Retail Digital Euro: How can a public-private partnership be achieved? Which risks must be avoided?

A general approach on the draft regulations governing the creation of a retail digital euro was agreed on December 19, 2025 by the Member States within Ecofin Council. This approach contains a number of features that raise concerns for economic stakeholders.
This is why, ahead of the forthcoming institutional steps, in particular ahead of the European Parliament deliberations, banks wish to explain their position and set out how, in their view, a genuine public–private partnership could exist – as notably called for by the President of the French Republic – around the Retail Digital Euro project promoted by the European Central Bank (ECB).

The objective of the present paper “The retail digital euro: a public–private partnership – how?” is to answer two key questions:

1.How can a public–private partnership be achieved?
The draft regulations on the digital euro should be amended in order to:

• Require the ECB to reuse existing infrastructures and standards (e.g. instant payments and others), in order to avoid duplication and therefore unnecessary expenditures; this is the public–private partnership pathway.

• Frame, or more tightly regulate, open funding, so that the customer relationship – and the distribution of the retail digital euro – is not monopolised by non-European players.

• Set a low holding limit, consistent with payment usage (for reference, average holdings of central bank money for transaction purposes are close to €100), financial stability objectives, and bank financing of households and companies in the Eurozone.

• Align the workings of offline digital euro with fraud prevention and anti-crime standards. The offline retail digital euro scheme currently envisaged would create an untraceable digital payment instrument, preventing the work carried out by public authorities to fight fraud, money laundering and terrorism financing.

2.Which risks must be avoided?
These proposals would mitigate some of the major risks identified by private payment stakeholders in relation to the retail digital euro.
Even with these changes, we believe that the digital euro project will not resolve the issue of European payment sovereignty, nor strengthen the international role of the euro.

On the contrary, we believe it risks mobilising significant resources – amounting to tens of billions of euros – that could be far better deployed to strengthen European sovereignty.

Our conviction, based on experience, is that European payment sovereignty also depends on European payment players and European payment solutions.