Digital Euro Rulebook: What the ECB Expert Call Means for PSPs

Last updated: April 2026

If you run payments operations at a licensed PSP in the euro area, the digital euro just moved from “watch this space” to “read the call documents.” On 18 March 2026, the ECB opened a call for experts to join two workstreams under the digital euro Rulebook Development Group. Two weeks earlier, on 5 March, the Eurosystem launched the formal call for PSPs to participate in the digital euro pilot. These are separate tracks, but they feed the same machine: a single set of rules, standards, and procedures that will govern how the digital euro works across the entire euro area.

This article breaks down what the digital euro rulebook is, what the ECB expert call involves, what the pilot means operationally, and what PSPs should be tracking right now. I will flag where details are still pending, because the legislative process is not finished.

What Is the Digital Euro Scheme Rulebook?

The digital euro scheme rulebook is exactly what it sounds like: the operational playbook for how digital euro payments will be initiated, processed, settled, and managed across all participating PSPs. Think of it as the equivalent of the SEPA rulebook for credit transfers or direct debits, but built specifically for the digital euro.

The rulebook will establish a single set of rules, standards, and procedures for the use of the digital euro across the euro area. It covers everything from how consumers fund and defund their digital euro wallets, to how merchants accept payments, to how PSPs interact with the Eurosystem’s settlement infrastructure.

The Rulebook Development Group (RDG) is the body responsible for drafting it. The RDG includes representatives from consumers, retailers, PSPs, and Eurosystem staff. Under the RDG sit multiple workstreams, each tackling a specific domain. The workstreams produce proposals that feed up to the RDG, which then integrates them into the rulebook text.

What the rulebook does not do

The rulebook is not legislation. It does not replace the digital euro regulation that is currently moving through the EU legislative process (COM(2023) 369). The draft rulebook is being developed flexibly to accommodate whatever the final legislation says. If the regulation changes holding limits, or adjusts the compensation model, or redefines the scope of mandatory distribution, the rulebook will follow. Teams that treat rulebook drafts as final specifications will get burned when trilogue negotiations produce amendments.

The March 2026 Expert Call: Workstreams G5 and B1

On 18 March 2026, the ECB published calls for experts to join two RDG workstreams. The application deadline was 10 April 2026. Here is what each workstream covers.

Workstream G5: ATM and terminal implementation specifications

This workstream reviews and develops proposals for the rulebook regarding implementation specifications for ATMs and payment terminals. The scope includes different communication technologies, offline digital euro integration, and reuse of existing standards. The ECB specifically requires expertise in interfacing with or providing ATM and payment terminals.

The operational significance here is substantial. Offline digital euro transactions need terminal hardware that can handle them. If you operate payment terminals or manage a merchant acquiring network, the specifications coming out of G5 will define what your hardware needs to support. The question is not whether your terminals will need updating. The question is what standard they will need to meet.

Workstream B1: Certification and approval framework (renewed call)

B1 is a renewed call, meaning the ECB is looking for additional or replacement experts. The mandate is to develop a proposal for testing and certification of payment and acceptance solutions, as well as infrastructure used by PSPs within the digital euro ecosystem. You need expertise in payments and acceptance devices to participate.

This workstream will shape the compliance requirements for any PSP distributing or acquiring digital euro payments. If B1 produces a certification framework that requires third-party testing of your mobile app or terminal integration, that is a cost and timeline item you need to plan for. The common mistake I see teams make: assuming certification will mirror existing card scheme processes. It might. It might not. The framework does not exist yet.

How experts are selected

Applications required a CV sent to Digitaleuro-scheme-rulebook@ecb.europa.eu. The ECB noted that a letter of support from a current RDG member would be appreciated. The language is appreciated, not required, but the signal is clear: the ECB wants participants who are embedded in the existing stakeholder structure.

The PSP Pilot Call: What It Is and What It Tests

Separately from the rulebook workstreams, the Eurosystem launched a call for expressions of interest on 5 March 2026, inviting licensed PSPs to participate in the digital euro pilot. The deadline for applications is 14 May 2026 at 17:00 CEST.

Pilot scope

The pilot will run for 12 months during the second half of 2027. It will test envisaged digital euro features within a controlled environment. The beta digital euro used in the pilot will not have legal tender status.

Participants will include staff from participating Eurosystem central banks and selected merchants that provide everyday services on the premises of the ECB and euro area national central banks (cafeterias, restaurants), as well as e-commerce merchants. The pilot will test person-to-person payments (online and offline), and person-to-business payments (physical point of sale and e-commerce, including mobile commerce).

