European Commission | EU Adopts 13th Package of Sanctions Against Russia After Two Years of its War of Aggression Against Ukraine

The Commission welcomes the Council’s adoption of a 13th package of sanctions against Russia. Two years since Russia brutally invaded Ukraine, EU’s support for Ukraine and its people remains as strong as ever. Europe is united and determined to continue defending its values and founding principles.
This package focuses on further limiting Russia’s access to military technologies, such as for drones, and on listing additional companies and individuals involved in Russia’s war effort. With this new package the number of individual listings has reached over 2000, dealing a huge blow to those who enable Russia’s illegal war against Ukraine.
Yet, there is no room for complacency. Full implementation of the sanctions is crucial, to deny Moscow the revenue, goods and technology it needs to feed its war. The Commission will continue supporting Member States to ensure effective enforcement of the measures, as well as working closely with third countries to tackle circumvention attempts.
The 13th package has these key elements:
This is an unprecedented package of 194 individual designations, including 106 individuals and 88 entities. With it, the EU exceeds the threshold of 2000 listings.  In particular:

Targeting Russia’s military and defence sector: the new listings include more than 140 companies and individuals from the Russian military-industrial complex, which among other things manufacture missiles, drones, anti-aircraft missile system, military vehicles, high-tech components for weapons, and other military equipment.

Sending a strong signal against Russia’s war effort partners: the new listings target 10 Russian companies and individuals involved in the shipping of Democratic People’s Republic of Korea (DPRK) armaments to Russia. They also target the Defence Minister of the DPRK, as well as several Belarusian companies and individuals providing support to the Russian armed forces.

Fighting circumvention: the new listings include a Russian logistics company and its director involved in parallel imports of prohibited goods to Russia, and a third Russian actor involved in another procurement scheme.

Strengthening EU action against Russia’s temporary occupation and illegal annexation of areas of Ukraine: the new listings include six judges and 10 officials in the occupied territories of Ukraine.

Sanctioning violations of children rights: The new listings also include 15 individuals and 2 entities involved in the forced transfer and in the deportation and the military indoctrination of Ukrainian children, including in Belarus.

This package further deepens our actions to stop Russia from acquiring Western sensitive technologies for Russian military. Unmanned aerial vehicles, or drones, have been central to Russia’s war against Ukraine. This package thus specifically lists companies procuring Russia with key drone components and introduces some sectoral sanctions to close loopholes and make drone warfare more complicated.
BaSed on hard evidence from various sources, supported by trade and customs data, the package adds 27 Russian and third country companies to the list of entities associated to Russia’s military-industrial complex (Annex IV of Regulation 833/2014). The EU will impose export restrictions towards these companies regarding dual-use goods and technology, as well as goods and technology which might contribute to the technological enhancement of Russia’s defence and security sector. The package adds:

17 Russian companies which are involved in the development, production and supply of electronic components, particularly used in connection with drone production.

Four companies registered in China and one each registered in Kazakhstan, India, Serbia, Thailand, Sri Lanka, and Türkiye, also trading in the area of electronic components, including of EU-origin.

In addition, the package expands the list of advanced technology items that may contribute to Russia’s military and technological enhancement or to the development of its defence and security sector. It adds components used for the development and production of drones, such as electric transformers, static converters and inductors found inter alia in drones, as well as aluminium capacitors, which have military applications, such as in missiles and drones and in communication systems for aircrafts and vessels.  This will further weaken Russia’s military capabilities.
The new package adds the United Kingdom to the list of partner countries for the iron and steel imports. These partner countries apply a set of restrictive measures on imports of iron and steel and a set of import control measures that are substantially equivalent to those in the EU Regulation (EU) No 833/2014.
Two years after Russia’s full-scale invasion of Ukraine, Europe is united and determined to continue defending its values and founding principles. The EU stands firmly with Ukraine and its people, and will continue to strongly support Ukraine’s economy, society, armed forces, and future reconstruction, for as long as it takes until Ukraine prevails.
To drain the Russian war machine of its revenue sources and key goods and technology, the EU has adopted 13 sanctions packages against Russia so far. Sanctions have significantly impacted Russia’s foreign revenues. EU sanctions have also ruptured Russia’s supply chains and limited its access to western technologies in important industrial sectors. Sanctions will deepen their effects over time.
As Russia tries to find ways around our sanctions, the Commission constantly evaluates the effectiveness of the measures in place, assessing how they are applied, detecting and addressing any potential loopholes. The focus now is on enforcement, in particular against circumvention of EU sanctions via third countries.
EU Sanctions Envoy David O’Sullivan continues his outreach to key third countries to combat circumvention. This is already delivering tangible results. Systems are being put in place in some countries for monitoring, controlling, and blocking re-exports. Working with like-minded partners, we have also agreed a list of Common High Priority sanctioned goods to which businesses should apply particular due diligence and which third countries must not re-export to Russia. We have recently extended by five items. In addition, within the EU, we have also drawn up a list of sanctioned goods that are economically critical and on which businesses and third countries should be especially vigilant.
Compliments of the European Commission.The post European Commission | EU Adopts 13th Package of Sanctions Against Russia After Two Years of its War of Aggression Against Ukraine first appeared on European American Chamber of Commerce New York [EACCNY] | Your Partner for Transatlantic Business Resources.


