Licensed outside the euro area? You may still offer digital euro, so map which customers you could serve

The digital euro is not only for firms in the euro area. A companion draft law, COM(2023) 368, would let payment service providers licensed in EU countries that do not use the euro offer digital euro services. Under its Article 3, they could serve people and businesses in the euro area, people who opened a digital euro account while living there and later moved away, and visitors. They would use their existing PSD2 passport, and supervisors in their home country would check that they follow the rules.

Serving customers in your own country is a separate step. Under Article 18 of the main proposal, COM(2023) 369, residents of a non-euro member state can use the digital euro only if that state asks for access and accepts set conditions, and the ECB and the national central bank agree an arrangement. Even then, the digital euro would not be legal tender there, so local shops would not have to take it.

Both texts are still proposals. On 9 July 2026, Parliament voted to open talks with the Council, and its position backs letting banks and PSPs from non-euro countries distribute the digital euro. Talks are now under way. If you already serve euro-area clients, list which of them fall into the groups above, check that your passport covers those services, and speak to your supervisor early. Do not plan a home-market digital euro offer until your country starts the Article 18 process.