Sittings · Document

DRAFT REPORT (COM(2023)0368 – C90214/2023 – 2023/0211(COD)) 2025-11-03

On the proposal for a regulation of the European Parliament and of the Council on the provision of digital euro services by payment services providers incorporated in Member States whose currency is not the euro and amending Regulation (EU) 2021/1230 of the European Parliament and the Council

Committee on Economic and Monetary Affairs · Rapporteur: Fernando Navarrete Rojas

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DRAFT EUROPEAN PARLIAMENT LEGISLATIVE RESOLUTION

on the proposal for a regulation of the European Parliament and of the Council on the provision of digital euro services by payment services providers incorporated in Member States whose currency is not the euro and amending Regulation (EU) 2021/1230 of the European Parliament and the Council

(COM(2023)0368 – C90214/2023 – 2023/0211(COD))

(Ordinary legislative procedure: first reading)

– having regard to the Commission proposal to Parliament and the Council (COM(2023)0368),

– having regard to Article 294(2) and Article 114 of the Treaty on the Functioning of the European Union, pursuant to which the Commission submitted the proposal to Parliament (C90214/2023),

– having regard to Article 294(3) of the Treaty on the Functioning of the European Union,

– having regard to the opinion of the European Central Bank of 31 October 2023,

– having regard to the opinion of the European Economic and Social Committee of 13 December 2023,

– having regard to Rule 60 of its Rules of Procedure,

– having regard to the report of the Committee on Economic and Monetary Affairs (A100000/2025),

1. Adopts its position at first reading hereinafter set out;

2. Calls on the Commission to refer the matter to Parliament again if it replaces, substantially amends or intends to substantially amend its proposal;

3. Instructs its President to forward its position to the Council, the Commission and the national parliaments.

Amendment 1

Recital 2

Text proposed by the Commission

Amendment

(2) Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro – COM(2023) 369 final] on the establishment of the digital euro establishes the digital euro and lays down rules concerning it, in particular as regards its legal tender status, distribution, use and essential features, with a view to adapting the euro to technological changes and to ensuring its use as a single currency.

(2) Regulation (EU) .../...+ establishes the digital euro and lays down rules concerning it, in particular as regards its issuance, legal tender status, distribution, use and essential features, with a view to adapting the euro to technological changes and to ensuring its use as a single currency.

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)) and insert the number, date, title and OJ reference of that Regulation in the footnote.

Or. en

Amendment 2

Proposal for a regulation

Recital 3

Text proposed by the Commission

Amendment

(3) It is essential to ensure that all payment services providers, whether incorporated in Member States whose currency is the euro or in Member States whose currency is not the euro, may distribute the digital euro and therefore exercise their freedom to provide services in the Union. The provision of digital euro payment service by all payment services providers would contribute to a high level of innovation, facilitate payments and increase competition across the Union and is necessary to safeguard the integrity of the single market. All payment services providers incorporated in the Union should therefore be in a position to distribute digital euro payment services under the same conditions to natural or legal persons residing or established in the Member States whose currency is the euro, to natural or legal persons who opened a digital euro account at the time they resided or were established in the Member States whose currency is the euro, but no longer reside or are established in such Member States, and to visitors in the euro area. Payment services providers incorporated in Member States whose currency is not the euro should also be in a position to distribute the digital euro to any other natural or legal persons residing or established in Member States whose currency is not the euro and in other countries of the European Economic Area or any third countries subject to the conditions laid down in the Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro – COM(2023) 369 final].

