Banking & Fintech /

Digital Euro and the Risk of Legislative Delays. ECB Warns of Growing Dependence on Big Tech and International Card Schemes

On 6 February 2026, ECB Executive Board member Piero Cipollone warned that delays in adopting the digital euro legislation could weaken the project’s momentum and further entrench Europe’s reliance on international card schemes and non-European Big Tech payment solutions.

The ECB consistently frames the digital euro as “digital cash”– retail central bank money for everyday payments, designed to complement banknotes rather than replace them. The broader policy objective is to strengthen the EU’s monetary sovereignty at a time when cash usage is declining and key payment infrastructure increasingly lies outside European control.

The ECB consistently frames the digital euro as “digital cash”- retail central bank money for everyday payments, designed to complement banknotes rather than replace them. The broader policy objective is to strengthen the EU’s monetary sovereignty at a time when cash usage is declining and key payment infrastructure increasingly lies outside European control.

Digital Euro as an Element of Monetary Sovereignty – Why Is the ECB Sounding the Alarm?

Cipollone backs the argument with concrete figures: “almost two-thirds” of card-based transactions in the euro area are processed by non-European companies, and in 13 euro area countries in-store payments depend entirely on international card schemes. In the ECB’s framing, this is a strategic autonomy and resilience question, not merely a market structure debate.

The “Big Tech” reference is framed geopolitically: when core payment rails are controlled outside the EU, Europe’s exposure to political, regulatory and commercial decisions beyond its influence increases.

Digital Euro in Practice – Operational Model and Design Assumptions

The ECB’s promise is broad usability: anytime and anywhere, universally accepted, and free of charge for basic use. Privacy is a design pillar: offline transactions are intended to provide cash-like privacy, while online payments would show the ECB/NCBs only encrypted codes and the amount, without identifying the payer or payee.

Public concerns about surveillance remain part of the political backdrop. Cipollone’s answer is twofold: the ECB will continue issuing banknotes and work to keep cash widely accepted and available, while the Council file on “strengthening the legal tender status of euro cash” runs in parallel to the digital euro regulation.

Fees, Caps and Terminal Readiness – Business Implications of the Digital Euro

For merchants, the ECB argues that the digital euro could address two pain points: dependence on international schemes and fee dynamics. Cipollone highlights high, non-transparent fees, notes that small merchants can pay multiples of what larger merchants pay, and suggests that the digital euro could materially reduce acceptance costs while enabling instant settlement and offline acceptance during temporary connectivity issues.

A further operational point is that some benefits could start “pre-launch.” Once legislation is adopted, standards can be finalised and made available, allowing merchants, when renewing terminals, to ensure that new devices are “digital euro-ready.”

How Will the Proposed Regulatory Framework Affect PSPs and Fintechs?

The ECB insists banks will not be disintermediated. The digital euro would be distributed through banks and other supervised intermediaries, holdings would not be remunerated and would be subject to holding limits, and wallets could be linked to commercial bank accounts to support larger payments without turning the digital euro into a store of value.

The Council’s negotiating position adds several PSP-relevant “hard” design choices: limits on holdings, mandatory consumer services that must be free of charge, a framework to ensure access to mobile device manufacturers’ hardware/software for interface and service providers, and a compensation model with fee caps for at least five years.

Operationally, the ECB also signals the next step for the industry: a call for interest inviting PSPs to participate in a pilot exercise, alongside an explicit encouragement to integrate the digital euro into existing payment solutions and treat it as a pan-European standard that private players can build on.

Could Delays in Adopting the Regulation Entrench the Current Balance of Power in Payments?

The ECB states it cannot implement the digital euro without a robust legal framework, and frames adoption as increasingly urgent to reduce reliance on foreign companies and unlock public-private synergies. The Council has already agreed on its negotiating position, and Cipollone expects the European Parliament to reach its position in May.

The ECB has been working on the digital euro since 2020 and plans a pilot in 2027; the political decision-making process in the EU institutions remains the gating factor. That is why Cipollone emphasises that delays would entrench dependence and increase exposure to Big Tech solutions and stablecoins.

The ECB has been working on the digital euro since 2020 and plans a pilot in 2027; the political decision-making process in the EU institutions remains the gating factor. That is why Cipollone emphasises that delays would entrench dependence and increase exposure to Big Tech solutions and stablecoins.

Shared Infrastructure or Market Competition – How Will the Project Interact with Private Initiatives?

Media coverage also notes that banks and private actors are building alternatives to global schemes and wallets.

The ECB’s story, however, is “public rails”: a public infrastructure that private companies can use to compete on services, quality and innovation, while achieving pan-European reach more easily. For fintechs, this can translate into both an opportunity and a new layer of operational and compliance requirements.

Is Your Organisation Prepared for “Digital Euro Readiness”?

In practice, readiness translates into concrete strategic and operational decisions: defining your role within the system, updating contracts and merchant terms, aligning data architecture with privacy-by-design principles, revisiting fee mechanics, and securing access to device-level functionality for mobile use cases.

Contact our teamwe advise PSPs and fintechs on the regulatory and contractual aspects of payment-market change – from mapping obligations and key risks to drafting documentation, refining processes and supporting discussions with partners and supervisory authorities.

Author team leader D&P Legal Jacek Szczytko
check full info of team member: Jacek Szczytko

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