What banks should know now about architecture, regulations and market acceptance
Preparations for the Digital Euro are continuing to progress. In its third progress report, published in summer 2025, the European Central Bank (ECB) provided specific insights into the design. At the same time, legislative work is underway and is expected to be completed by the second quarter of 2026 at the latest. Financial institutions are therefore faced with the task of adapting their existing payment infrastructures to the new requirements at an early stage – even though the final launch date of the Digital Euro is still open.
Digital Euro: Upcoming milestones (last update: 23 September 2025)
- Q3 / 2025: Publication of the results of user studies and focus groups by the ECB.
- October 2025: Decision by the Governing Council of the ECB on continuation after the preparatory phase.
- By early 2026: Political agreement at EU level on the legal framework for the digital euro.
- From 2026: Start of a possible implementation and introduction phase (the ECB expects it to take 2–3 years until actual issuance).
Current status of the project
The ECB is working on a comprehensive set of rules to create the basis for the uniform use of the digital euro in the euro area. Around 70 market participants are currently testing technical functions and use cases on a specially created innovation platform, including scenarios for conditional payments, programmable logic and offline transactions. DPS is also involved in this platform and is contributing a practical use case. The aim is to gain practical insights at an early stage into how the digital euro can be embedded in existing financial infrastructures.
At the same time, the ECB is conducting user studies to incorporate the needs of merchants, consumers and specific target groups into the design. For financial institutions, this means that the future regulations will require not only technological but also organisational adjustments.
Architecture and interoperability: financial institutions as intermediaries
The planned architecture of the digital euro positions banks and other payment service providers as central intermediaries. They provide services for transaction and liquidity management, onboarding, user administration and conflict resolution via dedicated API layers.
The Digital Euro Access Gateway provides the connection to the Eurosystem. Among other things, settlement, alias and onboarding services, fraud management and tokenisation are handled there. Financial institutions thus become not only distributors of the digital euro, but also guarantors of its reach and interoperability.
A key element is guaranteed accessibility: each participating bank must act as both a payer’s intermediary and a payee’s intermediary. This ensures that the digital euro functions seamlessly across borders and institutions.
Practical relevance for financial institutions
The introduction of the digital euro affects banks on several levels:
- Technically, because existing systems and interfaces will need to be expanded.
- Organisationally, because interoperability with existing processes must be ensured.
- Market-wise, because use cases must be created that generate customer benefits and promote acceptance.
We address these aspects in a three-part series of technical articles linked to this article.
Further specialist articles
This introductory article is the starting point for an ongoing series. As soon as the specialist articles are published, the links will be included here:
Technology: ISO 20022 and API interfaces as the basis for technical implementation. We show how financial institutions need to adapt their existing systems to the new messaging standards and what role robust API architectures play in connecting to the Eurosystem.
Interoperability: Integration into existing systems, expansion of core banking applications and integration into the self-service infrastructure (cash machines, non-cash, etc.). The focus is on how institutions can continue to run existing payment processes in parallel while ensuring the reach of the digital euro across all channels.
Market acceptance: Pilot projects such as ‘Tap’n Go’ in public transport with DPS and INIT as examples of practical implementation. Banks need to examine how use cases with high customer benefits can be developed and what investments in infrastructure and cooperation are necessary to achieve this.