(3) It is essential to ensure that all payment services providers, whether incorporated in Member States whose currency is the euro or in Member States whose currency is not the euro, may distribute the digital euro and therefore exercise their freedom to provide services in the Union. The provision of digital euro payment service by all payment services providers would contribute to innovation, facilitate payments and increase competition across the Union and is necessary to safeguard the integrity of the single market. All payment services providers incorporated in the Union should therefore be in a position to distribute digital euro payment services under the same conditions to natural or legal persons residing or established in the Member States whose currency is the euro, to natural or legal persons who opened a digital euro account or had an offline digital euro device at the time they resided or were established in the Member States whose currency is the euro, but no longer reside or are established in such Member States, and to visitors in the euro area in accordance with any specific limitations set on the use of digital euro pursuant to Regulation .../...+ . The access to and use of the automatic funding and defunding of the online digital euro should be restricted for visitors. Payment services providers incorporated in Member States whose currency is not the euro should also be in a position to distribute the digital euro to any other natural or legal persons residing or established in Member States whose currency is not the euro and in other countries of the European Economic Area or any third countries subject to the conditions laid down in the Regulation (EU) .../...++

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

++ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 3

Proposal for a regulation

Recital 5

Text proposed by the Commission

Amendment

(5) The provision of digital euro payment services by payment services providers incorporated in Member States whose currency is not the euro, should be subject to the same supervisory standards than those applied to payment services providers incorporated in Member States whose currency is the euro. For that purpose, the relevant provisions of Directive (EU) 2015/2366 of the European Parliament and the Council5 , as replaced by Directive (EU) [please insert reference – proposal for a Directive on payment services and electronic money services in the internal market – COM/2023/366 final], Directive (EU) 2015/8436 as replaced by Directive (EU) [please insert reference – proposal for Anti-Money Laundering Directive - COM/2021/423 final] should apply to the supervision by competent authorities and the sanctions regime and supervisory arrangements between the competent authorities of the home Member States and of the host Member States, concerning provision of digital euro payment service by payment services providers established in Member States whose currency is not the euro.

(5) The provision of digital euro payment services by payment services providers incorporated in Member States whose currency is not the euro, should be subject to the same supervisory standards as those applied to payment services providers incorporated in Member States whose currency is the euro. For that purpose, the relevant provisions of Directive (EU) 2015/2366 of the European Parliament and the Council5, Directive (EU) 2015/849 of the European parliament and of the Council6 should apply to the supervision by competent authorities and the sanctions regime and supervisory arrangements between the competent authorities of the home Member States and of the host Member States, concerning provision of digital euro payment service by payment services providers established in Member States whose currency is not the euro.

__________________

5 Directive (EU) 2015/2366 of the European Parliament and of the Council of 25 November 2015 on payment services in the internal market, amending Directives 2002/65/EC, 2009/110/EC and 2013/36/EU and Regulation (EU) No 1093/2010, and repealing Directive 2007/64/EC (OJ L 337, 23.12.2015, p. 35).

6 Directive (EU) 2015/849 of the European Parliament and of the Council of 20 May 2015 on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing, amending Regulation (EU) No 648/2012 of the European Parliament and of the Council, and repealing Directive 2005/60/EC of the European Parliament and of the Council and Commission Directive 2006/70/EC (OJ L 141, 5.6.2015, p. 73).

Or. en

Amendment 4

Proposal for a regulation

Recital 6

Text proposed by the Commission

Amendment

(6) Similarly, as in case of competent authorities of Member States whose currency is the euro under Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro – COM(2023) 369 final], the competent authorities responsible under Directive (EU) 2015/2366 for supervising the provision of payment services should also cooperate with the European Central Bank for the purposes of supervising the application of payment-related obligations laid down in Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro – COM(2023) 369 final].

(6) Similarly, as in case of competent authorities of Member States whose currency is the euro under Regulation (EU) .../...+, the competent authorities responsible under Directive (EU) 2015/2366 for supervising the provision of payment services should also cooperate with the European Central Bank for the purposes of supervising the application of payment-related obligations laid down in Regulation (EU) .../...++

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

++ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 5

Proposal for a regulation

Recital 7

Text proposed by the Commission

Amendment

(7) In accordance with Article (4), point (25), of Directive 2015/2366, funds mean banknotes and coins, scriptural money or electronic money. As a new form of central bank money with legal tender, the digital euro should be considered as funds under Directive 2015/2366 as replaced by Directive (EU) [please insert reference – proposal for a Directive on payment services and electronic money services in the internal market - COM/2023/366 final] which extends the definition of funds to all forms of central bank money issued for retail use. The same definition of funds should be included in Regulation (EU) 2021/1230 of the European Parliament and of the Council of 14 July 2021 on cross-border payments in the Union.

