The Digital Euro’s Planned Infrastructure

The European Central Bank (ECB) has framed the digital euro as a strategic response to Europe’s overreliance on non-EU payment providers. 13 countries in the EU rely entirely on international card schemes, which account for more than half of all euro area card payments. Visa, Mastercard, and Apple Pay dominate the market, leaving European infrastructure exposed to political and commercial dependencies. A digital euro offers the promise – or at least the optics – of European payment sovereignty.

But sovereignty is not only about money. It is also about who builds and governs the technical stack.

Despite the fog of consultation papers and policy briefings, some technical intentions are becoming clearer. 

In October 2025, the ECB announced the selection of five companies – including names like Almaviva, Fabrick, Giesecke+Devrient, equensWorldline – to build core components of the digital euro infrastructure. These components include the wallet, payment initiation, fraud detection, alias lookup, and offline functionality. These providers will implement a synchronous REST API interface aligned with market-standard patterns (e.g., Berlin Group), enabling real-time processing at scale with strong cryptography and fraud-detection support. Offline capability will enable NFC-based P2P and point-of-sale transactions without connectivity, mirroring cash’s universality.

The ECB has reiterated that the digital euro will be accessible not only through a dedicated ECB app, but also via Payment Services Providers (PSPs) own apps and open interfaces that allow the private sector to innovate on top of the public core. In parallel, the ECB launched its Innovation Platform – an environment to allow private sector actors to experiment with integration before the rules are finalised.

The digital euro Rulebook Development Group (RDG), has been preparing the rulebook that will provide a set of rules, standards and procedures to standardised use of the digital euro across the eurozone. 

The digital euro rulebook version 0.9, a draft published in June 2025, provides guidelines about the services scope, eligibility rules, functional and technical requirements, risk management, dispute management, minimum UX requirements, brand rules and even fees and thresholds.

For example, in terms of standards, the rulebook presents the preliminary candidates for three different domains: user domain, PSP domain, and DESP (digital euro services platform) domain. The DESP platform will enable issuance and redemption of the euro as well as functions such as settlement. The standards in this last domain will “adhere to the structure of market-standard RESTful APIs” (e.g. Berlin Group). Already in 2023, the Berlin Group announced a collaboration with Nexo – one of the candidates for POS and ATM standards – to support the design of technical standards that ensure interoperability of digital euro payments.

The rulebook also provides minimum user experience requirements which, according to their fourth progress report published in April, aim to provide a consistent experience across the entire eurozone while “preserving ample flexibility to develop innovative solutions”.  

Thus, while the rulebook does provide rigid minimum requirements to ensure accessibility and fairness to European citizens, it seems to want to strike a balance that might enable PSPs to enhance digital euro services. But to what end? Basic services will be free for consumers, while merchant processing fees—the only way PSPs can recover costs—will be capped. In this case, developing value added services around the digital euro will be critical for PSPs participating in the scheme. Following a four-month market consultation period that ended in October 2025, the ECB is integrating over 2,000 stakeholder comments into a final rulebook draft. Final version expected Q1 2026.

The digital euro pilot is the critical testing ground. Timeline:

• Q1 2026: Call for Expression of Interest opens. The ECB is selecting PSPs across all size/geography categories.
• Q2 2026: Selected PSPs sign participation agreements; infrastructure preparation begins.
• H2 2027–H2 2028: 12-month pilot execution with four use cases: (1) online P2P via alias; (2) offline P2P via NFC; (3) P2B via SoftPOS; (4) e-commerce.

The ECB is hosting a Focus Session on January 15, 2026 (virtual) detailing pilot mechanics and PSP selection criteria. Participation is uncompensated but provides early technical integration experience and direct Eurosystem feedback.

The Digital Euro vs Wero

An emerging conflict is the potential battle with Wero, a scheme launched in July 2024 by the European Payment Initiative, a consortium of 16 European banks and financial services companies. Currently active in Germany, France, and Belgium, Wero builds on SEPA Real-time/ SCT Inst payments to offer instant P2P payments and aims to become Europe’s sovereign payment solution.

Overlapping goals, target user groups and use cases may lead to competition between these two solutions. A potential resolution briefly emerged when, in November 2025, the European Parliament’s rapporteur proposed an offline-only digital euro, which would have effectively positioned digital euro as a cash replacement while leaving online P2P payments to Wero, creating a complementary rather than competitive dynamic. In December 2025, however, the European Council rejected this offline-only approach, insisting instead that the digital euro include both online and offline functionality, ensuring direct competition between digital euro and Wero in the online P2P market segment.