ECB | Digital euro: Debunking banks’ fears about losing deposits

Blog post by Ulrich Bindseil, Piero Cipollone and Jürgen Schaaf | On 18 October 2023 the ECB’s Governing Council outlined the scope and key features of a digital euro. The ECB also decided to proceed with the “preparation phase” of the digital euro project. The actual decision on whether to issue a digital euro will be taken at a later stage, but not before the legal framework is in place and all functional features have been specified.
Based on the specifications for a digital euro put forward by the ECB and the European Commission, we can expect the digital euro’s features to include pan-European reach, legal tender status and a high level of privacy. A digital euro would combine all the features of a modern digital payment solution. It would fill the gap left by the absence of a European electronic payment solution that is available and accepted free of charge throughout Europe, thereby strengthening the monetary sovereignty and resilience of the currency union.
To preserve the economic function of commercial banks, individual digital euro holdings would be limited. Merchants would be able to receive and process digital euro, but would not be able to hold them at all ‒ protecting the corporate deposit base of the banking system. Moreover, digital euro holdings would not accrue interest. Users would be able to seamlessly link their digital euro account to a payment account with their bank, enabling a “reverse waterfall” mechanism. This eliminates the need to pre-fund the digital euro account for online payments, as any shortfall would be covered instantly from the linked commercial bank account, provided it has sufficient funds available.
Addressing concerns about bank disintermediation
From the outset, questions concerning the risk to bank funding were at the centre of discussions about central bank digital currencies (CBDCs). In theory, CBDCs could affect financial institutions, as depositors might choose to move money from bank deposits to the central bank. This could reduce the ability of the traditional banking system to provide credit. However, central banks have analysed this issue and devised ways of tackling such risks upfront. In the case of a digital euro, the combination of the reverse waterfall, a holding limit and no remuneration would strongly reduce incentives to keep large amounts of money in a digital euro wallet. Users would rely on digital euro as a means of payment rather than use it for investment, particularly in view of the tendency of money holders to consolidate their liquidity pool. Moreover, banks could always offer higher remuneration to retain deposits.
But despite the explicit inclusion of mitigation measures in CBDC design, banking associations, bank-sponsored think tanks and scholars have continued to publish studies emphasising the risks associated with eliminating financial intermediaries from transactions ‒ known as bank disintermediation ‒ through the potential issuance of CBDCs in general and of a digital euro in particular.
Given the persistence of such criticism, it is worth taking a closer look at the arguments.
Some critics say that in an acute economy-wide banking crisis, a digital euro could accelerate bank runs, which could exacerbate the crisis.However, this is not very plausible for the following reasons:

Since a limit would be applied to digital euro holdings, the ability of customers to withdraw unlimited amounts of cash would pose much more of a threat to banks. Indeed, the disadvantage of holding cash as a short-term store of value because of safety concerns would become less important in a crisis of such magnitude.
Even in severe banking crises, many banks are still considered safe (also because central banks act as a system-wide lender of last resort). For example, during the great financial crisis in 2008 as well as in the recent crisis that hit US regional banks, safe banks continued to benefit from inflows.
In recent decades bank runs have not generally been triggered by large numbers of retail customers withdrawing small deposits, but by incidents in the wholesale market or the withdrawal of very large individual amounts above the thresholds covered by deposit guarantee schemes.

