterfall” that links the wallet to a bank account so payments above the cap clear automatically, and a deliberate decision to pay no interest, so the digital euro never competes with deposits as a savings vehicle.
The disagreement is over the number. Euro-area run models calibrated by the Deutsche Bundesbank and researchers writing for the Centre for Economic Policy Research (CEPR) find that welfare and stability are maximised at a limit of around €1,500: raise it further and the probability of a bank run begins to climb again as “fast” disintermediation risk returns. The European Commission’s proposal, by contrast, sits at €3,000–€4,000, roughly the average net monthly income of a euro-area household, and ECB survey work has floated figures as high as €10,000. The same instrument, modelled by different institutions for different objectives, yields limits that differ by an order of magnitude.
The December 2025 Council position added a second fight on top of the first: not just how high the limit should be, but who sets it. Under the texts now in negotiation, the Commission would set the ceiling by delegated act, within bounds, on financial-stability grounds, and drawing on an ECB report, rather than leaving the parameter wholly to the ECB. The mechanism is now taking shape even as the number stays open: in its 23 June 2026 position the Parliament backed the Commission setting the ceiling on an ECB recommendation, reviewed at least every two years, while insisting that Parliament keep full decision-making power over it. The level remains unresolved; the process around it is a deliberate, and contested, rebalancing between monetary and political authority, and member states pressed for it precisely because the holding limit is the lever that decides how much deposit base their banks could lose.
The holding limit is not a technical setting. It is the dial on which Europe decides how much public money it is willing to trust its own citizens with, and how much deposit risk it is willing to impose on its own banks. Set it too low and the digital euro is a curiosity. Set it too high and it is a run accelerator.
— Alejandro Casasempere · Managing Partner, Ahorro SostenibleThe fight in Parliament
The ECB has decided, the Council has its position, and as of June 2026 the European Parliament has one too. That was the stage where the project had been most contested. The file’s lead rapporteur, Fernando Navarrete (EPP, Spain), a former head of the governor’s office at the Banco de España, had pushed a significantly scaled-down, “offline-first” version of the Commission’s design, and through early 2026 the file approached deadlock under an unprecedented volume of amendments and cross-group division. That deadlock broke on 23 June 2026.
That day the Economic and Monetary Affairs Committee adopted its position on the whole single currency package, three files, not one. The digital euro establishment regulation passed by 43 votes to 14 with one abstention. The companion files on non-euro-area distribution and on the legal tender of cash passed by wider margins, and the committee voted to open negotiations with the Council. The adopted text keeps both online and offline functionality, with offline designed to be cash-like, so much so that losing the device means losing the stored money, with no refund. Basic use is free for citizens, merchant and inter-provider fees are capped, and offline payments are entirely fee-free. On governance, MEPs backed the holding-limit mechanism described above but insisted that Parliament retain full decision-making power over the parameter, an explicit bid to keep the dial under political, not purely technocratic, control.
Analysis: the committee margin was comfortable, but the long road to it, and the next stage of a trilogue with the Council before anything becomes law, is the clearest signal that issuance in 2029 is a target, not a certainty. The decisive framing came from the rapporteur himself. “Europe does not have to choose between the digital euro and successful private payment solutions. We need both to work together,” Navarrete argued, adding that existing standards and infrastructure should be reused wherever possible. That is not a throwaway line. It is the official validation of this article’s central point, that the digital euro is one corner of a contest, not its conclusion. The private alternatives Navarrete points to already exist, which is why the next section matters.
