Payment service providers
Digital euro disputes run through a fixed two-step process, so get your service desk ready for it now
The draft digital euro rulebook sets out how payment disputes will work. There are two steps. First comes a pre-dispute, where the payer raises the problem with the payee through their PSPs. If the payee does not answer, or the payer finds the answer not good enough, the payer's PSP opens a formal dispute through the Eurosystem's central platform (DESP). Disputes must use a fixed list of reasons, each tied to set scenarios and supporting documents. If the payer still disagrees, the case can go to arbitration, which sits outside the Eurosystem. The payer's PSP must then report the result back to DESP.
For PSPs, this is mostly an operations job. Your front line will need to pick the right reason code, collect evidence, and track deadlines and status updates through DESP's interfaces. Refunds are a separate flow: the payee starts them, usually at the payer's request, and they may trigger funding from a linked account if the merchant side lacks funds. The draft also says a PSP that leaves the scheme must keep handling open disputes and keep the related records.
Keep in mind that this is a draft. Rulebook v0.91 is not final, and the digital euro regulation itself is still in talks between Parliament and Council. Still, the shape is clear enough to start now: map these steps against your current card and instant-payment dispute processes, and plan the staff training and system links you will need.
Source: ECB, Digital euro scheme rulebook v0.91 (24 April 2026), Section 6 and Annex D2 #5 (Dispute management) and #7 (Settlement); ECB Rulebook Development Group progress report, October 2025