Offline Digital Euro Standards: The 25 September ECB Feedback Call

On 18 August 2026 the European Central Bank asked a narrow slice of the technology industry a very specific question: are the secure-hardware standards behind the offline digital euro mature enough, and does the market support them? The call for expression of interest, published through the ECB’s market infrastructure and payments news channel, gives interested organisations until 25 September 2026 to apply to review a preliminary list of standards and answer a Eurosystem questionnaire. It is a technical exercise, aimed at the people who build the chips and the SIMs inside a phone, and it moves the offline digital euro one step closer to a working design.

The invited respondents come from the technology and telecoms industry. The ECB is asking secure element and embedded SIM issuers acting as original equipment manufacturers, mobile network operators and mobile virtual network operators, secure element and eSIM manufacturers, and standards development organisations to comment on the maturity, industry support and implementation constraints of the identified standards. Payment institutions, electronic money institutions and credit institutions are not listed as respondent categories in their capacity as PSPs. The ECB instead invites organisations specialising in the four secure-hardware, telecom and standards-development categories identified in the call.

That is the reason a hardware-standards questionnaire belongs on a reporting and payments desk. The offline digital euro is the part of the project that most resembles cash, and it is the part whose device architecture is still being fixed. It would sit alongside the euro area’s existing retail payment arrangements, including SEPA instant payments, while the digital-euro proposal separately defines an offline payment mode based on local authorisation and settlement. Reading which standards the Eurosystem is assessing now gives an early indication of the offline architecture that selected pilot PSPs will test from the second half of 2027 and that future distributors may later need to support if the digital euro is issued.

Related reading: our guide to the digital euro PSP pilot open call.

The operative dates

The offline standards call sits inside a longer project calendar. These are the dates worth pinning:

• 18 August 2026 – the ECB publishes the call for expression of interest on offline digital euro standards.
• 25 September 2026 – deadline for interested organisations to submit the application form. Selected participants are contacted afterwards.
• 30 October 2025 – the Governing Council decided to move the digital euro project into its next phase, closing the two-year preparation phase that began in November 2023.
• Second half of 2027 – the planned digital euro pilot, expected to run for around 12 months.
• 2029 – the year the ECB aims to be ready for a potential first issuance, on the working assumption that the Regulation is adopted during 2026.

Only the first two dates belong to this specific call. The rest describe the project it feeds. The ECB states that its Governing Council will decide whether to issue the digital euro only after the Regulation on the establishment of the digital euro has been adopted. The beta pilot is planned for the second half of 2027 and is being prepared in alignment with the legislative process; readiness for a potential first issuance in 2029 remains linked to the legislative process.

What the ECB is asking, and who it is asking

The call has a defined shape. Participating organisations receive the preliminary list of identified standards together with a questionnaire, and the questionnaire asks three things: how mature the standards are and how they are expected to develop, the current and anticipated level of industry support, and any implementation constraints or dependencies that could help or hinder deployment and broader market adoption. Feedback can come as written responses, virtual technical exchanges, or a combination, depending on the topic and the participant.

The exercise is confidential by design. The ECB states that contributions will be shared only within the Eurosystem, that one participant’s input will not be shown to another, and that the updated list of standards will not attribute views to any individual organisation. Participants also agree to treat the materials the ECB sends them as confidential. That confidentiality is a signal in itself: the preliminary list of standards is not a public consultation document, and firms wanting to see it have to apply and be selected.

Here is the scope point that is easy to misread. This is a hardware and telecoms exercise, not a payment service provider consultation. Distribution-side firms have their own, separate engagement track, and treating the 18 August call as a bank-facing exercise would send the wrong team to the wrong door. The invited population is the secure-hardware and telecom layer plus the standards bodies that write the specifications those vendors implement. A payment institution acting only in its capacity as a PSP is not one of the respondent categories listed by the ECB; eligibility for this exercise turns on whether the organisation falls within one of the secure-hardware, telecom or standards-development categories identified in the call.

Secure hardware is the offline foundation

Offline is a specific legal and technical concept in the digital euro design, not a marketing label. The Commission’s 2023 proposal defines an offline digital euro payment transaction as one made in physical proximity, where authorisation and settlement both take place in the local storage devices of the payer and the payee. An online transaction, by contrast, settles in the central digital euro settlement infrastructure. The offline leg has to work with no network in the loop at the moment of payment, which is exactly why the hardware matters.

