(KF1) Privacy: undercutting existing systems
Central monitoring of all online digital euro transactions by the ECB threatens privacy even more than contemporary digital payment methods with segregated account databases.
Key Findings
(KF2) Security: ignoring obvious attack vectors
The ECB’s envisioned concept of a secure offline version of the digital euro offering full anonymity is in strong conflict with the actual history of hardware security breaches and mathematical evidence against it.
(KF3) Legal and financial: vague liability and unarticulated risks
The legal and financial liabilities for the various parties involved remain unclear.
(KF4) Economical: unclear incentives and market distortions
The design lacks well-specified economic incentives for operators as well as a discussion of its economic impact on merchants.
(KF5) Utility and costs: unclear benefits for society
The ECB fails to identify tangible benefits the digital euro would create for society, in particular given that the online component of the proposed infrastructure mainly duplicates existing payment systems.
(KF6) Governance and transparency: exclusionary process and missed opportunities of an open distribution model
The design process has been exclusionary, with critical decisions being set in stone before public consultations. Alternative and open design ideas have not even been discussed by the ECB.