Digital euro and CBDCs. 6 chapters and a final quiz.
Why 137 countries are exploring a central bank digital currency, how the ECB designed the digital euro (intermediated model, holding limits, offline mode, privacy), and where the timeline and the legislation stand. What banks fear, and what China’s e-CNY and the Bahamas’ Sand Dollar teach us. And what it all means in practice for a PSP or a merchant.
Distinguish central bank money from commercial bank money, and position CBDCs against cash, deposits, and stablecoins
Describe the digital euro’s design: intermediated model, holding limits, waterfall, offline mode, and privacy safeguards
Lay out the ECB’s timeline (pilot in 2027, possible issuance in 2029) and the state of the EU legislative process
Analyze the controversies: deposit flight, costs for banks, overlap with Wero, and surveillance concerns
Chapter 1. The case for a central bank digital currency.
When you pay in cash, you use central bank money: a banknote is a direct claim on the ECB, with no intermediary risk. When you pay by card or credit transfer, you use commercial bank money: your deposit is a claim on your bank, which can fail. A CBDC (central bank digital currency) solves a simple equation by giving the public a digital form of the former. Cash, without the paper.
Cash
Bank deposit
Stablecoin
CBDC (digital euro)
Issuer / debtor
Central bank
Commercial bank
Private issuer (Circle, Tether, etc.)
Central bank
Counterparty risk
None
Bank failure (insured up to €100,000)
Quality of reserves and redemption
None
Form
Physical
Digital
Digital (public blockchain)
Digital (central bank infrastructure)
Works offline
Yes
No
No
Yes (offline mode planned)
Anonymity
Full
None
Traceable pseudonymity
Strong offline, pseudonymized online
Four forms of money: who owes what to whom?
The project’s timing reflects the rapid decline of cash as a payment method. In the euro area, cash fell from 72% of point-of-sale transactions in 2019 to 52% in 2024 (ECB SPACE study). If this erosion continues, public money disappears from everyday life, and with it its role as an anchor. That anchor guarantees that a euro at BNP is worth a euro at ING, because each is convertible on demand into central bank money. The historical trigger dates back to June 2019, when Facebook’s Libra announcement confronted central banks with the prospect of a private global currency backed by a network of 2 billion users.
⚓
Preserving the monetary anchor
Keep public money in everyday use, so that it still guarantees convertibility and the singleness of money as cash fades.
🛡️
Payment sovereignty
In 13 of the 21 euro area countries, there is no longer a domestic card scheme. About two-thirds of card payments run through Visa or Mastercard, and the dominant wallets (Apple Pay, Google Pay) are American.
💵
Countering digital dollarization
Dollar-denominated coins make up 99% of stablecoins. Without a public euro alternative, the tokenized US dollar could take hold in European payment habits.
🔌
Resilience
A public payment method that works offline protects against outages, cyberattacks, and network failures. The Iberian blackout of April 2025 made the argument very concrete.
🤝
Inclusion
Free access to basic digital payments for people who are unbanked or underserved by the market.
🔑
CBDC ≠ crypto, CBDC ≠ stablecoin
A retail CBDC is neither a cryptocurrency (there is no decentralization: the central bank controls issuance and settlement) nor a stablecoin. With no private issuer and no reserves to audit, it is sovereign money itself. The right analogy is a dematerialized banknote, plus the possibilities and debates that digital brings.
Europe’s everyday payment infrastructure is largely non-EuropeanVisaMastercardApple PayGoogle PayPayPalAlipay
52 %
cash share of point-of-sale payments in the euro area in 2024 (72% in 2019)
ECB, SPACE 2024 study
137
countries and currency unions exploring a CBDC, representing 98% of global GDP
Atlantic Council CBDC Tracker, 2025
3
retail CBDCs officially launched: the Bahamas, Jamaica, Nigeria
Atlantic Council, 2025
13 / 21
euro area countries with no domestic card scheme, reliant on international networks
ECB, 2026
🎯 Quick question
What is the fundamental difference between a euro in your bank account and a central bank digital euro?
Chapter 2. The ECB’s design: intermediaries, holding limits, offline, privacy.
The digital euro’s design answers a seemingly contradictory constraint. It must give the public access to central bank money without disintermediating banks and without turning the ECB into a retail bank. The answer comes down to four choices: an intermediated model, holding limits, an offline mode, and a privacy-by-design architecture.