__________________

1a Regulation (EU) 2021/1230 of the European Parliament and of the Council of 14 July 2021 on cross-border payments in the Union (OJ L 274, 30.7.2021, p. 20, ELI: http://data.europa.eu/eli/reg/2021/1230/oj).

Or. en

Amendment 6

Proposal for a regulation

Recital 9

Text proposed by the Commission

Amendment

(9) The European Data Protection Supervisor and the European Data Protection Board were consulted in accordance with Article 42 of Regulation (EU) 2018/1725 and delivered a joint opinion on [XX XX 2023],

Or. en

Amendment 7

Proposal for a regulation

Article 1 – paragraph 1 – point c

Text proposed by the Commission

Amendment

(c) the specific obligations that original equipment manufacturers of mobile devices and providers of electronic communication services within the meaning of Article 2(1) Directive (EU) 2018/1972 established in Member States whose currency is not the euro shall apply in relation to the digital euro.

(c) the specific obligations that original equipment manufacturers of mobile devices and providers of electronic communication services within the meaning of Article 2(1) Directive (EU) 2018/1972 of the European Parliament and of the Council1a established in Member States whose currency is not the euro shall apply in relation to the digital euro.

__________________

1a Directive (EU) 2018/1972 of the European Parliament and of the Council of 11 December 2018 establishing the European Electronic Communications Code (OJ L 321, 17.12.2018, p. 36, ELI: http://data.europa.eu/eli/dir/2018/1972/oj).

Or. en

Amendment 8

Proposal for a regulation

Article 2 – paragraph 1 – point 1

Text proposed by the Commission

Amendment

1. ‘digital euro’ means the digital form of the single currency available to natural and legal persons as defined in Article 2, point 1 of Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro – COM(2023) 369 final];

1. ‘digital euro’ means the digital euro as defined in Article 2, point 1 of Regulation (EU) .../...+;

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 9

Proposal for a regulation

Article 2 – paragraph 1 – point 3

Text proposed by the Commission

Amendment

3. ‘digital euro payment service’ means digital euro payment service as defined in Article 2 point (8) Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro – COM(2023) 369 final];

3. ‘digital euro payment service’ means digital euro payment service as defined in Article 2, point 8 Regulation (EU) .../...+;

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 10

Proposal for a regulation

Article 2 – paragraph 1 – point 5

Text proposed by the Commission

Amendment

5. ‘visitor’ means a natural person as defined in Article 2, point 22, of Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro – COM(2023) 369 final];

5. ‘visitor’ means a natural person as defined in Article 2, point 22, of Regulation (EU) .../...+;

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 11

Proposal for a regulation

Article 2 – paragraph 1 – point 6

Text proposed by the Commission

Amendment

6. ‘Member State whose currency is not the euro’ means a Member State as defined in Article 2, point 23, of Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro – COM(2023) 369 final];

6. ‘Member State whose currency is not the euro’ means a Member State whose currency is not the euro as defined in Article 2, point 23, of Regulation (EU) .../...+;

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 12

Proposal for a regulation

Article 2 – paragraph 1 – point 7

Text proposed by the Commission

Amendment

7. ‘mobile device’ means a mobile device as defined in Article 2, point 31, of Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro – COM(2023) 369 final].

7. ‘mobile device’ means a mobile device as defined in Article 2, point 31, of Regulation (EU) .../...+.

