The European Central Bank’s digital euro project has prompted the European Banking Federation (EBF) and EuroCommerce to publish written feedback to the ERPB engagement on how the digital euro should fit into the payment ecosystem for merchants and consumers. Both submissions concentrate on how costs would be allocated across stakeholders, how merchant acceptance should work in practice, and how far the initial feature set should be simplified to support adoption. EBF argues the digital euro needs an easy, non-complex fee structure that preserves a viable business case for payment service providers and avoids a “race to the bottom”, and it challenges communications framing the basic use of the digital euro as “free of charge”. It questions the need for a cap on the merchant service charge, notes that Eurosystem processing fees would be only a small fraction of PSP costs, and calls for clarity on pricing rules. On design choices, the federation prefers an initial “4-corner” set-up in which liquidity for reverse-waterfall transactions moves only between the digital euro and a non-digital euro payment account at the same intermediary for an initial 3–5 years, and it asks for a low, stable holding limit to mitigate deposit and liquidity risks while relying on reverse-waterfall functionality for larger payments. It supports standardisation built on existing standards and schemes (including account-to-account and card schemes), urges a minimum viable product with a digital-only design first and staggered inclusion features later, and calls for user experience aligned with intermediaries’ existing interfaces alongside a balance between privacy and controls against illicit finance. EuroCommerce opposes inter-PSP fees and urges reducing the list of “free” basic services to the bare minimum, while stating merchants are prepared to pay their own intermediaries’ processing fees; it also advocates a shared, open and standardised European payment infrastructure that enables least-cost routing, and prioritising basic one-off “buy now, pay now” payments, including offline functionality, ahead of more complex use cases.
European Central Bank 2025-04-28
European Central Bank digital euro end-user workstream draws industry calls for simpler fees, clearer compensation and phased implementation
The European Central Bank's digital euro project prompted feedback from the European Banking Federation (EBF) and EuroCommerce on its integration into the payment ecosystem. The EBF emphasizes a simple fee structure for a viable business case for payment service providers, while EuroCommerce advocates for a shared, open payment infrastructure prioritizing basic transactions. Both stress the importance of standardization and a phased approach to feature inclusion to support adoption.