The intermediated model: the ECB settles, PSPs distribute
The ECB provides the settlement infrastructure and issues the money, but it never opens accounts for the public. Banks and PSPs distribute the digital euro: onboarding, KYC, wallets, apps, and customer support. Users will access the service through their bank’s app or through an app provided by the Eurosystem, always via a licensed intermediary.
An online digital euro payment, end to end
Payer
Initiates the payment from their wallet (banking app or digital euro app)
Alias, QR code, or NFC; no IBAN to enter
➜
Payer's PSP
Authenticates the customer and checks the balance; triggers the reverse waterfall if needed
If the wallet balance falls short, the difference is drawn instantly from the linked bank account
➜
Eurosystem (settlement platform)
Settles the transfer in central bank money within seconds
The ECB sees only pseudonymized data: it cannot link the payment to an identity
➜
Payee's PSP
Credits the merchant’s wallet and applies the waterfall
Any excess above the limit (zero for merchants) is automatically swept to the bank account
Holding limits and the waterfall: containing deposit flight
Each individual will be able to hold only a capped amount of digital euros. The limit is meant to prevent savers from moving their deposits en masse into central bank money, especially during a banking crisis. The figure has not been set. Preparatory work floated €3,000, banks are lobbying for €500, and in 2025 the ECB published a methodology for setting the limit as close to launch as possible. Merchants and businesses will have a limit of zero: any digital euro they receive is immediately swept to their bank account (waterfall). In the other direction, the reverse waterfall allows a payment larger than the wallet balance by drawing automatically on the linked account. The limit becomes invisible in the payment experience.
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Zero interest, by design
The digital euro will pay no interest. The choice guards against deposit flight as much as it asserts a philosophy: digital cash, a payment instrument, not an investment or a monetary policy tool aimed at households.
Offline mode: cash on your phone
Planned from the first release, offline mode will allow payments with no network connection at all. Preloaded digital euros are stored locally in the phone’s secure element (or on a dedicated card), then transferred device to device over NFC. Settlement is local and final. Neither the PSP nor the ECB sees the transaction, whose details are known only to the payer and the payee, for privacy comparable to cash. Beyond privacy, the resilience argument has become tangible. During the massive power outage on the Iberian Peninsula on April 28, 2025, payment terminals went dark and only people holding banknotes could pay. Offline digital cash is the structural answer to that scenario.
Privacy: pseudonymization by architecture
Online, the Eurosystem will see only pseudonymized data that technically cannot be linked directly to a person. Customer due diligence stays with PSPs, which remain subject to the usual AML/CFT rules. The separation between identity data and payment data is built into the architecture and written into the proposed regulation. The ECB keeps stressing that the digital euro would offer a level of privacy higher than today’s private payment solutions, which monetize transaction data.
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“Programmable money”: laying a myth to rest
No, the digital euro will not be money with an expiry date or restricted uses: the proposed regulation explicitly prohibits programmable money. That should not be confused with conditional payments, such as paying automatically on delivery or setting up recurring payments. These are simple automations controlled by the user, which any bank can already offer. The distinction is technical, but it sits at the center of the public debate. A payments professional should be able to explain it.
Dimension
Choice made
Goal
Distribution
Intermediated model: banks and PSPs distribute, the Eurosystem settles
Avoid disintermediating the industry; reuse what exists (KYC, apps)
Individual holdings
Capped (not set; €500 to €3,000 under debate), zero interest
Limit deposit flight from banks
Merchant holdings
Zero limit + automatic waterfall to the bank account
The digital euro is a way to collect payments, not a treasury tool
Payment experience
Reverse waterfall, alias, QR, NFC, P2P, e-commerce, and point of sale
Cover every everyday use case; the limit stays invisible
Offline
Local purse in a secure element, device-to-device settlement
Cash-like resilience, maximum privacy
Online privacy
Pseudonymized for the Eurosystem, KYC handled by PSPs
Neither centralized surveillance nor full anonymity
Pricing
Free for basic personal use; merchant fees regulated
A public good, funded like banknotes
The digital euro’s design choices at a glance
🎯 Quick question
What happens when a merchant receives €500 in digital euros, given that its holding limit is zero?
Chapter 3. Timeline and legal framework: where things stand.
