On the proposal for a regulation of the European Parliament and of the Council on the legal tender of euro banknotes and coins

The Single Currency Package responds to the increasing digitalisation of the economy, in which access to cash – currently the only form of the single currency available to citizens – is declining. The Rapporteur supports this package to ensure that the euro, in all its forms, remains the foundation of a competitive, innovative, open and strategically autonomous European economy. Europe’s single currency is more than a means of payment: it is a cornerstone of the Union’s strategic autonomy.

To guarantee continued access to central bank money in the digital era, a digital version of the single currency should be introduced, while reinforcing the right of EU citizens to use cash. Europe must also address its overreliance on non-European payment providers. A genuine European response in payments is needed to strengthen strategic autonomy amidst geopolitical instability.

Under the Rapporteur’s vision, defining that response is the purpose of this proposal. He clearly distinguishes between two digital forms of the single currency accessible to citizens and businesses.

On the one hand, the offline digital euro is understood as a tokenised version of cash, not account-based, but operating through “device-to-device” payments. It guarantees privacy, resilience, and universal accessibility even in times of network failure or crisis. Stored and transferred locally on secure devices, it preserves the right of citizens to hold central-bank money in all circumstances. In short: digital cash.

On the other hand, the online digital euro is conceived as an account-based system that requires a digital euro settlement infrastructure operated through the ECB. By its very nature, the online form of the digital euro entails risks of bank disintermediation, loss of deposits, direct competition with private payment solutions and, ultimately, a negative impact on the financing capacity of European businesses and households.

Today, Europe’s payment ecosystem works: citizens can pay conveniently, and the system is stable. The issue is not one of functionality, but of scale, reach, and dependency. For over twenty years, Europeans have shared a currency but not an indigenous pan-European payment system. Many transactions still depend on non-European providers, exposing Europe to technological and geopolitical risks. The Commission’s 2023 proposals sought to address this via a digital euro, but since then, private initiatives have advanced and Europe’s priorities have evolved.

The Rapporteur’s amendments offer a nuanced, realistic and updated response. They propose establishing an offline digital euro while making the online version conditional on the absence of a pan-European sovereign retail payment solution, to be verified by the Commission through a market test once the ECB concludes its offline digital euro preparatory work.

The Rapporteur stresses his agnostic stance toward the outcome of this test, from which he expects an objective assessment of the private sector’s capacity to operate at euro-area scale in person-to-person, point-of-sale and e-commerce payments. It is in the Rapporteur’s interest to clarify that this assessment by the Commission shall in no case delay the ECB’s preparatory work or the overall process.

This approach provides a holistic, proportionate and evidence-based response, balancing financial stability with competitiveness in the payments system. Under this framework, the offline digital euro would represent a proportionate European response, free from financial stability risks, and ensuring European payment sovereignty — without prejudging the possibility that the private sector could solve the scale and dependency gaps of the European payments ecosystem through interoperability.

In conclusion, the Rapporteur’s amendments to the establishment of the digital euro are formulated to ensure that the offline digital euro is introduced to address the challenge of the digitalisation of the economy, while the online digital euro is made conditional upon the absence of a pan-European private sovereign retail payment solution. This conditionality ensures that the digital euro acts as a safety net against market fragmentation, not as a parallel payments ecosystem hindering private solutions from reaching pan-European scale or discouraging continuous innovation.

Nothing in this position questions the importance of developing the wholesale digital euro, which the Rapporteur strongly supports as the most effective means to modernise interbank settlement, enhance cross-border efficiency and strengthen monetary-policy transmission across the euro area.

Separately, the Rapporteur treats this package as one coherent vision for the future of money in Europe, built upon three reinforcing pillars:

 safeguarding the universality and access to cash,

 introducing a digital form of central-bank money following a speedy but cautious approach which will also serve as a means of payment, and

 allowing its cross-border provision in a way that respects non euro area Member States and third countries’ competences, and sovereignty and preserves the integrity of the single market.