The two objections that will not resolve themselves
On privacy, the Council’s December 2025 position made an honest concession that the project’s critics had long demanded acknowledgement of. The offline digital euro, even on certified hardware, cannot reliably guarantee the physical proximity that makes a cash transaction truly anonymous, and therefore cannot fully replicate the anonymity of banknotes. Online payments would be pseudonymised, with the ECB seeing codes, not identities, but pseudonymity is reversible under the right conditions, and privacy researchers have repeatedly shown that pseudonymised payment data can permit re-identification under certain conditions. European data-protection authorities, including France’s data-protection regulator the CNIL, have proposed a workable compromise: genuine untraceable anonymity below a daily threshold, traceability above it only for entities with a legal public-interest mandate. The Parliament’s adopted position pushed the online side further than many expected, with privacy-by-design and privacy-by-default, zero-knowledge proofs to verify transactions without exposing personal data, and an explicit rule that the ECB would have no access to personal identification data. That is the substance behind the rapporteur’s public claim of “no ECB surveillance.” Whether the final regulation delivers that through trilogue, or settles for “highly private but not anonymous,” is still to be negotiated, and not in isolation. The anonymity ceiling is being set just as the EU’s new Anti-Money Laundering Authority (AMLA), operational in Frankfurt since July 2025 and having absorbed the European Banking Authority (EBA)’s anti-money-laundering mandates in January 2026, has named crypto-assets and “novel payment channels” as priority supervisory risks.
On cost, the gap between the two sides is almost threefold, and the pilot has now made the banks’ exposure concrete. The banking industry, through the European Banking Federation (EBF), the European Association of Co-operative Banks (EACB) and the European Savings and Retail Banking Group (ESBG), commissioned a PwC study in June 2025 estimating the investment euro-area banks would need over an initial four-year build; the resulting figures run well above the ECB’s own assessment of roughly €4–5.77bn for the sector. The ECB has countered that the bank-commissioned numbers are “substantially higher” than other industry studies and rest on conservative scoping. Three different numbers are often conflated here and should not be: the ECB puts its own development cost at around €1.3bn to first issuance, plus roughly €320m a year to operate, borne by the Eurosystem and, like banknote costs, expected to be offset by seigniorage; the banks’ €4–5.77bn is their separate integration cost; and the PwC figure is a contested third. The dispute over the bank aggregate is unresolved, but the principle is not: the ECB’s own pilot call confirms that providers must fund development, integration, certification and end-user support themselves, and that participation “will not be remunerated.” Whatever the precise total, the direction of the cost flow, from banks to the project, is now established from the issuer’s side.
The banks’ parallel bet
The most telling signal about the digital euro is not what banks say in consultations. It is what they are building instead. The institutions that the regulation would compel to distribute a public digital euro are, in parallel, financing private alternatives to it. That hedge sharpens the project’s central weakness: if the distributors themselves are funding substitutes, the adoption problem is more acute than any survey suggests.
Analysis: a word on the axis that organises this contest, because at the point of payment it is nearly invisible. An account-based instrument is a balance in a ledger someone maintains: you hold a claim, and a transfer is an update to two records, as with a bank transfer or an account-to-account rail. A token-based instrument is a bearer of value you hold directly, more like a banknote, that can pass from payer to payee without a central record updating at the moment of payment. The distinction barely registers for a user, both feel like tapping a phone, but it decides who can see the transaction, whether it works offline, and where the legal claim sits. The digital euro is deliberately both: its online form is account-based, with balances recorded in a central digital euro account, while its offline form is a bearer instrument stored on the device, spendable in proximity without connectivity and with cash-like privacy. That dual design is why it appears mid-axis on the map that follows rather than at either pole.
Incorporated in Amsterdam in December 2025, Qivalis is a bank consortium venture to issue a MiCA-regulated, euro-pegged stablecoin backed one-to-one by euros and high-quality liquid assets, with a launch targeted for the second half of 2026 pending an electronic-money-institution licence from the Dutch central bank. By early February 2026 it counted twelve banks: BNP Paribas, BBVA and CaixaBank alongside ING, UniCredit, Danske Bank, DekaBank, DZ BANK, KBC, Raiffeisen Bank International, SEB and Banca Sella. By May 2026 the consortium had grown to 37 banks across 15 countries, a sector-wide bet, not a fringe one.
A fourth strand sits outside the banks’ own consortia but answers the same dependency. In February 2026 the European Payments Initiative, behind the Wero wallet, signed a memorandum of understanding with the EuroPA alliance of national schemes (Spain’s Bizum, Italy’s Bancomat, Portugal’s MB WAY, the Nordics’ Vipps MobilePay), connecting roughly 130 million users across 13 countries through a central interoperability hub, with cross-border peer-to-peer payments targeted for 2026 and point-of-sale for 2027. This is an account-to-account rail, not a token, and it is precisely the kind of private, pan-European solution the above-mentioned European Parliament’s rapporteur has argued the public digital euro should be tested against.
