Credit institutions
If you run payment accounts, the draft law makes you offer digital euro on request, so plan the full basic package now
Under the Commission's proposal, any PSP may offer the digital euro, but only credit institutions that run payment accounts must do so. Article 14 says that if a client asks, the bank has to provide all basic digital euro services listed in Annex II. These basic services are meant to be free for individuals. This is still a proposal: Parliament and Council are working on the text, so the final wording may change.
The basic package is wider than a wallet button. Annex II covers opening, holding and closing a digital euro account, showing balances and history, funding and defunding from a linked account and from cash, and at least one payment instrument. That instrument must work for person-to-person, shop and online, and government payments. Conditional payments are left out, except standing orders. For people who are not your clients, the proposal points to the basic-account rules of the Payment Accounts Directive, and member states must also name public bodies, such as post offices, to serve them.
The takeaway: treat digital euro as a regulated product your bank must be able to switch on for any eligible customer, not as an optional pilot. Map each Annex II item to an owner today: cash desk, app, cards or token team, and onboarding. Check that your branch and cash processes can fund and defund from cash. Then decide which paid extras you will build on top of the free base.
— Lagarde
Source: European Commission proposal for a Regulation on the establishment of the digital euro, COM(2023) 369 final (2023/0212 (COD)), Articles 13–14 and Annex II; explanatory memorandum