To make local authorisation and settlement safe, the value and the transaction logic have to live in a tamper-resistant part of the phone. In the pilot documentation the ECB describes the secure element as a hardware component that protects transaction processing and stored value against tampering, extraction of cryptographic keys and other attacks, and that prevents the balance from being altered. In the pilot, the ECB-provided software running on the secure element protects against double-spending. The two form factors the ECB names are the embedded secure element and the embedded SIM. The 18 August call is about the standards those components and their secure deployment rely on.

A common misconception is that offline is just online payment with a cached balance that syncs later. Money received offline can be spent again offline without first reconnecting to the network, and settlement between the two devices is immediate and local. The device only has to reach back to a distributor and the Eurosystem to fund or defund, in the way you top up cash at an ATM and later bank what you did not spend. That design is why the security has to live in the device’s hardware.

How the offline euro reaches users

The digital euro reaches the public through supervised intermediaries, and this is where banks and payment institutions enter the picture. The proposed Regulation would let all account servicing payment service providers under the second Payment Services Directive distribute the digital euro, including credit institutions, electronic money institutions, payment institutions and post office giro institutions, alongside crypto-asset service providers regulated under the Markets in Crypto-Assets Regulation that are also account servicing providers. These are the same licence categories being reshaped by the payment services review covered in our PSD3 guide for payment institutions and electronic money. The mandatory-distribution layer is narrower than the general permission to distribute. Article 14(1) would require credit institutions that provide the specified payment services under PSD2, upon request of their clients, to provide basic digital euro payment services to the relevant natural persons. Article 14(3) would also require Member States to designate specified public authorities or post office giro institutions to provide basic services to natural persons who do not hold or do not wish to hold a non-digital-euro payment account.

In the pilot, PSPs do not need to develop the secure-element application or the double-spending protection themselves; the ECB supplies the software that runs on the secure element and handles double-spending protection, whether a provider uses the Eurosystem app or integrates the service into its own mobile app through the provided software development kit. In the pilot, the PSP distribution component relays funding and defunding requests and can incorporate PSP business logic, while the Eurosystem-hosted offline issuance component is responsible for funding and defunding offline beta-digital-euro holdings. Pilot PSPs also manage their end-user relationship and the integration of pilot payment services. Under the proposal, providers register and de-register the local storage devices their customers use for offline payments, and may store the device identifier only for as long as they are facilitating that customer’s offline service.

The 18 August exercise is an input to that build, not a final standards decision. The ECB states that it will use the feedback to refine and update its preliminary list of identified standards. For distributors, the exercise therefore provides an early indication of possible secure-hardware constraints, but it does not yet determine the final standards or the handset population that a future offline digital euro would support.

Privacy and AML work differently offline

The offline design deliberately gives the payment leg a cash-like privacy profile, and the anti-money-laundering controls move to a different point in the flow. The proposal’s dedicated offline rule provides that transaction data is not retained by payment service providers or by the central banks. There is no central record of who paid whom offline, which is the feature that makes it behave like physical cash in proximity.

The control point is funding and defunding. The proposal requires providers to retain funding and defunding data, the amount, the identifier of the local storage device, the date and time, and the account numbers used, and to make that data available to the Financial Intelligence Unit and competent authorities on request. As drafted, the retention obligation points to Article 40 of Directive (EU) 2015/849. Directive (EU) 2015/849 remains in force and is repealed with effect from 10 July 2027 by Directive (EU) 2024/1640; Regulation (EU) 2024/1624 generally applies from 10 July 2027. The digital-euro proposal still refers to Article 40 of Directive (EU) 2015/849, so that cross-reference will need to be read against the final digital-euro text and the new AML framework once applicable.

So the offline euro stops short of full anonymity. It gives privacy at the point of payment while keeping the entry and exit identified. For a compliance team, the relevant split in the Commission proposal is that offline payment transaction data would not be retained, while specified funding and defunding data would be retained; separate Commission implementing acts would set offline transaction and holding limits.

Holding limits and waterfalls are still open

How much offline value a person can hold is one of the questions the legislation has not closed. The proposal would empower the ECB to set limits on the use of the digital euro as a store of value, using tools that could include quantitative limits on individual holdings, and it provides that the digital euro would not bear interest. It does not name a figure. Offline transaction limits and offline holding limits would be set by a Commission implementing act. The level remains unresolved, and holding limits are among the issues the co-legislators are still negotiating.

Under Article 13(4) of the Commission proposal, reverse-waterfall and waterfall functionality is specified for online digital euro payment transactions: a reverse waterfall draws a shortfall from a linked non-digital-euro payment account, while a waterfall automatically defunds excess digital euros to that linked account when an online payment is received above the holding limit. Both require the user’s authorisation, and both assume a link between a digital euro account and an ordinary payment account that a distributor has to operate. The 18 August ECB exercise separately seeks feedback on secure-hardware standards for offline functionality.