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 13

Proposal for a regulation

Article 3 – paragraph 1 – introductory part

Text proposed by the Commission

Amendment

Within the framework of Directive (EU) 2015/2366, payment services providers incorporated in the Member States whose currency is not the euro may provide digital euro payment services to:

Within the framework of Directive (EU) 2015/2366, payment services providers incorporated in the Member States whose currency is not the euro may provide digital euro payment services set out in Annex I to Regulation (EU) .../... + for offline digital euro and Annex II to that Regulation for online digital euro to:

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 14

Proposal for a regulation

Article 3 – paragraph 1 – point d

Text proposed by the Commission

Amendment

(d) natural and legal persons residing or established in Member States whose currency is not the euro, subject to the conditions laid down in Article 18 of the Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro - COM(2023) 369 final];

(d) natural and legal persons residing or established in Member States whose currency is not the euro, subject to the conditions laid down in Article 18 of the Regulation (EU).../...+;

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 15

Proposal for a regulation

Article 3 – paragraph 1 – point e

Text proposed by the Commission

Amendment

(e) natural and legal persons residing or established in third countries, including territories under a monetary agreement with the European Union, subject to the conditions laid down in Articles 19 and 20 of the Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro - COM(2023) 369 final].

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 16

Proposal for a regulation

Article 3 – paragraph 1 – subparagraph 1 a (new)

Text proposed by the Commission

Amendment

The European Central Bank may restrict the access to and use of the online digital euro for the digital euro users referred to in the first subparagraph, points (b) and (c) of this Article subject to the conditions laid down in Article 16 of the Regulation (EU) .../...+.

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 17

Proposal for a regulation

Article 3 – paragraph 1 – subparagraph 1 b (new)

Text proposed by the Commission

Amendment

The access to and use of the automatic funding and defunding of the online digital euro shall be restricted for digital euro users referred to in the first subparagraph, point (c).

Or. en

Amendment 18

Proposal for a regulation

Article 4 – paragraph 1 – subparagraph 1

Text proposed by the Commission

Amendment

The requirements laid down in Article 13, Article 14(1), Chapter V, Article 18, Chapter VII, Chapter VIII and Chapter IX of Regulation (EU) No X on the establishment of the digital euro, shall be applicable to payment service providers incorporated within the territory of Member States whose currency is not the euro that provide digital euro payment services in accordance with Article 1 of this Regulation.

The requirements laid down in Article 13, Article 14(1), Chapter V, Article 18, Chapter VII, Chapter VIII and Chapter IX of Regulation (EU).../...+, shall be applicable to payment service providers incorporated within the territory of Member States whose currency is not the euro that provide digital euro payment services in accordance with Article 1 of this Regulation.

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../.... (2023/0212(COD)).

Or. en

Amendment 19

Proposal for a regulation

Article 4 – paragraph 1 – subparagraph 2

Text proposed by the Commission

Amendment

The requirement laid down in Article 33 of Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro – COM(2023) 369 final] shall be applicable to original equipment manufacturers of mobile devices and providers of electronic communication services within the meaning of Article 2 (1) Directive (EU) 2018/1972 established in Member States whose currency is not the euro.

The requirement laid down in Article 33 of Regulation (EU) .../...+ shall be applicable to original equipment manufacturers of mobile devices and providers of electronic communication services within the meaning of Article 2(1) Directive (EU) 2018/1972 established in Member States whose currency is not the euro.

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 20

Proposal for a regulation

Article 4 – paragraph 3

Text proposed by the Commission

Amendment

3. In accordance with Article 2(10) of Regulation (EU) 2021/1230 of the European Parliament and of the Council of 14 July 2021 on cross-border payments in the Union , the provisions of that Regulation shall apply to payment transactions in digital euro.

3. In accordance with Article 2(10) of Regulation (EU) 2021/1230, the provisions of that Regulation shall apply to payment transactions in digital euro.

Or. en

Amendment 21

Proposal for a regulation

Article 4 – paragraph 4

Text proposed by the Commission

Amendment

4. Without prejudice to Articles 37 of Regulation [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro – COM(2023) 369 final], Directive (EU) 2015/849 of the European Parliament and of the Council, of 20 May 2015, on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing and Regulation (EU) 2015/847 of the European Parliament and of the Council of 20 May 2015 on information accompanying transfers of funds shall apply with respect to the digital euro.

