Who sees the payment: What does the twelve-part series on the digital euro show?

Editorially reviewed: 22 October 2026 · Legal status checked up to: 22 October 2026. Time-bound statements are dated; legal acts that are announced but not yet published are marked as such. The series reflects the state of negotiations at the time of publication (September to October 2026); the trilogue on the digital euro is ongoing and a supplementary part on its outcome is planned.

For whom: Banks (SI) Banks (LSI) Reporting service providers For payments, regulatory reporting and compliance functions in banks; parts 7 and 8 address reporting officers, parts 9 to 11 finance and risk functions.

Four theses stood at the start; none fell, none survived unchanged: legally the digital euro is modelled on cash, economically it follows the card; online the central bank sees less than a card scheme, offline your own bank sees every funding and defunding; regulatory reporting comes after the launch, only tax law is ahead; and resilience exists only offline, at the price of new dependencies on the phone maker and on one central platform.

Why does every part follow the same 15-euro purchase?

So that only the means of payment makes the difference: every part follows the same purchase. The amount sits below every threshold at which the law treats a payment differently – below the 50 euros for contactless payment without PIN and below the 1,000 euros of the Transfer of Funds Regulation. What differs therefore lies in the money, not in the amount:

• Cash: central bank money; nobody sits in the middle.
• Debit card: a claim on the bank; the card scheme sees card number, merchant, place and time.
• Instant payment or Wero: a claim on the bank; via TIPS the Eurosystem sees name and account number.
• Euro stablecoin: a claim on the issuer; on a public blockchain everyone sees it, pseudonymously and worldwide.
• Digital euro online: central bank money; the platform sees amount and pseudonym, your own bank every payment.
• Digital euro offline: central bank money; nobody watches the payment, the bank sees funding and defunding.

The twelve parts

1. Part 1: Why Europe is negotiating the digital euro – In Austria a card payment at the bakery runs through Visa or Mastercard; there is no national scheme and Wero is not yet at the till. Two cases show the vulnerability: the Visa outage of June 2018 with 5.2 million failed transactions and both schemes' withdrawal from Russia in 2022. The part presents the four theses and the state of play: the technology is ahead of the law, the trilogue has run since July 2026, issuance follows no earlier than 2029 under the Eurosystem's plan. Post on LinkedIn (German) →
2. Part 2: 15 euros, six ways, and what Covid has to do with it – The same purchase paid six times – legally there are three debtors behind it: central bank, bank or issuer, visible only in disputes and losses. Covid merely accelerated the decline of cash (share at the point of sale 72 % in 2019, 52 % in 2024); the winner was the contactless card that merchants already accepted. In Austria the 50-euro contactless limit, raised temporarily in 2020, became permanent. Post on LinkedIn (German) →
3. Part 3: Modelled on cash, following the card – Legally the digital euro is legal tender with mandatory acceptance; operationally banks distribute and settle it like a card, at the same terminals (around 25.7 million in the euro area). The contradiction: micro-enterprises may refuse it unless they accept debit cards or instant payments – legal tender inherits its reach from a means of payment nobody has to accept. Austria counts 143,080 terminals and has no national card scheme. Post on LinkedIn (German) →
4. Part 4: Price anchor or price follower? – Debit card merchant fees averaged 0.44 % of turnover in 2022; for the digital euro the whole merchant fee is capped and scheme fees disappear. But the cap is derived from the card price (Council presidency: around 50 basis points) and banks and acquirers keep the margin. Thesis 1 modified: during the transition the digital euro is a price follower. For Austria even the baseline figure is unpublished; around 80 % of card payments run through Mastercard. Post on LinkedIn (German) →
5. Part 5: Who reads along when you pay – Who sits in the middle differs by payment method: the card scheme with card number, merchant, place and time; the Eurosystem for instant payments via TIPS with name and account number; the digital euro platform online only with amount and pseudonym. Online the central bank therefore sees less than a card scheme – and less than it already sees in TIPS today (4.6 million payments a day in May 2026). Your own bank still sees every payment. Post on LinkedIn (German) →
6. Part 6: Offline does not mean traceless – Nobody watches a device-to-device payment, but funding and defunding are seen by the bank with amount, device identifier and time; lose the phone, lose the money. The offline limit is set by the Commission and would also apply between private individuals. Thesis 2 modified: more privacy towards card scheme and central bank, not towards your bank and the authorities – who may see what is set by law, not by the type of money. Post on LinkedIn (German) →
7. Part 7: Regulatory reporting comes afterwards – The digital euro is not on the bank's balance sheet; funding works like a cash withdrawal. Fraud statistics, payment statistics, FINREP and LCR have no line for it; confirmed fraud cases go daily to the Eurosystem as operator, not to supervisors. Only tax law is ahead: since 1 January 2026 an account in central bank digital currency counts as a depository account under the CRS. Thesis 3 confirmed and refined. Post on LinkedIn (German) →
8. Part 8: What reporting officers should know – If the platform fails, every bank must decide whether this is a major ICT incident under DORA – reported to the FMA within four hours, without knowing the cause. Add two balances (the bank's sub-ledger, the original at the Eurosystem), double fraud reporting, FIU requests to be answered within five working days from July 2027 and cost reporting with auditor confirmation. Three preparations can be made today. Post on LinkedIn (German) →
9. Part 9: 18 or 4 billion? The cost dispute – PwC estimates around EUR 18 billion over four years for the banking associations, the ECB 4.0 to 5.77 billion. The gap comes from counting (institutions or groups), sharing assumptions (90 to 98 % joint development) and deductions of around 16 %. Both leave out running costs; only the Eurosystem has quantified its own at 1.3 billion up to issuance and 320 million a year. In Austria 339 of 445 institutions belong to sectors with shared IT. Post on LinkedIn (German) →
10. Part 10: Resilience, but only offline – In the Spanish blackout of 2025 card payments fell by 55 %; online the digital euro would not help, offline only with a pre-loaded amount. Switch-off by a non-European card scheme is gone, the dependency moves to the secure element controlled by the phone maker; availability targets for the platform are unpublished while the ECB demands 99.85 to 99.95 % from banks. Thesis 4 modified. In Austria the concentration extends to IT providers and sector centres. Post on LinkedIn (German) →
11. Part 11: Bank run by app? – In the ECB's worst case a EUR 3,000 holding limit would drain EUR 699 billion, 8.2 % of retail sight deposits; the banking study arrives at 739 billion. The limit does not slow the pace, it caps the amount – and at weekends the central banks' payment system is closed for 48 hours. The OeNB calculates a 9.0 % outflow of retail deposits for Austria; 7.4 % of banks would fall below the liquidity threshold. Proposed limits range from 500 to 3,000 euros. Post on LinkedIn (German) →
12. Part 12: Four theses, none rejected, none unchanged – The balance: theses 1, 2 and 4 modified, thesis 3 confirmed and refined. Open remain liability for platform outages and offline double-spending as well as performance targets for the platform – the rulebook sets them only for banks. Three conditions decide: whether people use the digital euro, whether phone makers open the secure element and whether the Eurosystem discloses what its platform must deliver. A supplementary part follows after the trilogue. Post on LinkedIn (German) →