This is not a sandbox exercise where you submit API calls and get test responses. Selected PSPs will act as providers of pilot payment services. They will support onboarding of pilot participants (consumers and merchants) and contribute to validating core digital euro functionalities. That means real integration work with Eurosystem technical infrastructure.

Selection criteria

Applications are assessed on eligibility requirements and weighted evaluation criteria covering:

Regulatory compliance
Technical and operational capabilities
Market presence and delivery track record

The Eurosystem will also ensure representative coverage of the euro area market in terms of size, geographical coverage, and market reach. A Luxembourg-licensed PSP with strong local but limited cross-border presence should note that geographic balance is an explicit selection factor.

What PSPs get from participating

Participation is not remunerated. But the trade is clear: selected PSPs gain first-hand experience of a simulated digital euro ecosystem, and their feedback shapes the technical specifications. According to a presentation by ECB Executive Board member Piero Cipollone at the ABI Executive Committee Meeting on 18 February 2026, the pilot offers an early readiness advantage. Participating PSPs can prepare systems, processes, and teams before large-scale roll-out.

There is also a less obvious benefit. The PSPs that participate in the pilot will understand the operational model before their competitors do. When the digital euro goes live (potentially 2029 or later), those PSPs will have a head start on integration, certification, and go-to-market strategy. The PSPs that sit out the pilot will be reading documentation written by the PSPs that shaped it.

What participation requires operationally

Once selected, PSPs must sign a participation agreement with their national central bank. For Luxembourg-based PSPs, this means the BCL. The agreement formalizes the PSP’s role as a pilot payment service provider.

I would flag this to compliance teams now: the participation agreement is a contractual commitment with a central bank. Even though the pilot uses a beta digital euro without legal tender status, the agreement itself will likely contain confidentiality, data handling, and reporting obligations. Review capacity and legal bandwidth need to be factored in before you submit the expression of interest.

The Technical Service Provider Angle

On 27 January 2026, the ECB published a separate call for technical service providers (TSPs) to participate in two expert-level workshops. These workshops took place in early March 2026. They covered two value chains:

Workshop 1: Distribution. TSPs that support PSPs in distributing digital euro payment services to consumers.
Workshop 2: Acquiring and acceptance. TSPs that support digital euro payment services for merchants and acquiring PSPs.

The workshops aimed to take stock of the current European TSP market, explore which parts of the PSP value chain for digital euro services could be supported by TSPs, and gather views on how the Eurosystem could help TSPs facilitate PSP market readiness.

If your institution relies on third-party processors, payment gateways, or terminal management providers, the outcomes of these workshops matter. The Eurosystem has signaled that PSPs may rely on TSPs for digital euro integration, just as they do for existing payment schemes. But the question of TSP certification, liability, and access to Eurosystem infrastructure is still being defined. Do not assume your current processor will automatically support digital euro services.

Where the Legislation Stands

The digital euro regulatory proposal (COM(2023) 369) was published by the European Commission in June 2023. The Council of the EU reached a general approach on 19 December 2025, which the ECB described as a key milestone and a strong statement of support from Member States.

What the Council’s general approach confirmed

The general approach supports the main pillars of the Commission’s proposal:

Legal tender status for the digital euro
Both offline and online use
Mandatory distribution by banks
Weighted average fee caps
Free basic services for consumers

Key changes from the Council

The Council introduced several changes in response to banking sector concerns. According to the Cipollone presentation at the ABI meeting:

Compensation: a transitional period and an inter-PSP fee to align with current business models. The inter-PSP fee means the merchant’s acquiring PSP pays a fee to the consumer’s PSP. This is structurally similar to interchange in card schemes.
Multiple accounts and joint accounts: PSPs would provide these to consumers on a voluntary basis, not as a mandatory requirement.
User interfaces: increased prominence of banks’ interfaces for accessing the digital euro.
Access to mobile devices: more stringent rules for phone manufacturers to give PSPs access to software and hardware for providing offline digital euro services.

The common misreading here: teams assume the Council text is final. It is not. The European Parliament still needs to complete its reading, and trilogue negotiations between Council, Parliament, and Commission will produce the final text. The compensation model, the holding limits, and the exact scope of mandatory distribution could all shift during trilogue. Building your strategy around the Council’s general approach alone is premature.