Other critics say that the attractiveness of safe central bank money could lead to banks losing deposits as a source of refinancing in the long term. This could put a strain on lending to companies and private households. According to the Association of German Banks, substantial quantities of central bank money could be withdrawn from the banking system, which would restrict the ability of commercial banks to refinance against customer deposits. However, the combination of a holding limit, no remuneration, the reverse waterfall and the absence of corporate holdings of digital euro would mean that overall levels of digital euro holdings would remain rather low.
Comprehensive analysis must include banknotes
What matters most for banks is the total amount of central bank money in circulation. Focusing on digital euro alone ignores banknotes in circulation. This is misleading, as the way they both affect the financial accounts of the economy is identical. Banks experienced elevated demand for euro banknotes during periods of financial stress and low interest rates, but didn’t raise this as an issue at the time. Between 2007 and 2021 euro banknotes in circulation increased from €628 billion to €1,572 billion, which far exceeds the amount expected to be issued in the form of digital euro.
The declining use of banknotes for daily transactions will also eventually reduce the structural demand for banknotes. The point of having a “store of value” is that it should be spent, only not immediately. In addition, the usefulness of a store of value relies on the ease with which money can ultimately be spent. Therefore, the decline in the use of banknotes also risks reducing their attractiveness as a store of value in the long term.
Indeed, in 2023 the value of euro banknotes in circulation declined for the first time in nominal terms since 2002, by around €5 billion. Even though only 20% of the demand for banknotes can be attributed to domestic payments- and this trend reversal is probably mainly a reflection of higher interest rates – the digitalisation of payments is also a factor.
Digitalisation in general is likely to lead to lower real growth in central bank money in circulation, or even to a decline. From this perspective, the persistent complaints regarding future volumes of digital euro in studies sponsored by the banking system are not looking at the right variable (which is central bank money in circulation) and are outdated (since they ignore the digital euro blueprint).
As the ECB advances its work on developing a digital euro, it will continue to refine design choices, address potential risks and optimise benefits. The ECB has presented innovative design features that would limit the circulation of digital euro while offering benefits to users. The concerns regarding bank funding have been taken seriously by proposing holding limits, access constraints, no remuneration and the reverse waterfall. The holding limits would be calibrated based on a comprehensive analysis considering all relevant factors.
In terms of the interaction between central bank money and commercial bank funding, what really matters is the total volume of central bank money in circulation. Amid the declining use of banknotes, it is likely that nominal growth in banknotes in circulation will diminish or even turn negative. This could lead to a scenario in which there is a decline of central bank money in circulation relative to GDP.
Moreover, new players might pose a greater risk to bank funding than CBDCs. Stablecoins, e-money institutions and other narrow bank constructs, some sponsored by big tech companies with huge customer bases, do not care about the role of banks in the economy. Non-banks have no obvious incentive to limit the use of their stablecoins or the services they offer, and the use of stablecoins could become significant.
Banks are barking up the wrong tree when they rely on studies that overlook the outlined design features of a digital euro. In doing so, they ignore the many other challenges they need to address to ensure stable funding through deposits. Banks need to offer attractive products and services that incentivise customers to hold their deposits with them instead of migrating to new and powerful private competitors.
> Piero Cipollone, Member of the Executive Board, ECB
> Ulrich Bindseil, Director General – Market Infrastructure & Payments, ECB
> Jürgen Schaaf, Adviser – Market Infrastructure & Payments, ECB
Compliments of the European Central Bank.
 The post ECB | Digital euro: Debunking banks’ fears about losing deposits first appeared on European American Chamber of Commerce New York [EACCNY] | Your Partner for Transatlantic Business Resources.


EIB | Investment Report 2023/2024: Transforming for Competitiveness.