The strategic read for an institution is that “the digital euro” is not a single event but the public corner of a four-cornered contest: retail CBDC, bank-issued euro stablecoins, tokenised deposits, and account-to-account rails like Wero. It is a contest in which Europe’s largest banks have placed bets across the board. And beneath these sits the quieter instrument that worries the digital euro least but competes with it most directly on the merits: the tokenised deposit, a claim on a bank’s own balance sheet that does not drain deposits the way a CBDC can, and the option that the Bank for International Settlements (BIS), in its “unified ledger” work, and the International Monetary Fund (IMF) have treated as the less disruptive route to tokenised money.
The contested terrain
Across the institutional literature, from the ECB and the Bundesbank to Bruegel, the European Parliament and the banking associations, three substantive contradictions recur. Understanding them is not academic. They define the choices institutions must make now.
| Contradiction | Position A | Position B | Why They Disagree |
|---|---|---|---|
| Holding limit: usefulness vs. stability | A limit near €3,000–€4,000 is needed for the digital euro to be genuinely useful as an everyday payment instrument (European Commission) | Stability is maximised around €1,500; higher limits reintroduce bank-run risk in a crisis (Bundesbank/CEPR, 2024) | Objective: the Commission optimises for adoption and usefulness; financial-stability modellers optimise against tail risk. Both are right within their own frame. |
| Public CBDC vs. private rails | Only a public digital euro can guarantee sovereign, pan-European payment autonomy that private actors will not deliver on their own (ECB) | Private European initiatives (Wero, bank stablecoins) can deliver autonomy faster and should be tested first (EP rapporteur; banking associations) | Trust in delivery: the ECB doubts private rails will cover the whole area unaided; the banks doubt a public instrument can earn adoption. The pilot is designed to test exactly this. |
| Cost: who pays, and how much | Integration will cost banks well above the ECB’s estimate; the bank-commissioned study points to a far higher figure (EBF/EACB/ESBG via PwC, 2025) | Sector integration is roughly €4–5.77bn; the bank study is “substantially higher” than peers and conservatively scoped (ECB) | Scope and incentive: the banks model a maximal build and bear the cost unremunerated; the ECB nets out synergies. The unremunerated pilot has already proven the direction of the cost flow. |
What is settled, contested, and still open
The limits of what we know
What is established beyond reasonable doubt: Europe’s retail payments are heavily dependent on non-European infrastructure, and a generously-sized digital euro would, in a crisis, give depositors a frictionless route out of banks. Both the dependency and the disintermediation mechanism are accepted across the institutional spectrum.
What remains genuinely contested: the right level for the holding limit, the true integration cost to banks, and whether the privacy guarantees survive the move from committee text to final law. These are not knowledge gaps that better data will close; they are value choices about how much sovereignty, stability and privacy to trade against one another.
The single most important unanswered question: will Europeans actually use it? No survey has produced revealed demand, most euro-area consumers already have working digital payments, and the ECB itself frames the 2027 pilot as a test of readiness, not of appetite. If adoption does not come, the sovereignty argument will have built an instrument that solves a real strategic problem that consumers do not feel, and the private rails will have won the everyday payment by default.
What this means for your organisation
For any organisation with exposure to payments, treasury, compliance or consumer data, the digital euro should now be treated as a scheduled regulatory and infrastructure event for the 2026–2029 window, not a hypothetical. The decisions that will define its commercial and operational impact, the holding limit, the distribution and compensation rules, the privacy architecture, the cost allocation, are being made now. The Parliament adopted its committee position on 23 June 2026, and the trilogue with the Council, where the final shape of the law is set, is the next stage. The institutions that engage during this window will shape the rules they later have to live under. Those that wait for issuance will inherit them. In monetary policy as in strategy, the cost of arriving late is not measured in fees. It is measured in the loss of the chance to have influenced the design at all.
Acknowledgements — The author thanks Diego Caballero Orduna (Investment Banking Risk Manager) for the review of and comments on this article. Any errors are the author’s sole responsibility.