The PSD3 connection

The digital euro regulation does not exist in isolation. PSD3 (the Payment Services Directive revision) and the Payment Services Regulation (PSR) are moving through the legislative process in parallel. PSD3 will redefine the licensing framework for payment institutions and electronic money institutions, merging the two into a single category. The digital euro regulation will reference the PSD3/PSR framework for definitions of “payment service provider” and “payment account.” If PSD3 changes what qualifies as a PSP, that change flows directly into who must distribute the digital euro. For a deeper look at the PSD3 overhaul, see our guide to PSD3 for Luxembourg payment institutions.

What the Rulebook Will Govern

The digital euro scheme rulebook, once finalized, will cover the operational rules for every actor in the digital euro ecosystem. Based on the workstream structure and published ECB materials, the rulebook is expected to address at minimum:

Onboarding and account provisioning: how consumers open a digital euro account or wallet, KYC/AML requirements specific to the digital euro, and how PSPs verify eligibility
Funding and defunding: how consumers load digital euro from a linked payment account and convert back to commercial bank money
Transaction processing: rules for online person-to-person transfers, offline transactions, and merchant payments at point of sale and in e-commerce
Settlement: how digital euro transactions settle between PSPs and the Eurosystem, including timing, finality, and reconciliation
Terminal and device specifications: what hardware and software standards ATMs, POS terminals, and mobile devices must meet (Workstream G5)
Certification and approval: how PSPs and their solutions get tested and certified for the digital euro ecosystem (Workstream B1)
Fees and compensation: the inter-PSP fee structure, merchant service charges, and what consumers pay (or do not pay)
Offline functionality: rules for offline transactions including limits, reconciliation, and what happens when connectivity is restored

Not all of these are equally advanced. Some workstreams have been running since the investigation phase. Others, like G5, are newly staffed. The rulebook is a living document that will be updated as the legislative process and pilot results produce new inputs.

What PSPs Should Be Doing Now

The operational question for PSPs is not “will the digital euro happen?” The Governing Council moved to the next project phase in October 2025, the Council reached a general approach in December, and the ECB is now staffing workstreams and selecting pilot participants. The question is whether your institution will be ready when mandatory distribution obligations kick in.

Short-term actions (Q2-Q3 2026)

If you have not already, decide whether to apply for the PSP pilot by 14 May 2026. Even if you choose not to apply, read the published technical, operational, and procedural information accompanying the call. It is the most detailed public description of the digital euro’s operational model to date.
Identify which of your current payment processing partners (TSPs) are engaging with the Eurosystem’s TSP workshops. Ask them directly. If they are not tracking the digital euro, that is a supplier risk signal.
Map the gap between your current infrastructure and what a digital euro distribution role would require. This includes mobile app capabilities, offline transaction handling, and settlement connectivity with the Eurosystem.

Medium-term actions (2026-2027)

Track the trilogue negotiations on COM(2023) 369. The final regulation will determine whether distribution is mandatory for all credit institutions, all PSPs, or a subset. It will also set the compensation framework and holding limits. These parameters drive your business case.
Monitor the SEPA Instant Payments Regulation implementation alongside the digital euro. The SEPA instant payments requirements and the digital euro share infrastructure dependencies. If your institution is already building instant payment capabilities, some of that work may apply to digital euro readiness.
Watch for RDG workstream outputs. The ECB publishes summaries and updates on the digital euro scheme rulebook page. Certification requirements (B1) and terminal specifications (G5) will define the compliance baseline for PSPs.

What teams commonly get wrong

Three mistakes I see in how PSPs approach the digital euro:

First, treating it as an IT project. The digital euro is a regulatory obligation (once the regulation is adopted) with IT implications, not the other way around. Compliance, legal, and operations need to own the readiness assessment, not just the technology team.

Second, assuming the digital euro is years away and not worth tracking. The pilot runs in H2 2027. If the regulation passes in 2027 or early 2028, mandatory distribution could be required by 2029. For a PSP that needs to build mobile wallet capabilities, integrate with Eurosystem settlement, and get certified under a new framework, two to three years is tight.

Third, confusing the digital euro with a stablecoin or crypto product. The digital euro is central bank money. It will have legal tender status. It does not sit on a blockchain. The compliance framework will be payments regulation, not MiCAR. Teams that file the digital euro under their crypto desk are misallocating resources.

Key Open Questions

Several critical details remain unresolved. PSPs should track these actively:

Holding limits

The Commission proposal and Council text both include individual holding limits for the digital euro, but the exact amount is not fixed in the regulation. The ECB’s Governing Council will set the limit after the regulation is adopted. Numbers ranging from EUR 3,000 to EUR 10,000 have been discussed publicly, but the final figure will depend on financial stability assessments. This limit directly affects your funding/defunding infrastructure and how you manage waterfall mechanisms (automatic conversion between digital euro and commercial bank deposits when the limit is reached).