Preface by Debora Revoltella, Director of the Economics Department |  The digital and green transitions, combined with a growing roll-back of globalisation, are pushing the European economy to transform to be more sustainable, resilient,  productive, and competitive. Now is the time to accelerate efforts to achieve those aims. After the severe economic shocks caused by the COVID-19 pandemic and the energy crisis, growth has slowed, and the economy risks falling into recession. However, unlike previous crisis periods, investment has remained surprisingly strong. This has been thanks to a combination of factors, including the high level of policy support with a strong focus on public investment, and the health of businesses, which enabled them to withstand the shocks comparatively well. Moreover, this period has seen some advances in the transformation of the European economy, despite the strains. Public investment remained resilient, and businesses have been investing in digitalisation, energy efficiency and reinforcing their supply chains.
Conditions for investment are rapidly deteriorating, however. Higher interest rates are coinciding with a reduction in fiscal space and a winding down of fiscal support for the overall economy. The financial buffers that have helped companies to keep investing, despite weakening growth and rising rates, are gradually being depleted. In this context, there are risks ahead for both public and private investment.
At the same time, effectively transforming the European economy will require huge levels of investment. Europe faces the challenges of digitalisation, ageing, the emerging  trend of deglobalisation and cutting its reliance on fossil fuels. Competitiveness is the leitmotif that brings these elements together. Staying competitive will depend on the  ability of firms to progressively increase productivity and successfully sell their goods and services in the global marketplace, ultimately improving living standards in a sustainable way. Competitiveness also depends on firms’ ability to drive change and adapt to it through innovation, which must be supported by the availability of skilled  employees, infrastructure, adequate finance and a conducive regulatory environment. In Europe, a well-oiled single market is also vital for enabling innovation. Fully removing internal barriers, increasing competition and taking advantage of economies of scale could smooth the reallocation of resources required for transformation and further improve efficiency, productivity and, ultimately, competitiveness.
To meet its climate goals and remain competitive, Europe needs to invest heavily in research and development (R&D), skills, infrastructure and the adoption of green, digital and more productive technologies. And despite the resilience of investment in recent years, funding to support these aims remains insufficient. In terms of productive  investment (a measure that excludes housing), Europe lost pace after the global financial crisis, falling behind the United States. The gap between the European Union and the United States is still some 1.5 percentage points of gross domestic product (GDP), largely driven by lower investment in machinery, equipment and innovation. Europe’s position in other important areas, such as R&D spending and the issuance of patents, is threatened, especially by China. And Europe faces the added challenge of ending its dependence on imported fossil fuels, with electricity prices projected to remain elevated for more than a decade before renewable energies start to push them down.
The investment to address these needs must be made by the private sector, for the most part. But that will not happen at sufficient speed and scale unless the public sector acts to create enabling conditions and to support investment in a catalytic way. As global competition accelerates, Europe must focus on the essentials: enhancing innovation and ensuring that innovative and highly productive firms have the resources and conditions they need to grow. These firms require a competitive environment that is open to change and disruptive innovation, as well as access to the sizeable and level playing field offered by the EU single market, which will allow them to reap economies of scale. They also need more suitable financial resources, such as equity or quasi-equity instruments, to be able to scale up their operations.
In the context of growing geopolitical risks and deglobalisation, there is also a need for more investment in the diversification and resilience of supply chains. The EU economy benefits from its openness to trade, while the EU single market offers strategic opportunities to diversify supplies among EU members.
However, Europe needs targeted strategies to further enhance its resilience against supply disruptions, particularly for raw materials that are critical to the green transition. Europe’s aim to reduce emissions by 55% by 2030 represents a still greater challenge for the economy, but it also brings many opportunities. From innovating green  technologies to deploying them, Europe’s climate ambitions are reflected in increasingly clear incentives and the emergence of market-leading players.
Improving the availability of skills – by investing in education and training and by facilitating workers’ ability to move – is also critical for the economy to transform and improve its competitiveness. The single market is a huge asset, but Europe has not yet fully realised its potential to facilitate the efficient allocation of capital and other resources and to help European firms grow into global champions.
This edition of the European Investment Bank’s annual Investment Report focuses on the European economy’s effort to transform and become more competitive, and to remain at the global technological frontier. The analysis it presents is supported the annual EIB Investment Survey of 12 000 European firms, the latest edition of which also included a special module on manufacturing firms covered by the EU Emissions Trading System. This report is divided into two parts. The first provides an assessment of the
macroeconomic and financial environment in the European Union. It discusses trends and developments in investment, focusing on government and corporate investment. The second part looks at the structural challenges of promoting innovation and digitalisation, and addressing climate change.
You can read the full report here.
Compliments of the European Investment Bank – a Platinum member of the EACCNY.The post EIB | Investment Report 2023/2024: Transforming for Competitiveness. first appeared on European American Chamber of Commerce New York [EACCNY] | Your Partner for Transatlantic Business Resources.