4. Without prejudice to Articles 37 of Regulation .../...+, Directive (EU) 2015/849 and Regulation (EU) 2023/1113 of the European Parliament and of the Council2a shall apply with respect to the digital euro.

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

2a Regulation (EU) 2023/1113 of the European Parliament and of the Council of 31 May 2023 on information accompanying transfers of funds and certain crypto-assets and amending Directive (EU) 2015/849 (OJ L 150, 9.6.2023, p. 1, ELI: http://data.europa.eu/eli/reg/2023/1113/oj).

Or. en

Amendment 22

Proposal for a regulation

Article 5 – paragraph 1

Text proposed by the Commission

Amendment

1. Directive (EU) 2015/2366 of the European Parliament and of the Council shall apply to the supervision by competent authorities and the sanctions regime and supervisory arrangements between the competent authorities of the home Member States and of the host Member States, concerning the activities of payment service providers established in Member States whose currency is not euro in relation to the digital euro for the purposes of applying this Regulation and the obligations referred to in Chapters IV, V, VI and VII of Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro – COM(2023) 369 final].

1. Directive (EU) 2015/2366 of the European Parliament and of the Council shall apply to the supervision by competent authorities and the sanctions regime and supervisory arrangements between the competent authorities of the home Member States and of the host Member States, concerning the activities of payment service providers established in Member States whose currency is not the euro in relation to the digital euro for the purposes of applying this Regulation and the obligations referred to in Chapters IV, V, VI and VII of Regulation (EU) .../...+.

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 23

Proposal for a regulation

Article 5 – paragraph 2

Text proposed by the Commission

Amendment

2. Directive (EU) 2015/843 shall apply to the supervision by competent authorities and the sanctions regime and supervisory arrangements between the competent authorities of the home Member States and of the host Member States concerning the activities of payment service providers incorporated in Member States whose currency is not euro established in relation to the digital euro for the purpose of applying thus Regulation and the obligations contained in Chapter IX of Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro – COM(2023) 369 final].

2. Directive (EU) 2015/849 shall apply to the supervision by competent authorities and the sanctions regime and supervisory arrangements between the competent authorities of the home Member States and of the host Member States concerning the activities of payment service providers incorporated in Member States whose currency is not the euro established in relation to the digital euro for the purpose of applying this Regulation and the obligations contained in Chapter IX of Regulation (EU) .../...+.

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 24

Proposal for a regulation

Article 6 – paragraph 1

Text proposed by the Commission

Amendment

For the purposes of supervising the application of Chapters IV, V and VII of the Regulation (EU) [please insert reference – proposal for a Regulation of the European Parliament and the Council on the establishment of the digital euro – COM(2023) 369 final] the competent authorities referred to in Article 4(1) shall cooperate with the European Central Bank.

For the purposes of supervising the application of Chapters IV, V and VII of the Regulation (EU) .../...+ the competent authorities referred to in Article 4(1) shall, where relevant, cooperate with the European Central Bank.

__________________

+ OJ: Please insert in the text the number of the Regulation contained in document PE-CONS .../... (2023/0212(COD)).

Or. en

Amendment 25

Proposal for a regulation

Article 7 – paragraph 1

Regulation (EU) 2021/1230

Article 2 – point 10

Text proposed by the Commission

Amendment

Article 2(10) of Regulation (EU) 2021/1230 of the European Parliament and of the Council of 14 July 2021 on cross-border payments in the Union is replaced by “‘funds’ means central bank money issued for retail use, scriptural money or electronic money”.

In Article 2 of Regulation (EU) 2021/1230 of the European Parliament and of the Council, point 10 is replaced by the following: “‘funds’ means central bank money issued for retail use, scriptural money or electronic money.

Or. en

EXPLANATORY STATEMENT

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.