The Single Currency package sets out a vision of a Europe adapted to the digital era, and committed to its strategic autonomy through openness: Europe leading by building capacity, sovereignty and resilience not by closing markets.

The rapporteur views this package as a single, coherent response to a twin challenge: Europe’s over-reliance on non-European payment providers and the need to anchor monetary sovereignty in an open, competitive and innovative market to ensure that Europe possesses its own backbone of payment resilience.

Being this approach the core of the Rapporteur’s proposal, he also addresses several additional concerns regarding the rules, framework and operational aspects of the legislation.

The Rapporteur clarifies the framework under which payment service providers (PSPs) established and supervised in the Union may distribute the digital euro in line with Directive (EU) 2015/2366. PSPs shall offer online and offline digital-euro payment services to residents and businesses in euro-area Member States, and to certain non-resident users, under defined conditions.

Distinct rules apply to the online and offline digital euro. For the online digital euro, PSPs must enable users to fund and defund their digital-euro accounts—manually or automatically—from or to non-digital-euro accounts, offline devices or cash, within limits based on financial stability. For the offline digital euro, PSPs shall provide equivalent functionalities through secure devices, allowing users and merchants to load or redeem balances in line with stability and AML requirements.

The amendments establish an automatic defunding mechanism linking each online digital-euro account to a single non-digital-euro account designated by the user, ensuring compliance with holding limits and continuity of payments. The digital euro distributed by PSPs shall be convertible at par with other forms of euro-denominated money, and users shall maintain a contractual relationship only with PSPs, not with the ECB or national central banks. Users may hold one or several online accounts with the same or different PSPs, and providers must make information on features and conditions publicly available free of charge.

The rapporteur introduces specific holding limits to ensure that the digital euro is serving as a means of payment and it cannot evolve into a store of value. Holding limits, combined with funding and defunding mechanisms, they prevent excessive accumulation while enabling frictionless daily use, safeguarding the banking sector’s intermediation role and financial stability.

Trust also depends on fairness. The Rapporteur sets principles on fees and charges to ensure that PSPs required to distribute the digital euro are fairly compensated while merchants are not overcharged. Since at the time of issuance there will not yet be sufficient information on average unit costs or the total volume of digital-euro transactions, a transition period will be needed. During that period, fees and charges will be based on a “no-worse-off” clause, ensuring a high degree of proportionality by applying criteria comparable to existing means of payment at a granular level.

Moreover, the Rapporteur proposes that if, after a ten-year transition period, it is demonstrated that a cost-based compensation model delivers lower costs, greater efficiency and competition in payment markets, and prevents cross-subsidisation across merchant business models or within the European payments ecosystem, the Commission should propose a new legislative framework on fees and charges for the provision of digital-euro payment services.

The Rapporteur also stresses that citizens will embrace the digital euro only if it protects privacy as effectively as cash protects anonymity. AML/CFT controls shall apply at the user level, not by marking individual digital units, thereby preserving fungibility and preventing programmable or traceable money. The ECB must also ensure that fraud and counterfeiting levels remain below those of comparable instruments. Privacy, security and technological resilience are thus design imperatives, not optional features.

The two accompanying proposals complete this framework. The Regulation on the legal tender of euro banknotes and coins guarantees universal acceptance and access to cash in proportion to citizens’ demand, ensuring financial inclusion and resilience. Its coordination with the digital euro regulation is essential to avoid any perception of substitution. The Regulation on the provision of digital euro services in non-euro-area Member States provides the external dimension, allowing PSPs in those countries to offer digital-euro services under conditions respecting national prerogatives and the integrity of the single market.

In a nutshell, the Rapporteur’s proposal recognises that technological sovereignty in payments cannot be legislated into existence; it must stem from competition, innovation and trust. By prioritising private European infrastructures, the Single Currency Package safeguards both the euro’s stability and Europe’s competitiveness. It modernises the single currency without transforming it into a public payment monopoly.