EACC & Member News

Archipel Tax Advice: Employee Stock Ownership Plan [ESOP]: Explainer & Template

In this post, we walk through the basics and some intricacies of an Employee Stock Ownership Plan [ESOP]. We say ‘an’ ESOP because every plan will be unique; no two companies are the same and neither are any two talent pools, and as a properly working ESOP should interlink Company metrics and goals with Staff preferences and culture, such plans are most always taylor-made and highly specific.


EACC & Member News

Houthoff: Digital Services Act to apply from 17 February 2024

On 17 February 2024 the Digital Services Act (or: DSA) will become fully applicable in the European Union. The DSA sets out rules for the provision of various online intermediary services.

It aims to ensure a safe online environment, protect users’ fundamental rights and create a level playing field for businesses. This update is part of a series of News Updates and provides an overview of the latest developments regarding the DSA.


EACC & Member News

Loyens & Loeff: Getting Ready for the Digital Services Act: The Netherlands ACM publishes for consultation its draft DSA Guidelines

The European Union (EU) has introduced a landmark regulation known as the Digital Services Act (DSA). The DSA is aimed at creating a safer and more transparent online environment and will apply to all regulated entities as per February 17, 2024. The Netherlands Authority for Consumers and Markets (Autoriteit Consument & Markt) (ACM) will play a pivotal role in the enforcement of the DSA within the Netherlands as the regulator-designate.



European Parliament | Greenwashing: How EU Firms Can Validate Their Green Claims

The Internal Market and Environment committees adopted on Wednesday their position on the rules on how firms can validate their environmental marketing claims.

The so-called green claims directive complements the already-approved EU ban on greenwashing. It defines what kind of information companies have to provide to justify their environmental marketing claims in the future. It also creates a framework and deadlines for checking evidence and approving claims, and specifies what happens to companies who break the law.
Verification system and penalties
MEPs agreed with the Commission that companies should submit any future environmental marketing claims for approval before using them. The claims would be assessed by accredited verifiers within 30 days, according to adopted text. Companies who break the rules may be excluded from procurements, lose their revenues and face a fine of at least at 4% of their annual turnover.
The Commission should draw up a list of less complex claims and products that could benefit from faster or simpler verification, MEPs say. It should also decide whether green claims about products containing hazardous substances should remain possible. MEPs also agreed that micro enterprises should be excluded from the new obligations and SMEs should get one extra year before applying the rules.
Carbon offsetting and comparative claims
MEPs confirmed the recent EU ban on green claims based solely on the so-called carbon offsetting schemes. They now specify that companies could still mention offsetting schemes if they have already reduced their emissions as much as possible and use these schemes for residual emissions only. The carbon credits of the schemes must be certified, as established under the Carbon Removals Certification Framework.
Special rules would also apply to comparative claims (i.e. ads comparing two different goods), including if the two products are made by the same producer. Among other provisions, companies should demonstrate they have used the same methods to compare relevant aspects of the products. Also, claims that products have been improved cannot be based on data that are more than five years old.
Parliament’s rapporteur Andrus Ansip (Renew, EE) for the Internal Market Committee said: “Studies show that 50% of companies’ environmental claims are misleading. Consumers and entrepreneurs deserve transparency, legal clarity and equal conditions of competition. Traders are willing to pay for it, but not more than they gain from it. I am pleased that the solution proposed by the committees is balanced, brings more clarity to consumers and at the same time is, in many cases, less burdensome for businesses than the solution originally proposed by the Commission.”
Parliament’s rapporteur Cyrus Engerer (S&D, MT) for the Environment Committee said: “It is time to put an end to greenwashing. Our agreement on this text ends the proliferation of deceitful green claims which have tricked consumers for far too long. It also ensures that businesses have the right tools to embrace genuine sustainability practices. European consumers want to make environmental and sustainable choices and all those offering products or services must guarantee that their green claims are scientifically verified.”
Next steps
The draft report was adopted with 85 votes to 2 and 14 abstentions. It will now be put to a vote at an upcoming plenary session and will constitute Parliament’s position at first reading (most likely in March). The file will be followed up by the new Parliament after the European elections on 6-9 June.

