Q19: How is the digital euro scheme rulebook being developed?
The European Central Bank answers:We answer them:The Eurosystem is developing the draft rulebook in close collaboration with representatives of the European retail payments market through the Rulebook Development Group (RDG).
The RDG, which consists of senior representatives from European associations representing both the supply and demand sides of the European retail payments market, is working on the basis of the digital euro design choices that have already been approved by the ECB’s Governing Council.
Dedicated workstreams have been created within the Rulebook Development Group to focus on sections of the rulebook that require particular expertise.
In June 2025 a revised interim draft of the digital euro scheme rulebook was delivered to the RDG for a market consultation. The draft rulebook remains sufficiently flexible to accommodate any future adjustment deriving from the final text of the Regulation on the establishment of the digital euro, once adopted.
Instead of engaging in public discussion with the information security community, the rulebooks are developed behind closed doors (KF6). The digital euro design choices cannot be questioned by the experts working on the rulebooks, regardless on the privacy, security or usability issues they may create.
The digital euro rulebook should better be seen as an attempt to use red tape to paper over the inherent design problems of the digital euro by prescribing complex processes and imposing costly business process requirements on participants (KF4). Instead of developing innovative technical standards, it will likely primarily refer to established norms and procedures.