This call is not the PSP pilot call

Two ECB calls are moving in parallel, and conflating them is the mistake to avoid. The 18 August 2026 call is a standards-feedback exercise aimed at secure-hardware and telecom vendors and standards bodies. The other track was the call for expression of interest for the digital euro pilot: it was published on 5 March 2026, closed on 14 May 2026, and the Eurosystem has selected 36 PSPs from across the euro area for the pilot starting in the second half of 2027.

The pilot is a controlled exercise, and its transactions do not carry legal tender status. The Eurosystem has described it as involving its own staff, selected merchants on ECB and national central bank premises such as cafeterias, and selected e-commerce, with person-to-person payments online and offline and person-to-business payments at the point of sale and online. The digital transactions in the pilot replicate the technical design for validation only. The ECB’s current pilot timeline has three phases: preparation, development and operational. The development phase starts in the third quarter of 2026 and the operational phase in the second half of 2027; pilot PSP participation is not remunerated.

The standards work and the pilot are connected but distinct. The offline standards call helps fix the secure-hardware base; the pilot then tests distribution and payment flows on top of it. A firm that builds secure elements might engage with the first; PSP engagement is separate, including the selected 2027 pilot and the wider digital euro scheme rulebook that sets the distribution rules.

Where the legislation stands

The device work is running ahead of a law that is not yet adopted. The digital euro Regulation began as a Commission proposal in June 2023. The Council agreed its negotiating position in December 2025. In the European Parliament, the Economic and Monetary Affairs Committee adopted its position on the single currency package by 43 votes to 14 with one abstention and agreed a negotiating mandate for interinstitutional talks, announced at the start of the July 2026 plenary. Trilogue negotiations between the Parliament, the Council and the Commission follow from there, and the ECB continues to plan on the working assumption that the Regulation could be adopted during 2026.

Several of the points that matter most to distributors are exactly the ones still being negotiated, holding limits and the compensation model among them. That is worth keeping in view when reading any timeline: the beta pilot is planned for the second half of 2027 while the legislative process continues, while any decision to issue a digital euro remains subject to adoption of the Regulation and a subsequent ECB Governing Council decision. The ECB is running the offline standards call before the legislation is final, while stating that its preparatory work remains aligned with the legislative process and will be implemented flexibly.

What to do before 25 September

For a secure-hardware issuer, a mobile network operator or a standards body, the action is direct: decide whether to apply by 25 September 2026 through the application form, using the ECB’s dedicated contact address for questions, and be ready to comment on standard maturity, industry support and implementation constraints under confidentiality.

For a bank or payment institution, the work is preparatory. The regulation as proposed would make distributors responsible for registering and de-registering offline devices, and for operating the account links that make waterfall functionality work, so those are the obligations to map against existing systems. Tracking the secure-element and eSIM standards work can help a distributor identify potential hardware constraints, but the 18 August exercise does not yet establish the final standards or the handset population that a future offline service will support. Watching the holding-limit outcome in trilogue will inform the eventual size of permitted offline balances; reverse-waterfall functionality is specified for online payments in Article 13(4) of the Commission proposal and for online beta-digital-euro holdings in the pilot. None of this requires a filing on 18 August, but all of it shapes the build that starts once the rules are set.

Frequently Asked Questions

Can my bank or payment institution respond to the 18 August 2026 call?

The invited respondents are secure element and eSIM issuers and manufacturers, mobile network and virtual network operators, and standards development organisations. For PSPs, the separate pilot call is no longer an application route: it closed on 14 May 2026 and the Eurosystem has selected 36 PSPs. This 18 August standards questionnaire is addressed to the secure-hardware, telecom and standards-development categories listed by the ECB.

Is the preliminary list of standards public?

No. The list is sent only to selected participants under confidentiality, contributions are shared within the Eurosystem, and the ECB has said the updated list will not attribute views to any individual organisation. Firms that want to see the list have to apply by 25 September 2026 and be selected.

Will offline digital euro payments work with no internet connection at all?

Yes at the moment of payment. Offline transactions happen in physical proximity, with authorisation and settlement on the two devices, and value received offline can be spent again offline. Connectivity is needed to fund the device beforehand and to defund it afterwards, similar to withdrawing and later banking cash.

Does the offline function depend on a particular type of phone?

It depends on the device having eligible tamper-resistant hardware. The ECB names the embedded secure element and the embedded SIM as the form factors it is exploring, and the 18 August call is assessing the standards those components rely on. The call does not determine which devices would qualify for a future offline digital euro; the ECB states that it will use the feedback to refine and update its preliminary list of identified standards.