Compliments of the European Parliament.The post European Parliament | Greenwashing: How EU Firms Can Validate Their Green Claims first appeared on European American Chamber of Commerce New York [EACCNY] | Your Partner for Transatlantic Business Resources.


Speech ECB | Preserving people’s freedom to use a public means of payment: insights into the digital euro preparation phase

By Piero Cipollone, Member of the Executive Board of the ECB, at the Committee on Economic and Monetary Affairs of the European Parliament | Brussels, 14 February 2024

Thank you for the opportunity to speak before the Committee today. As I emphasised during my confirmation hearing, I am committed to actively pursuing the dialogue with the European Parliament on a digital euro.
This year marks the 25th anniversary of the euro and our monetary union. It is up to us to ensure both remain fit for the digital age. The Single Currency Package[1] will help us achieve just that: first, by ensuring cash remains widely accessible and accepted; and second, by complementing cash with a digital option for paying with central bank money.
A digital euro would be a European means of payment which could be used free of charge, for any digital payment, anywhere in the euro area. Together with cash, a digital euro would preserve European citizens’ freedom to use a public means of payment.
Yet, we are at risk of taking this freedom for granted. In my previous role, I received countless letters from mayors of communities – in mountainous regions for instance – who expressed concerns about increasingly long distances to the nearest ATM.
Cash and a digital euro have the same objective: ensuring that everyone, regardless of their income, can pay in any situation of daily life. This is a fundamental right. And it should be protected in the same way in all parts of the euro area.
This is a timely moment to discuss a digital euro. As co-legislators, you are currently debating the European Commission’s legislative proposal, while the Eurosystem initiated the digital euro preparation phase last November.[2]
Your legislative deliberations frame our technical work, and they will continue to do so. The Eurosystem stands ready to provide technical input to European co-legislators as needed. Let me assure you that the ECB’s Governing Council will not take any decision about the issuance of a digital euro until the legislative act has been adopted. This constitutes the framework within which the digital euro will be established as legal tender. We will of course remain fully accountable at all times and will keep you continuously and closely informed about the Eurosystem’s progress towards a digital euro, not just at this stage but also after the legislative deliberations have concluded.
Let me now update you on four key issues that are central to our preparation phase: i) search for possible providers to develop a digital euro platform and infrastructure; ii) preparing the digital euro rulebook; iii) ensuring the stability of the financial system; and iv) last but not least, offering a higher level of privacy when making digital payments.
Searching for possible providers to develop a digital euro platform and infrastructure
At the beginning of this year, we started the selection process to find possible providers who could potentially develop a digital euro platform and infrastructure.[3]
Let me be clear: we are not launching any of the development work now. Instead, we want to establish framework agreements that could be used in the coming years to develop the relevant components if the decision to launch the digital euro is taken.[4] We need to be prepared for such an event. Our readiness would be compromised if we started searching for possible suppliers only after that decision is made. However, we are not tying our hands in any way by sourcing potential suppliers now. The agreements will be sufficiently flexible to accommodate the legislative deliberations or technological advances. And if we were to take the decision not to launch a digital euro, we would not sign any contracts.
Closer engagement with external providers will provide us with insights into the technological options available and the choices to be made. This is particularly crucial for components that are not yet on the market, such as the offline digital euro functionality.
To strengthen our autonomy, resilience and security, a digital euro would rely on a European infrastructure. Accordingly, only legal entities with registered offices in the EU and controlled by such entities or EU nationals[5] will be eligible to participate in the procurement process.[6]
At this stage, we have issued calls for applications to establish framework agreements with potential providers of digital euro components and related services.
We will publish the outcome of the subsequent public tender process on our website.
Preparing the digital euro rulebook
There is currently no single European digital means of payment that is universally accepted across the entire euro area. This forces Europeans – consumers, merchants and banks – to rely on ever more expensive international card solutions for daily payment activities. Fees applied by international card schemes almost doubled between 2016 and 2021 in the EU.[7] And even these international card solutions cannot be used everywhere.
A digital euro would remedy this situation, breaking Europe’s long-held dependency and fostering competition. To this end, everyone in the euro area should be able to make or receive payments in digital euro, irrespective of their intermediary or country of origin – as is currently the case for cash.
This is why we need a digital euro rulebook. We are working on a draft rulebook together with representatives of consumers, retailers and intermediaries.[8] We have recently published a report on our progress in this area.[9]
