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The digital euro in 2026: where the law stands and what banks in Central and Eastern Europe should prepare

Techtone Group · Oct 5, 2026 · Last reviewed Oct 14, 2026

The digital euro is not law yet. The Council agreed its position in December 2025, the European Parliament confirmed its mandate on July 9, 2026, and the two are negotiating. If the regulation is adopted in 2026, the ECB plans a pilot from mid-2027 and could be ready for a first issue during 2029.

Where the legislation stands

The ECB has said that the final decision to issue will only be taken once the legislation is adopted. Its timeline assumes adoption during 2026: a pilot exercise and first transactions from mid-2027, and the whole Eurosystem ready for a potential first issue during 2029.

What the Council position would mean for banks

• Holding limits. The ECB would set a maximum amount each person can hold, within a ceiling approved by the Council and reviewed at least every two years. The limit decides how many deposits could move out of banks, and it is the number most banks are waiting for.
• Online and offline use. The digital euro would work with and without an internet connection, alongside cards and other private payment options.
• Capped fees. Interchange and merchant service charges for digital euro payments would be capped for at least five years, and consumers could not be charged for basic services.
• Distribution through supervised providers. Banks and other payment service providers would open wallets, onboard users and handle payments, with the compensation model still to be settled.

Why it matters in Central and Eastern Europe

• Euro area banks in Slovenia, Slovakia, Croatia, the Baltic states and Bulgaria would be distributors from day one, with the onboarding, wallet and acceptance obligations that come with it.
• Banking groups headquartered or active in non-euro countries would carry the obligations through their euro area subsidiaries, and will want one regional design rather than several.
• Processors and acquirers face a new acceptance scheme with capped merchant fees, which changes the economics of card acceptance for the same merchants.
• Retail deposit funding in euro area subsidiaries could shift, depending on the holding limit, which belongs in funding and liquidity planning now.

How it differs from cards and instant payments

The digital euro would be central bank money, a direct claim on the Eurosystem, held in a wallet that a bank or payment provider operates. Cards and instant transfers move commercial bank money between accounts. For a consumer the experience could look similar to paying by card or by phone, but for banks the difference is fundamental: money held in a digital euro wallet is not a deposit on the bank's balance sheet. That is why the holding limit and the link to the customer's bank account, which can top up or sweep the wallet automatically, matter so much to the business case.

Offline payments add a second difference. Paying device to device without a connection, with privacy close to cash, requires secure hardware in phones or cards and new processes for limits, recovery and disputes. These are product and technology questions that banks will have to answer even if the ECB provides much of the infrastructure.

What to prepare while the law is negotiated

• Model deposit outflows under a range of holding limits, for example EUR 500, 1,500 and 3,000 per person, and the effect on funding costs.
• Assess the acceptance economics for your merchant base under capped fees, against today's card income.
• Decide the role you want: full distributor with your own wallet, distributor through the ECB app, or acquirer only.
• Map the technology dependencies: core banking, mobile app, card and acquiring platforms, and the offline device requirements.
• Follow the trilogue closely; the holding limit and the compensation model are the two decisions that change the business case.

This article is general information. The legislation is still under negotiation and the final text may differ from the positions described here.

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