What changed between the draft committee report of 9 Feb 2024 and the draft committee report of 3 Nov 2025

Added:Article 16 – paragraph 5 – subparagraph 1 – point b (new): (b) the total assets represented by credit institutions which will reach or fall below a liquidity coverage ratio (LCR) of a 100% will be below 1% for the euro area as a whole and for each individual Member State in the euro area.

Added:Article 16 – paragraph 5 – subparagraph 1 a (new): If the holding limits were to be lower than the estimated average cash holdings of natural persons as a means of transactions, the Commission may decide to set initial holding limits equivalent to those average cash holdings.

Added:Article 16 – paragraph 5 a (new): 5a. The Commission is empowered to adopt a delegated act revising the initial holding limits downwards, after consulting the European Central Bank and the European Systemic Risk Board, whenever it deems this to be appropriate.

Added:Article 16 – paragraph 5 b (new): 5b. The Commission shall propose a legislative amendment where it considers it appropriate to modify the criteria referred to in paragraph 5 to revise the initial holding limits upwards.

Added:Article 16 – paragraph 6: 6. The holding limits referred to in paragraph 5 shall be applied in a non-discriminatory manner and uniformly across the euro area.

Added:Article 16 – paragraph 6 – subparagraph 2 (new): Payment service providers providing account servicing payment services within the meaning of Directive (EU) 2015/2366 to natural and legal persons referred to in Article 13(1) shall ensure those overall holding limits to online digital euro payment accounts and offline digital euro devices.

Added:Article 16 – paragraph 7: 7. Where a digital euro user uses both an offline and online digital euro, the holding limit that applies to online digital euro shall be equal to the overall holding limit determined in paragraph 5 minus the holding limit for offline digital euro set by digital euro users. A digital euro user may set its offline holding limit at any amount between zero and the holding limit set in accordance with Article 37.

Added:Article 16 – paragraph 7 a (new): 7a. Visitors and natural and legal persons referred to in Article 13(1), points (b), (d) and (e), shall be subject to holding limits as regards the use of the digital euro as a store of value that are not higher than those effectively implemented in the euro area for natural and legal persons residing or established in Member States whose currency is the euro. Those holding limits shall be applied in a non-discriminatory manner and uniformly across Member States whose currency is not the euro. When deciding on the holding limits and other limits, the Commission shall consult the European Central Bank and national central banks of Member States whose currency is not the euro.

Added:Article 16 – paragraph 7 b (new): 7b. Where an online digital euro user has multiple online digital euro payment accounts, the digital euro user shall specify to the payment service providers with which the digital euro payment accounts are held how the individual holding limit is to be allocated between the different digital euro payment accounts.

Added:Article 16 – paragraph 7 c (new): 7c. Where an online digital euro payment account is held by more than one digital euro user, any holding limit on the related digital euro payment account adopted pursuant to paragraph 5 shall amount to the sum of the individual holding limits allocated to its users.

Added:Article 16 – paragraph 7 d (new): 7d. The Commission is empowered to adopt delegated acts, at the request of the European Central Bank, proposing additional limits to the use of the digital euro for the purpose of safeguarding financial stability and the stable funding of credit institutions and their lending capacity to the economy, while ensuring the usability and acceptance of the digital euro as a legal tender instrument and respecting the principle of proportionality.

Added:Article 16 – paragraph 8: 8. The digital euro shall not bear interest.

Added:Article 17 – title: Fees and charges for the provision of digital euro payment services

Added:Article 17 – paragraph 1: 1. For the purpose of Article 15(2), without prejudice to any possible fees charged on other digital euro payment services, payment services providers shall not charge fees to natural persons as referred to in Article 13(1), points (a), (b) and (c), for the provision of the basic digital euro payment services referred to in Annexes II and IIa.

Added:Article 17 – paragraph 1 – subparagraph 1 (new): To prevent the use of natural persons’ digital euro payment accounts for business purposes from being covered under the basic digital euro payment services in Annexes II and IIa, payment services providers shall be allowed to establish a proportionate limit on the number of received and issued payment transactions that are free-of-charge, and they shall be allowed to charge the exceeding ones according to paragraph 2 of this Article.

Added:Article 17 – paragraph 2 – introductory part: 2. For the purpose of Article 15(2), any merchant service charge or inter-payment service provider fee in relation to online digital euro payment transactions shall comply with the principle of proportionality. Any inter-payment service provider fee or merchant service charge levied by a payment service provider on a payment service provider or merchant in respect to online digital euro payment services shall not be higher than the inter-payment service provider fee or merchant service charge levied by that payment service provider on that specific payment service provider or merchant for comparable means of payment.

Article 17 – paragraph 2 – point a: deleted

Article 17 – paragraph 2 – point b: deleted

Change 10

Removed:Article 22 – paragraph 3: 3. Each Digital Euro wallet shall have a unique Digital Euro wallet identification number.

