Digital euro customers can leave you and keep their account number, so build switching as a service you win on

In today's banking, the IBAN keeps customers in place, because moving it is not possible. The digital euro removes that barrier. Under Article 31 of the Commission's proposed regulation, a user can move their digital euro payment account to another payment service provider and keep the same account identifier. The ECB and national central banks could also authorise a switch if a provider cannot offer digital euro services for a long time or has lost account data. This is still a proposal, not adopted law, but the ECB's draft scheme rulebook (v0.9) already builds on it.

The rulebook makes switching your job. Scheme participants must let users move their holdings and all or some of their digital euro services to a new provider while keeping the same digital euro account number (DEAN). The move must be seamless, with clear instructions and several ways to start it: online, in the mobile app, and in person. A bank that leaves the scheme must help move its users' accounts before it is technically offboarded. The ECB has also suggested that switching be part of the free basic services, so that no bank can charge an exit fee. That is a suggestion for lawmakers, not a final rule.

The takeaway: plan for both directions now. Map the onboarding steps, such as due diligence, that you will run when a customer switches in. Test that you can release holdings and services cleanly when a customer switches out. Do not count on fees or friction to keep digital euro customers. Keep them with better service, because leaving you will be easy.