The inter-PSP fee level

The Council’s general approach establishes the principle of an inter-PSP fee, similar to interchange in card payments. But the exact fee level is not set. The regulation will likely cap it or delegate the cap to the ECB. Until PSPs know what they will earn per transaction, the business case for voluntary investment in digital euro capabilities remains incomplete.

Offline transaction limits and reconciliation rules

Offline functionality is a core feature of the digital euro, designed to replicate the cash experience. But offline transactions introduce risks around double-spending, stale balances, and delayed reconciliation. The rulebook will need to define offline holding limits, maximum transaction values, and when devices must reconnect. These specifications are still being developed across RDG workstreams.

Certification timeline and cost

Workstream B1 is developing the certification framework, but no PSP knows yet what certification will cost, how long it will take, or whether existing payment scheme certifications (EMVCo, PCI) will count toward digital euro compliance. This is a planning gap.

The European Parliament’s position

The Parliament has not yet adopted its negotiating position. Key MEPs have raised questions about privacy (how much transaction data the ECB and PSPs can see), financial inclusion (ensuring offline access for vulnerable populations), and the impact on bank deposits. The Parliament’s amendments could materially change the regulation’s requirements for PSPs.

Timeline: Key Dates for PSPs

Here is the timeline as it stands in April 2026. Dates beyond mid-2026 are indicative and subject to the legislative process.

30 October 2025: ECB Governing Council decides to move to the next project phase.
19 December 2025: Council of the EU reaches general approach on digital euro regulation.
27 January 2026: ECB opens call for TSPs to participate in workshops (workshops held in early March).
5 March 2026: Eurosystem launches call for PSPs to participate in the pilot.
18 March 2026: ECB opens call for experts for RDG Workstreams G5 and B1 (deadline: 10 April 2026).
14 May 2026: Deadline for PSP pilot applications (17:00 CEST).
H2 2027: Digital euro pilot runs for 12 months.
2027-2028 (estimated): Trilogue negotiations and adoption of the digital euro regulation. [Exact timing depends on the European Parliament’s position and political negotiations.]
Minimum two years after a decision to issue: First issuance of the digital euro. The ECB has indicated 2029 as the earliest possible date, contingent on legislation being adopted.

The Luxembourg Angle

Luxembourg’s payment services sector is heavily cross-border. Many PSPs licensed by the CSSF operate across the euro area under passporting arrangements. For these institutions, the digital euro’s pan-euro-area scope is both an opportunity and a compliance challenge.

The Verification of Payee (VoP) requirements already pushing Luxembourg PSPs to upgrade their infrastructure will overlap with digital euro onboarding requirements. KYC processes for digital euro wallets will need to be consistent with AML/CFT obligations under the upcoming AMLR framework. PSPs that are already investing in identity verification infrastructure for VoP and instant payments should map that investment against future digital euro requirements.

The BCL, as Luxembourg’s national central bank within the Eurosystem, will be the local counterpart for any Luxembourg PSP participating in the pilot. The participation agreement will be signed with the BCL, and any Luxembourg-specific operational requirements will flow through that relationship.

Where the Digital Euro Fits in the EU Payments Stack

The digital euro is one piece of a broader EU payments overhaul. PSPs need to see it in context:

PSD3/PSR: New licensing and operational framework for all payment services. The PSD3 overhaul merges PI and EMI licenses.
SEPA Instant Payments Regulation: Mandatory instant payment capabilities for PSPs, with the regulatory timeline already in motion.
Digital euro regulation: Mandatory distribution by banks, voluntary for other PSPs (subject to trilogue outcome).
AMLR: The new Anti-Money Laundering Regulation that will define KYC/CDD standards applicable to digital euro accounts.

These are not separate projects on separate timelines. They interact. The PSP that plans for them in silos will find conflicting requirements, duplicated investments, and missed synergies.

Frequently Asked Questions

Is the digital euro mandatory for all PSPs to distribute?

Under the Commission’s proposal and the Council’s general approach, mandatory distribution applies to credit institutions (banks). Other PSPs may distribute the digital euro voluntarily. The final scope depends on the trilogue outcome. Non-bank PSPs should track the negotiations closely, because the Parliament could push for broader mandatory distribution.

What is the digital euro Rulebook Development Group?

The RDG is the ECB-convened body responsible for drafting the digital euro scheme rulebook. It includes representatives from consumers, retailers, PSPs, and Eurosystem staff. Under the RDG, specialized workstreams (like G5 for terminals and B1 for certification) develop proposals on specific topics.