The digital euro is moving forward on two tracks that don’t advance at the same pace. The ECB leads the technical work, while the legislative process plays out among the Commission, Parliament, and the Council. The ECB has always been clear: no issuance without an adopted regulation. Here is the full timeline, with the key milestones.
June 2019
The Libra shock
Facebook announces its private global currency. G7 central banks sharply accelerate their CBDC work.
Oct. 2020
First ECB report
The ECB publishes its foundational report on a digital euro and launches a public consultation, which draws a record 8,200 responses.
Oct. 2021–Oct. 2023
Investigation phase
Two years to settle the main design options: intermediated model, holding limits, offline, privacy.
June 28, 2023
Proposed regulation
The European Commission presents the “single currency” package: a regulation establishing the digital euro and a text enshrining the legal tender status of cash.
Nov. 2023
Preparation phase
Finalizing the rulebook, tendering for technical components, running experiments.
Oct. 30, 2025
Green light for the next phase
The Governing Council decides to move to the next phase. A pilot exercise is targeted for mid-2027, and first issuance is possible in 2029, subject to adoption of the regulation.
Mid-2027
Pilot and first transactions
Real transactions in a controlled environment with volunteer PSPs, if the legal framework allows it.
2029
Target for first issuance
Possible public launch, rolled out gradually by use case and by country.
≈ €1.3B
development cost estimated by the ECB through first issuance (2029)
ECB, Oct. 2025
≈ €320M/yr
estimated annual running cost for the Eurosystem thereafter
ECB, Oct. 2025
2027
pilot exercise with real transactions, targeted for mid-year
ECB, decision of Oct. 30, 2025
2029
possible year of first issuance, subject to adoption of the regulation
ECB, Oct. 2025
On the legislative side, the June 28, 2023 proposal is still under negotiation as of mid-2026. The Council made progress in late 2025 on two points: governance of the holding limit, where member states want a say rather than leaving it to the ECB, and the compensation model for market participants. Parliament moved more slowly: its ECON committee adopted its position on June 23, 2026 (43 votes to 14), confirmed in plenary on July 9, 2026 (416 votes to 169), opening trilogue talks aimed at a deal by the end of 2026. The most contested issue remains who sets the holding limit: a monetary prerogative for the ECB, a political choice with consequences for financial stability for the co-legislators.
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An issuance decision with a double lock
Remember the institutional mechanics. The EU regulation creates the legal framework (legal tender, mandatory acceptance, holding limits, privacy). Then the ECB Governing Council decides whether or not to issue. The October 2025 decision commits technical resources, not issuance itself. No law, no digital euro, however mature the platform.
🎯 Quick question
What exactly did the ECB Governing Council decide on October 30, 2025?
Chapter 4. Controversies: bank deposits, costs, privacy.
Few ECB projects have drawn so much organized opposition, and it has come on three fronts. Banks fear for their deposits and their costs. Part of the political class and the public raises the specter of surveillance. And skeptics question its usefulness, pointing to overlap with existing solutions. Let’s examine each argument, along with the responses.
First front: deposit flight
Demand deposits are the raw material of bank lending. The Copenhagen Economics (2023) study, commissioned by European banking federations, puts potential outflows at up to €739 billion if every adult in the euro area converted €3,000 of deposits into digital euros. Bank funding would then become more expensive, and ultimately so would credit. The nightmare scenario is a digital bank run. If a rumor hit a bank, moving deposits into central bank money would no longer mean lining up at an ATM, just three seconds in an app. The ECB responds through design (holding limit, zero interest, waterfall) and notes that its own studies find the impact manageable with a well-calibrated limit.
Banks’ argument
ECB response
Deposit flight of up to €739B (Copenhagen Economics, 2023) and weaker lending
Holding limit, zero interest, waterfall: the digital euro is designed as a payment instrument, not a store of value
Accelerates bank runs in a crisis
The limit mechanically caps outflows; accessible central bank money already exists (banknotes), and going digital changes its speed, not the principle
Implementation costs of up to €30B for euro area banks (PwC-Strategy& study, 2024, for the banking associations)
Estimates seen as excessive; reuse of existing infrastructure (SEPA Instant, banking apps), and compensation planned for distributors
Overlap with instant payments and Wero: why add another public rail?