Certain financial institutions have expressed concerns that the split focus on these two approaches may slow down the achievement of an effective pan-European payment infrastructure. In particular, the President of the Hessian Savings Banks Association called for abandonment of the digital euro to accelerate expansion of Wero as the sole EU payment method ‘because some banks in Europe do not want to set up parallel structures and are therefore waiting to see what happens’. 

On the other hand, the BEUC has also voiced concerns surrounding the level of fraud protection offered by Wero, claiming it does not reach the level of international card schemes.

As of now, development of the digital euro is continuing, but whether these two solutions can coexist and even complement each other is still to be seen. 

Non-EU Actors

Despite aiming for European Payment Sovereignty, there are concerns that the design of the digital euro opens doors for further monopolization by non-EU payment services providers. The president of the German Savings Banks and Giro Association (DSGV), Ulrich Reuter, provides a few reasons why the current approach might not work, including that it won’t protect EU payments from foreign providers in any meaningful way. In fact, the digital euro currently requires intermediaries to function and is not tied to any EU market solution. Thus, the president of DSGV claims that it will lead to European PSPs being wrapped up in IT development for years while agile non-EU competitors overtake the EU ecosystem and ultimately continue to dominate the market, as well control the customer experience and data.

In his opinion, a better alternative would be to strengthen Wero, strengthen EU institutions in international competition, and build on the existing consumer trust that European banks have fostered over decades. 

Indeed, the ECB estimates total development costs of €1.3 billion (until first issuance in 2029), with annual operating costs of €320 million from 2029 onward. For the euro area banking sector, integration is more substantial: €4.0–€5.8 billion over four years (2025–2029) to adapt systems and connect to the Digital Euro Service Platform. PSPs must additionally budget for value-added services (analytics, loyalty integration, fraud tooling) as basic services will be free for consumers and merchant fees are capped.

The European Banking Industry

Reuter isn’t the only voice calling for increased consideration of EU banks. 

In a recent article, Vice President of the SPD Economic Forum and the Head of the Finance and Capital Market Expert Forum Peter Güllmann shared his own concerns about the expected involvement—or lack thereof—of the banking industry. 

He states that, as it stands, the digital euro not only poses considerable risks for the banking industry, but also does not involve the institutions enough. In fact, he believes that the digital euro should be “issued exclusively via account-holding institutions” to guarantee security and regulatory compliance, and that duplicate structures will only hinder the initiative. 

Overall, it seems the shared sentiment is to involve existing, trusted institutions in the launch of a sovereign payment solution, whether it be the digital euro or, more preferably, Wero. 

Whether it’s the digital euro or Wero (or both), the EU banking industry is looking at a new payment landscape where European APIs and collaboration overtake US payment providers as the main rails that move European money.

European banks have spent the better part of a decade investing in API technologies and strategies. Open Banking accelerated this trend, but so did internal demands for faster product launches, modularity, and streamlined partner integrations. The digital euro might test these investments. 

Key considerations:

• Value-added services: To what extent will PSPs be able to bundle additional services – such as expense management, loyalty, or analytics – around digital euro payments?
• Standardisation: Which existing payment and identity standards (e.g. SEPA, NextGenPSD2, openFinance, eIDAS) will be used or adapted for digital euro APIs?
• Fee models and commercial incentives: What opportunities might there be for creating revenue through distributing or servicing digital euro wallets? What value can PSPs add?
• Wallet interface flexibility: How much latitude will PSPs have to customise the user experience?
• Data access: Will banks be able to access and use transaction data, and if so, under what regulatory or commercial terms?
• Testing and certification: The ECB’s Innovation Platform provides an environment for sandbox testing, but what will a formal conformance framework look like for broader rollout?

The digital euro will introduce a new form of money, but it will also challenge the assumptions underpinning digital financial infrastructure. In this environment, value won’t stem from exclusivity or access control, but from the ability to orchestrate – to bring together public rails and private experience, and to build new, user-facing propositions on top.

The digital euro might not completely replace banks, but it can redefine their role within a new monetary and technical order. For banks invested in API-led transformation, the digital euro is both a challenge and an inflection point. This will mean recalibrating (once again) their positioning in a shifting landscape. 

As usual, banks that treat APIs not just as technical channels but as strategic interfaces are more likely to maintain relevance. The ECB is building the pipes, but it remains to be seen who builds the bridges.

Suggested further reading: 

Digital Euro Closing Progress report