Can PSPs still apply for the pilot?

Yes. The deadline for expressions of interest is 14 May 2026 at 17:00 CEST. Applications should be submitted to digitaleuro-Pilot@ecb.europa.eu. The ECB has published detailed technical, operational, and procedural information to support PSP applications.

Will participation in the pilot be remunerated?

No. The ECB has stated explicitly that participation will not be remunerated. The value proposition is early access to the digital euro ecosystem, influence over technical specifications, and readiness ahead of competitors.

How does the digital euro differ from SEPA instant payments?

SEPA instant payments are commercial bank money transferred between payment accounts. The digital euro is central bank money held in a digital wallet or account. They use different settlement infrastructure (TIPS for instant payments, a dedicated Eurosystem platform for the digital euro). A PSP will need to support both, and some infrastructure investments may overlap, but they are distinct payment instruments with separate regulatory frameworks.

What happens if the regulation is not adopted?

The ECB has been clear: a decision to issue the digital euro will only be taken after the relevant EU legislation is adopted. If the regulation stalls or is rejected, the digital euro cannot be issued. However, the preparatory work (rulebook development, pilot, infrastructure) would continue to the extent politically feasible, and could be reactivated if a future legislative cycle succeeds.

When will the rulebook be finalized?

There is no fixed date. The rulebook is being drafted in parallel with the legislative process and will be updated to align with the final regulation. A stable version is unlikely before the regulation is adopted and the ECB Governing Council takes a decision on issuance.

Does the digital euro affect PSPs outside the euro area?

The regulation focuses on the euro area. PSPs licensed in non-euro EU Member States are not directly subject to mandatory distribution. However, PSPs that passport into euro area countries, or that serve euro-denominated payment flows, will need to assess whether voluntary participation makes strategic sense.

PSD3: What It Means for Luxembourg Payment Institutions and Electronic Money Issuers – Covers the PSD3/PSR overhaul, the PI/EMI merger, and what Luxembourg-licensed PSPs need to prepare for under the new framework.
SEPA Instant Payments Regulation – Explains the mandatory instant payment requirements, timelines, and operational impact for EU PSPs.
Verification of Payee (VoP) for Luxembourg PSPs – Details the VoP requirements under the instant payments regulation and what PSPs need to implement.
MiCAR Reporting Obligations – For teams that need to distinguish digital euro (central bank money) from crypto-asset regulatory requirements.
CESOP Reporting Explained – Covers payment data reporting obligations under CESOP, relevant for PSPs managing cross-border payment data flows.

Key Takeaways

The ECB opened a call for experts on 18 March 2026 for two digital euro rulebook workstreams: G5 (ATM/terminal specifications) and B1 (certification framework). The application deadline was 10 April 2026.
The Eurosystem’s call for PSPs to participate in the digital euro pilot is open until 14 May 2026. The pilot runs for 12 months in H2 2027.
The digital euro scheme rulebook will establish a single set of rules for digital euro payments across the euro area. It is still being drafted and will align with the final regulation.
The Council reached a general approach in December 2025. Trilogue negotiations with the European Parliament are the next legislative step. Key details (holding limits, fee levels, exact scope of mandatory distribution) remain open.
PSPs should not wait for the final regulation to start readiness assessments. Map your infrastructure gaps, track your TSPs’ engagement, and understand the pilot requirements.
The digital euro is central bank money, not a stablecoin. Its regulatory framework is payments regulation (PSD3/PSR), not MiCAR.
Luxembourg PSPs should engage with the BCL as the local Eurosystem counterpart for pilot participation and future operational requirements.
Plan the digital euro alongside PSD3, SEPA instant payments, VoP, and AMLR. These interact. Siloed planning leads to duplicated investment and missed dependencies.

Sources and References

ECB: Call for experts to participate in workstreams of the digital euro Rulebook Development Group – 18 March 2026
ECB: Call for payment service providers to participate in digital euro pilot – 5 March 2026
ECB: Call for experts to participate in TSP workshops – 27 January 2026
European Commission: Proposal for a Regulation on the establishment of the digital euro (COM(2023) 369) – 28 June 2023
Piero Cipollone, ECB Executive Board: “Digital euro – Where we stand and what lies ahead,” presentation at the ABI Executive Committee Meeting, 18 February 2026
Council of the EU: General approach on the digital euro regulation – 19 December 2025 [Note: URL is indicative; verify against the Council press release archive]

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.