Wero is a private solution from a bank consortium; the digital euro is a pan-European public good with legal tender status, and the two can coexist or even share rails
Loss of interchange revenue and payment data
Compensation model: distributing PSPs will earn regulated merchant fees, as with cards, but capped by the regulation
Bank arguments vs. ECB responses, point by point
⚠️
The Wero paradox
The same banks that fund Wero (EPI’s pan-European wallet, launched in 2024 in Germany, France, and Belgium) oppose the digital euro on the grounds that it would duplicate it. There is also the opposite argument, which credits pressure from the ECB project for part of the banks’ push behind a European wallet. For industry watchers, the two projects keep each other in check and could end up sharing acceptance standards and infrastructure.
European private initiatives the project disruptsWEWeroCACartes BancairesVisaMastercard
Second front: privacy and the surveillance charge
“Monetary Big Brother,” “money with an expiry date,” “Chinese-style social control”: the project crystallizes fears that go well beyond its actual design. That design provides for pseudonymization, a near-anonymous offline mode, and an explicit ban on programmable money. But suspicion weighs on it structurally, fed by the idea that any technical capability ends up being used. Europe’s answer is legal (write the safeguards into the regulation, not into promises) and architectural (make surveillance technically impossible, not merely prohibited). The geopolitical contrast fuels the debate. The US banned any CBDC by executive order on January 23, 2025, followed by a House vote in summer 2025. Washington is betting everything on private dollar stablecoins, regulated under the GENIUS Act.
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The transatlantic lens
Two monetary strategies now clash head-on. The US is privatizing the digital dollar, with regulated stablecoins and a banned CBDC, while Europe is keeping the digital euro public, with a retail CBDC and stablecoins supervised under MiCA. For payments professionals, the debate is anything but academic: it determines which rails will be available in each market by 2030.
🎯 Quick question
Which feature of the digital euro’s design directly addresses the risk of massive bank deposit flight?
Chapter 5. Global overview: e-CNY, the Bahamas, mBridge, and others.
The global CBDC map shows a paradox: near-universal exploration, very few launches, and disappointing adoption everywhere. Three retail CBDCs are officially in circulation (the Bahamas, Jamaica, Nigeria), and some 50 pilots are under way, including China’s giant. Major Western economies are moving in different directions, when they haven’t reversed course altogether.
Country / region
Project
License type
Key lesson
Bahamas
Sand Dollar
Launched Oct. 2020, the world’s first retail CBDC
Marginal adoption: less than 1% of currency in circulation
Nigeria
eNaira
Launched Oct. 2021
Documented adoption failure: 98.5% of wallets inactive (IMF, 2023), despite government incentives
Jamaica
JAM-DEX
Launched in 2022, legal tender
Same finding: without a use case that beats existing options, the public stays away
Eastern Caribbean
DCash
Launched in 2021… shut down in Jan. 2024 for a complete overhaul
A CBDC can die: operational resilience is non-negotiable
China
e-CNY
Giant pilot since 2019–2020, steadily expanding
180M wallets and CNY 7.3 trillion in cumulative transactions (June 2024), but a tiny fraction of money in circulation next to Alipay and WeChat Pay
India
e-rupee
Retail pilot since Dec. 2022
About 6M users (2025): methodical caution from the RBI, backed by UPI’s success
Sweden
e-krona
Pilot completed, project on hold
A pioneer of the debate, the Riksbank is waiting for a proven need and a political mandate
United Kingdom
Digital pound
Design phase
In 2025, the Bank of England publicly questioned the need for a retail CBDC if private innovation is enough
United States
–
CBDC banned by executive order (Jan. 23, 2025)
A deliberate choice of regulated private stablecoins as the digital dollar
Euro area
Digital euro
Preparation phase, pilot targeted for mid-2027
The most advanced retail project among major advanced economies
Overview of the main CBDC experiments (as of mid-2026)
China’s case deserves a closer look. The e-CNY is by far the world’s largest pilot. In June 2024, the central bank reported 180 million personal wallets and CNY 7.3 trillion in cumulative transactions (≈ €930 billion). An international operations center opened in Shanghai in 2025. And yet the e-CNY remains a tiny fraction of Chinese payments, where Alipay and WeChat Pay, embedded in daily habits for 15 years, leave it almost nothing. Even the state best able to impose a payment method runs into the iron law of payments: you can’t shift payment habits without a clear benefit for the end user.