Added:Article 17 – paragraph 2 – subparagraph 1a (new): For the purpose of Article 15(2), any merchant service charge in relation to offline digital euro payment transactions shall comply with the principle of proportionality. Merchant service charges levied by a payment service provider on a merchant in respect of offline digital euro payment services shall not be higher than merchant service charges levied by that payment service provider on that merchant, with regard to comparable means of payment.

Removed:Article 22 – paragraph 4: 4. Each Digital Euro wallet may be linked to one or more non-digital euro payment accounts that shall be designated by the Digital Euro user. For the purpose of Article 13(4), each Digital Euro wallet may only be linked to one non-digital payment account.

Added:Article 17 – paragraph 3: 3. The Commission, in collaboration with the European Central Bank, shall regularly monitor the information on the fees or charges requested for comparable means of payment as well as the merchant service charges levied on digital euro transactions and publish periodically the amounts resulting from that monitoring with an explanatory report.

Removed:Article 22 – paragraph 5: 5. Payment service providers shall allow the use of Digital Euro wallet by more than one Digital Euro users.

Added:Article 17 – paragraph 4: 4. The Commission may require payment service providers to provide all information necessary for the application of this Article and to verify compliance with it. Any information requested shall be sent by payment service providers within the time limit set by the Commission. The Commission may require that such information is certified by an independent auditor

Removed:Article 24 – paragraph 1 – introductory part: 1. To ensure that payment service providers, other service providers and Digital Euro users can use conditional Digital Euro payment transactions, the European Central Bank may:

Added:Article 17 – paragraph 5: deleted / (deleted) / (deleted) / (deleted) / (deleted)

Removed:Article 24 – paragraph 1 – point b: (b) provide the functionalities in the Digital Euro transfer infrastructure necessary for the execution of conditional Digital Euro payment transactions, including for the reservation of funds;

Added:Article 17 – paragraph 6: 6. The merchant service charge shall incorporate all the fees and charges charged to the merchant in relation with the provision of acquiring services and, regardless of their price structure, be expressed as a percentage of the total monetary amount transacted in a given period of time. Payment service providers shall not charge merchants for the automatic defunding of the digital euro, including digital euro payment transactions referred to in Article 13(4) when the defunding goes to a non-digital euro payment account held with the same payment service provider. Payment service providers shall not charge merchants for the front-end services included in Annexes II and IIa.

Removed:Article 24 – paragraph 1 – point b a (new): (ba) adopt standards in order to allow the Digital Euro to be referenced on distributed ledgers.

Added:Article 17 – paragraph 7: 7. No inter-payment service providers fee shall apply to offline digital euro transactions or to the funding and defunding of online digital euro accounts from or to a non-digital euro payment account held with the same payment service provider.

Removed:Article 26 – paragraph 1 – subparagraph 1: The European Central Bank shall ensure the interoperability of the design features and rules of Digital Euro and the standards governing the interface of the Digital Euro infrastructure with relevant standards governing private digital means of payment. The European Central Bank shall prioritise to enable private digital means of payment to distribute the Digital Euro on the basis of the design features and rules, governing the Digital Euro.

Added:Article 17 a (new): Article 17a / Review clause on the fees and charges for the provision of digital euro payment services / 1. By 10 years from the issuance of the digital euro, provided that sufficient and reliable cost data for digital euro transactions are available in an accurate, harmonised and verifiable manner, and that the average unit costs and volume of total digital euro transactions have stabilised after the consumers’ adoption period, the Commission, after consulting the European Central Bank, shall carry out a review and submit a report to the European Parliament and to the Council to evaluate whether the compensation model referred to in Article 17 should be replaced with a cost-based compensation model. / 2. If a cost-based compensation model is deemed to provide lower costs for merchants, greater efficiency and competition in the payment markets and avoids cross-subsidies among different merchants’ business models or within the European payments ecosystem, the Commission shall prepare a legislative proposal for a new model of fees and charges for the provision of digital euro payment services. / 3. The report referred to in paragraph 1 of this Article shall include a comparison between the fees and charges that could result a cost-based compensation model, including a reasonable margin of profit, and the data collected pursuant to Article 17(3). / 4. The reasonable margin of profit referred to in paragraph 3 shall be calculated on the basis of the profit margin applied by those…

Removed:Article 26 – paragraph 1 – subparagraph 2: For the purpose of the first subparagraph, interoperability shall be pursued by the use of existing established standards and a contribution to their further development.

Added:Article 18 – paragraph 4: 4. Payment service providers shall implement the limits set by the Commission in accordance with Article 16 on the use of the digital euro by natural and legal persons residing or established in Member States whose currency is not the euro, which are applicable in those Member States.

Removed:Article 26 a (new): Article 26a / Governance and interoperability / The eligible payment service providers shall, on the basis of the design features and rules defined by the European Central Bank for the Digital Euro and the standards defined by the European Central Bank for the interface to the Digital Euro infrastructure, develop a Digital Euro payment scheme that governs the rules, standards and processes in the payment service provider infrastructure and for the front-end provided to the Digital Euro user. / For the purpose of the first subparagraph, each eligible payment service provider shall offer to the Digital Euro users at least one Digital Euro front-end service that is interoperable with front-end services across the euro area.