Which four theses does the series test, and with what result?

Three theses were modified and one confirmed and refined; none fell.

What does the digital euro mean for reporting officers?

For regulatory reporting the digital euro is above all a holding that is shown nowhere. It is not on the bank's balance sheet, FINREP and LCR show only the deposit outflow, and neither the fraud statistics to the OeNB nor the ECB's payment statistics have a line for it. Five points from parts 7 and 8 can be prepared before the legal text is final:

• Sub-ledger of customer holdings: the bank keeps its own list, the original sits at the Eurosystem; reconciliation frequency and ownership need settling, because the CRS year-end balance is also reported from that list.
• ICT incident without an internal cause: a platform outage can trigger a DORA report within four hours whose root-cause analysis only the central banks can deliver; that workflow belongs in incident management.
• Fraud twice: daily per case to the operator, half-yearly in aggregate to the OeNB – two reporting channels, one data set.
• Answers in days: from July 2027 FIU requests must generally be answered within five working days; funding data must be retrievable.
• Costs with an auditor: under the Council mandate selected banks report their digital euro costs and card fees, confirmed on request – a cost accounting that mostly does not exist today.

What is special about Austria's situation?

The position is particular, and every part ends with a look at Austria: 62 % of payments at the till are in cash (SPACE 2024), yet there is no national card scheme as a fallback, so card payments in shops depend almost entirely on Visa and Mastercard. The OeNB stands on both sides – it builds part of the platform as one of six central banks and oversees the payment systems. Merchant fees are unpublished, 339 of 445 credit institutions source their IT from a few sector providers, and in the OeNB's extreme case 9.0 % of retail deposits would flow out. Austria has more independence to gain than countries with a national card, but depends more on actual use.

Frequently asked questions

Is the digital euro on the bank's balance sheet?

No. It is a liability of the Eurosystem towards the holder, like a banknote; the bank only keeps the account in the customer's name. Funding works in the bank's balance sheet like a cash withdrawal: fewer deposits, fewer central bank reserves. The Eurosystem knows the holding, the bank knows the holder.

Must a bank report a platform outage under DORA?

It must assess whether a major ICT incident has occurred and then report to the FMA within four hours – although it does not know the cause and the final report requires a root-cause analysis. A joint report by all banks is unlikely, because the platform probably does not count as an ICT third-party provider; the central banks themselves are not subject to the reporting duty.

When does the digital euro arrive?

Under the Eurosystem's plan no earlier than 2029. Before that come the political agreement in the trilogue, formal adoption, publication in the Official Journal and the issuance decision of the ECB Governing Council. The pilot with 36 payment service providers is planned for the second half of 2027.

What data does the central bank see in an online payment?

Under the draft, amount and pseudonym, plus account identifier and IP range for fraud prevention – no merchant, no place. That is less than a card scheme sees today and less than the Eurosystem processes for instant payments via TIPS. Your own bank still sees every online payment.