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The universal lesson from the pioneers
The Bahamas, Nigeria, Jamaica, China: four radically different contexts, one conclusion. Launching a CBDC is an engineering problem; getting it adopted is a value-proposition problem. So the ECB is focusing on the experience (reverse waterfall, offline, free basic use, mandatory acceptance) rather than on technical prowess alone. And it is taking its time.
The other CBDC: wholesale, less publicized and further along
While retail CBDCs search for users, wholesale CBDCs (restricted to settlement between financial institutions) are advancing quickly. The mBridge project (China, Hong Kong, Thailand, and the UAE, joined by Saudi Arabia in 2024) settles cross-border payments in digital central bank currencies. The BIS withdrew in late 2024 and left the members to carry on, a sign of how geopolitically sensitive the project is. In July 2025, the Eurosystem launched a two-track initiative. Pontes connects TARGET to DLT platforms, with a pilot expected in late 2026, while Appia sets out a long-term vision for global wholesale settlement. Switzerland already settles digital bonds in central bank Swiss francs on SIX Digital Exchange (Project Helvetia). For market infrastructures, this quiet revolution is probably closer than the retail digital euro.
🎯 Quick question
What does China’s e-CNY experience teach us about CBDC adoption?
Chapter 6. Practical impact for PSPs and merchants.
Let’s leave macroeconomics behind. If the regulation is adopted and issuance is approved, the changes reach the point of sale and a PSP’s roadmap. There are many of them, and the proposed text makes some mandatory. The digital euro would have legal tender status. Merchants that already accept digital payment methods would be required to accept it, with exemptions (notably for microenterprises). On the distribution side, account-servicing banks would have to offer basic services to customers who request them.
Accepting digital euro payments at the merchant
Customer
Pays in digital euros by NFC or QR code, online or in store
Reverse waterfall: the payment goes through even if their wallet balance falls short
➜
Merchant's acquiring PSP
Routes the transaction to the Eurosystem settlement platform
A role similar to card acquiring: certification, routing, service
➜
Eurosystem
Settles instantly in central bank money
Immediate finality: no chargeback risk in the card sense
➜
Merchant’s PSP
Waterfall: sweeps the funds to the merchant’s bank account
Zero limit for businesses; cash management unchanged
🏷️
Regulated fees
The proposed regulation caps merchant service charges by reference to the costs of comparable payment methods. It would give merchants unprecedented leverage when negotiating card fees.
⚡
Instant, final settlement
Payment in central bank money, immediate finality, less counterparty risk, and simpler accounts receivable management.
🔧
Acceptance workload
Upgrading terminals (NFC, QR), checkout systems, and e-commerce; supporting offline mode; certifying a new scheme. The scale of the work will depend on how much existing standards are reused.
📊
Constrained data
Because of pseudonymization, less usable transaction data will be available than on card rails. A lost revenue source for some business models, a selling point for others.
For PSPs, the equation cuts both ways. The threat is a public rail with capped fees that cannibalizes part of card and credit transfer volumes, where the margins are. The opportunity is a new market: distributing the digital euro (wallets, onboarding, merchant acquiring, value-added services on top of the public rail). Inter-PSP compensation set out in the regulation will apply, modeled on the economics of acquiring. The winners will be the players that can pool their investments, and those that have already industrialized instant payments and Wero will have a technical head start.
Company
Do now
Start at the pilot (2027)
Merchant
Track the timeline; inventory the terminal estate and e-commerce flows; price acceptance into card processing RFPs
Test acceptance with your PSP; train checkout staff; integrate the digital euro into online checkout flows
PSP / acquirer
Take part in rulebook consultations; map the impact on card revenue; design for reuse of SCT Inst rails
Apply for the ECB pilot; certify acceptance solutions; build the distribution offering (wallets, onboarding)
Retail bank
Model the deposit impact under different limit assumptions; prepare app + waterfall integration
Roll out wallets to pilot customers; test the reverse waterfall and offline mode in live conditions
Readiness checklist: 2027 pilot, 2029 issuance
🔑
What to watch through 2027
Four signals will shape the project’s future: adoption of the regulation and who sets the limit, then the level of the limit, the final fee model for merchants, and the list of pilot PSPs for 2027. A payments professional who tracks these four markers will know before anyone else whether the digital euro becomes a mass-market rail or a contingency infrastructure.
🎯 Quick question
Under the proposed regulation, which merchants would be required to accept the digital euro?