On 14 July 2026 the European Central Bank (ECB) selected 36 payment service providers for the digital euro pilot, drawn from more than 50 applications to a call for expressions of interest issued in March. The test starts in the second half of 2027 and runs for twelve months. The project therefore has a participant list, a draft rulebook and a timetable. A law to underpin it does not yet exist.
The digital euro regulation has been in trilogue between Council, Parliament and Commission since 13 July 2026. The pilot is being built while its legal basis is still under negotiation.
What: selection of 36 payment service providers for the digital euro pilot
Who: European Central Bank (ECB) together with 19 national central banks
When: selected 14 July 2026, pilot from the second half of 2027, running twelve months
Who tests: staff at the participating central banks, not the general public
Legal status: the beta carries no legal tender status; the regulation is in trilogue
Issuance: around 2029 at the earliest, conditional on the regulation being adopted
Who is in the pilot
The list covers commercial banks, cooperative institutions, payment processors and fintechs across 16 countries of application. Five German firms take part: Deutsche Bank AG, DZ BANK AG, Landesbank Hessen-Thüringen Girozentrale, PAYONE GmbH and RS2 Financial Services GmbH. Italy fields the largest group with seven participants, among them UniCredit S.p.A, Nexi Payments S.p.A., Poste Italiane S.p.A. and Banca Monte dei Paschi di Siena S.p.A.
France is represented by BPCE, the Netherlands by Adyen N.V., Ireland by Stripe Technology Europe, Limited and SumUp Limited, and Luxembourg by Satispay Europe S.A. and Worldline Financial Services (Europe) S.A. Revolut applies through its Lithuanian banking licence entity, Revolut Bank UAB, rather than a UK company.
One observation resists explanation. Nineteen national central banks take part, while the euro area has comprised 21 states since Bulgaria joined on 1 January 2026. Malta and Bulgaria are absent, and no reason for that appears in the documents.
Who tests, and who does not
End customers do not test. The ECB puts it this way: “Staff at participating central banks will have the opportunity to make beta digital euro payments from person to person (both online and offline) and from person to business (both at the physical point of sale, including Software Point of Sale, and via e-commerce, including mobile payments).”
Central bank staff therefore make the payments, at real points of sale and in e-commerce. Some of the 36 providers give that group account access, others serve selected merchants on the acquiring side, and some do both. Reading this as a field test with the public overstates the scope considerably.
The status of the instrument being tested is equally clear. The beta will be “functionally and technically close to the digital euro as foreseen in the draft legislation but will not have legal tender status”. What is under test is a functionally close precursor, and no legal tender.
The rulebook and its own caveat
A draft of the digital euro scheme rulebook exists in version 0.91, produced by the Rulebook Development Group of the Eurosystem. Its dating is inconsistent and should be reported as such: the cover page carries 2 July 2026, publication followed on 6 July alongside the sixth progress report, while the change history inside the document itself dates version 0.91 to 24 April 2026. According to Banca d'Italia, more than 4,000 comments from the market consultation of July to October 2025 were worked in.
One sentence in the document deserves attention: “the draft rulebook version 0.91 is not intended for use as a basis for implementing any systems, processes, or policies related to the digital euro or to the beta digital euro in a Digital Euro Pilot context.” The rulebook the market wants to steer by expressly rules itself out as a basis for implementation. A separate set of pilot documentation exists, and version 1.0 follows only once the regulation is adopted.
What remains open in the trilogue
The Council of the European Union set its position on 19 December 2025 under the Danish presidency. The European Parliament voted on 9 July 2026 to open negotiations, and the first trilogue took place on 13 July. The target is agreement by the end of 2026 under the Irish presidency.
Four points remain unsettled, and each touches product design in banks. First, holding limits and whether they are set through a delegated act or a Council implementing decision. Second, the compensation model, where the Council text foresees a ten-year maximum for fee caps and the argument runs between time-limited and open-ended caps. Third, acceptance obligations, for which the Parliament text carries an exemption for small and medium-sized enterprises. Fourth, data protection and permissible data processing.
Piero Cipollone, member of the ECB's executive board and chair of the high-level task force on the digital euro, reads the number of applicants as a market signal: “The strong market interest in the pilot shows the private sector's readiness to engage actively and quickly advance with the digital euro project to strengthen the European payments landscape. We look forward to deeper engagement as we work with and learn alongside European payment service providers in developing a secure, efficient and inclusive digital euro.” Piero Cipollone has repeatedly put first issuance at around 2029 at the earliest, expressly conditional on the regulation being adopted in 2026.
What this means in practice
Four starting points follow for payments and product leaders, whether or not their own institution sits in the pilot.
Now: The 36 participants cover both issuing and acquiring. Institutions outside the pilot should settle whether they intend to issue the digital euro later, to accept it, or to do both. That decision determines which systems are affected, and it can be taken before the regulation exists.
In planning: Version 0.91 shows the direction on user experience, roles and processes. The document itself rules out its use as a basis for implementation. Deriving system requirements from it now means building on a draft whose authors advise against exactly that.
In planning: Holding limits, compensation, acceptance obligations and data protection determine both economics and scope. Costing the two extreme variants for each in rough terms leaves you with a basis once agreement lands, rather than a standing start.
On the timeline: Pilot from the second half of 2027, issuance around 2029 at the earliest, and both hang on a regulation targeted for the end of 2026. Planning internally against earlier dates means planning against a chain of conditions. The reliable anchor is the conclusion of the trilogue.
Christian Schablitzki
Strategy & Management Consultant · Agentic AI expert for financial institutions
More than 20 years in investment banking and derivatives trading, followed by over 10 years advising financial institutions. Currently Partner at Infosys Consulting in Germany. Certified in Google AI, Generative AI Leader (Google Cloud) and IBM RAG and Agentic AI.
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