How does the pilot’s use of NFC and the CPACE standard relate to this call?

In the pilot, CPACE is used for secure NFC communication between an individual end-user device and a merchant SoftPOS device in online-mode proximity P2B payments. The 18 August call concerns a different layer: standards relevant to eSE/eSIM secure hardware and secure deployment for offline functionality.

Who decides the offline holding limit, and is there a number yet?

Under the proposal the ECB may set limits on the digital euro’s store-of-value use, and offline transaction and holding limits would be set by a Commission implementing act. No figure has been fixed in the legislation, and holding limits remain an open point in the trilogue negotiations.

Is offline the same as anonymous?

No. The proposal provides that offline transaction data is not retained by providers or central banks, which gives the payment leg a cash-like privacy profile, but funding and defunding data is retained and made available to the Financial Intelligence Unit and other competent authorities. Privacy attaches to the payment, not to the conversion into and out of offline holdings.

Related Articles

• Digital Euro PSP Pilot Open Call: what the Eurosystem’s call for expression of interest asked of payment service providers joining the 2027 pilot.
• Digital Euro Rulebook: The ECB Expert Call for PSPs: how the scheme rulebook process shapes distribution obligations for providers.
• PSD3 for Payment Institutions and Electronic Money: the proposed successor framework for payment institutions and electronic money institutions.
• ECB Appia and Pontes Payment Infrastructure: the Eurosystem’s wider settlement and tokenisation workstreams for EU PSPs.
• SEPA Instant Payments Regulation: the instant-payment obligations that frame the euro-area retail payments backdrop.

Key Takeaways

• Applications to the offline digital euro standards call close on 25 September 2026; only secure-hardware, telecom and standards-body organisations are invited to respond.
• The call examines standards for secure hardware and secure deployment, with the embedded secure element and embedded SIM as the named form factors.
• Offline means authorisation and settlement on both devices in physical proximity; in the pilot, the secure element protects transaction processing and stored value, while ECB-provided software running on it protects against double-spending.
• In the pilot, the PSP distribution component relays funding and defunding requests; the Eurosystem-hosted offline issuance component is responsible for funding and defunding offline holdings. Distributors would also own device registration and the account links behind waterfall functionality under the proposed Regulation.
• Under the Commission proposal, offline payment transaction data would not be retained by PSPs or central banks; funding and defunding data would be retained and made available to the Financial Intelligence Unit and other competent authorities on request.
• No offline holding limit figure is fixed; the ECB would set store-of-value limits and a Commission implementing act would set offline limits, with the level still under negotiation.
• The pilot PSP call closed on 14 May 2026; 36 PSPs have been selected across the euro area for the pilot starting in the second half of 2027. This standards call is separate and follows a different track.
• The beta pilot is planned for the second half of 2027 while the legislative process continues; any potential first issuance remains subject to adoption of the Regulation and a subsequent ECB Governing Council decision.

Sources and References

• European Central Bank, “Call for expression of interest to provide feedback on the list of standards relevant for the offline digital euro”, MIP News, 18 August 2026: ecb.europa.eu
• European Central Bank, “Eurosystem moving to next phase of digital euro project”, press release, 30 October 2025: ecb.europa.eu
• European Central Bank, digital euro pilot overview: ecb.europa.eu
• European Central Bank, digital euro pilot frequently asked questions (secure element, offline design, CPACE, waterfall, pilot phases and PSP selection): ecb.europa.eu
• European Central Bank, “Call for payment service providers to participate in digital euro pilot now open”, MIP News, 5 March 2026: ecb.europa.eu
• European Central Bank, “Declaration of intent to launch call for expression of interest for digital euro pilot”, MIP News, 28 November 2025: ecb.europa.eu
• European Commission, Proposal for a Regulation on the establishment of the digital euro, COM(2023) 369 final, 28 June 2023: eur-lex.europa.eu
• European Parliament, Legislative Train Schedule, Digital euro (COM/2023/369): europarl.europa.eu
• Directive (EU) 2024/1640, Article 77 (repeal of Directive (EU) 2015/849 with effect from 10 July 2027): eur-lex.europa.eu; and Regulation (EU) 2024/1624, Article 90 (application from 10 July 2027): eur-lex.europa.eu

Reading the September window

The 18 August call is small in scope and large in consequence. Its purpose is to help the ECB refine and update the preliminary list of standards relevant to secure hardware and secure deployment for offline functionality; it will not decide whether the digital euro is issued. For the vendors it targets, the next step is concrete: apply by 25 September 2026 and be ready to answer the questionnaire under confidentiality. For everyone building around them, the step is to track which standards come out of it.

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.