Added:Article 19 – paragraph 3: 3. The agreement between the Union and the third country shall specify the necessary implementing measures and procedures, and the cases under which the agreement may be restricted, suspended, or terminated, in particular where the third country has been identified as a third country with significant strategic deficiencies in its national anti-money laundering and combating the financing of terrorism regime as referred to in Article 29 of Regulation (EU) 2024/1624 or as a third country with compliance weaknesses in its national anti-money laundering and combating the financing of terrorism regime as referred to in Article 30 of that Regulation. That agreement shall be complemented by an arrangement between the European Central Bank and the national central bank and, where appropriate, the national competent authority of the third country.

Removed:Article 27 – paragraph 3: deleted

Added:Article 19 – paragraph 5: 5. Intermediaries established or operating in the third country shall implement the limits set by the Commission in accordance with Article 16 on the use of the digital euro by natural and legal persons residing or established in the third country, which are applicable in that country.

Removed:Article 28 – paragraph 1 – subparagraph 1 – introductory part: Payment service providers distributing the Digital Euro shall have the option of using the following digital front-end services to allow Digital Euro users to access and use Digital Euro payment services:

Added:Article 22 – paragraph 3: 3. Each online digital euro payment account shall have a unique digital euro payment account number. Each offline digital euro device shall have a unique identifier.

Removed:Article 28 – paragraph 1 – subparagraph 1 – point a: (a) front-end services developed by payment service providers; or

Added:Article 22 – paragraph 4: 4. Each online digital euro payment account or offline digital euro device may be linked to one or more non-digital euro payment accounts that shall be designated by the digital euro user. For the purpose of Article 13(2a) and (4), each online digital euro payment account may only be linked to one non-digital payment account.

Removed:Article 28 – paragraph 2 a (new): 2a. The [Governance Body of the digital Euro Rulebook OR European Central bank] shall, in accordance with Article 26, define a minimum set of technical standards required for the interoperability between front-end services for the purpose of point (b) of Annex I. These standards shall be applied: / (a) by payment service providers when developing own front-end services and; / (b) by the European Central Bank pursuant to paragraph 1, point (b).

Added:Article 22 – paragraph 5: 5. Payment service providers shall allow the use of online digital euro payment account by more than one digital euro users.

Removed:Article 28 – paragraph 3 – point b: (b) Digital Euro wallets can be quickly and easily accessed to and used by Digital Euro users.

Added:Article 23 – paragraph 1: 1. The offline digital euro shall be available for offline digital euro payment transactions as of the first issuance of the digital euro. The online digital euro availability shall be subject to conditions set out in the Article 3.

Removed:Article 29 – paragraph 2: 2. During the execution of a Digital Euro payment transaction, the payer’s payment service provider and the payee’s payment service provider involved in the execution of that transaction shall not verify whether the payer or the payee whose Digital Euro wallet are used for the execution of that Digital Euro payment transaction are listed persons or entities in addition to carrying out verifications under paragraph 1.

Added:Article 23 – paragraph 2: 2. The digital euro, held online or offline, shall be convertible at par between each other and with respect to electronic money and scriptural money, at the request of the digital euro users.

Change 11

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Change 12

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Change 13

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Change 14

Removed:Article 31 – paragraph 2: 2. In exceptional circumstances where a payment service provider is operationally not in a position to provide Digital Euro payment services to Digital Euro users for a prolonged period of time, or has lost the Digital Euro wallet-related data concerned, the European Central Bank and national central banks may authorise the switching of Digital Euro wallets held with that payment service provider to another payment service provider designated by the Digital Euro user. That switching shall enable the new payment service provider to complete the switching without relying on the unavailable payment service provider.

Added:Article 24 – paragraph 1 – point b: (b) provide the functionalities in the online digital euro settlement infrastructure necessary for the execution of conditional digital euro payment transactions, including for the reservation of funds.

Removed:Article 32 – paragraph 3 – point a: (a) assess the exposure to fraud risk of online Digital Euro transactions in real-time at the exclusive use of payment service providers before the transaction is introduced into the Digital Euro transfer infrastructure;

Added:Article 25 – paragraph 2: 2. On request by digital euro users, payment service providers distributing the digital euro shall ensure that those users can rely on the functionalities of their European Digital Identity Wallets in accordance with Article 5a of Regulation (EU) 910/2014.

Removed:Article 35 – paragraph 1 – point a: (a) provision of access for payment service providers to the Digital Euro transfer infrastructure and support the exchange of messages between payment service providers;

Added:Article 26 – title: Existing infrastructures and interoperability

Removed:Article 35 – paragraph 1 – point c: (c) safeguarding the security and integrity of the Digital Euro transfer infrastructure and of local storage devices;

Added:Article 26 – paragraph 1: 1. The European Central Bank shall seek to use to the extent possible and where appropriate the existing infrastructures, protocols and standards governing private digital means of payment and especially those underpinning instant payments.

Removed:Article 35 – paragraph 1 – point d: deleted