The rulebook will define a single set of rules, standards and procedures for the digital euro that will ensure its harmonious implementation. This will guarantee, for example, that someone from Finland will be able to pay with digital euro as easily and in the same way in Lisbon as they can back home in Helsinki.
A digital euro would thus provide an alternative infrastructure for all day-to-day payments, which could be used by payment service providers and schemes, such as the European Payments Initiative, Bizum or Bancomat, to roll out instant payment-based solutions across the euro area. This would reduce our dependence on non-European players while fostering competition among European players.
By analogy: the digital euro infrastructure could be seen as a common European railway, on which different companies can operate their own trains and compete for customers without needing to deploy their own private tracks, as is the case with today’s payment system. In addition, private payment service providers could launch new and innovative products or extend their scope beyond existing use cases and domestic markets. This would be a marked improvement on the current situation.
Ensuring the stability of the financial system
There is a growing public preference for digital payments.[10] But central bank money is, for now, only available in physical form – cash. So, if we do not offer a digital euro, we run the risk that central bank money could be crowded out of payments.
Our objective is to preserve the role and share of central bank money in payments, not to displace private money. As clearly stated in the European Commission’s legislative proposal, preserving the role of central bank money should not come at the expense of other objectives, such as protecting monetary policy transmission or financial stability. And we are in any case bound by these objectives, which are at the heart of the ECB’s mandate.
That is why we have included safeguards in the design of a digital euro.
First, as is the case for euro banknotes, digital euro holdings would not be remunerated and hence would not compete with savings deposits.[11] And banks could always offer higher remuneration to retain deposits. This would benefit savers and could in fact increase the deposit base, supporting bank lending.[12]
Second, there will be limits on the amount of digital euro that can be held by individuals. And while businesses and public sector organisations could receive and process payments in digital euro, they could not hold any.[13]
Third, users could pay with digital euro online without prefunding their wallets, by seamlessly linking their digital euro account to a payment account with their bank. This would offer them the convenience of being able to make and receive online payments, even above their digital euro funds and the holding limit.[14] However, if people want to use the offline functionality, they would need to prefund their offline wallet. Just like today with people having to withdraw banknotes in order to use cash.
These features show that a digital euro is being designed as a means of payment and not as a form of investment. And it will preserve the role of intermediaries, contrary to alternative solutions offered by technology firms, which will have no such safeguards.[15]
We have just started to develop the analytical framework and models that would be used to determine the holding limit. This limit will be set to preserve financial stability, having considered the impact on different bank business models and on monetary policy transmission and implementation.
This is a Eurosystem-wide endeavour, and we will engage with banks and other market participants to properly set out the necessary assumptions and define the analytical methodology. We will share our findings with you and the general public. Let me assure you that financial stability considerations are central to our thinking as they underpin our ability to pursue our price stability mandate.
Offering a higher level of privacy in digital payments
Let me now turn to one of the most important design features of a digital euro, namely privacy. We welcome the high standard of privacy and data protection provided for under the proposed regulation. Ultimately, this is for the European co-legislators to decide.
On our side, we are determined to not only protect but enhance privacy in payments.
First, we already provide cash, the payment instrument that offers the highest level of privacy. We are determined to continue to do so, as demonstrated by our ongoing efforts to produce the third series of euro banknotes.[16] We will continue to do everything in our power to ensure people can continue to have the option to pay with it. They value this option, and we are committed to maintaining it for them.[17]
Second, a digital euro will be usable offline. Paying offline in digital euro would be similar to using cash. Just like cash payments, it would require physical proximity and offer cash-like privacy: personal transaction details would only be known to the payer and the payee.
Third, a digital euro would allow people to make online payments with very high standards of privacy, higher in fact than what commercial solutions currently offer. The Eurosystem would not be able to identify people based on the payments they make.[18] We would only see a minimal set of pseudonymised data necessary to fulfil Eurosystem tasks, such as settlement.[19] And digital euro users would retain control over how their data is used by payment service providers,[20] who would have access to customer data to prevent illicit activities, such as money laundering or terrorist financing,[21] and also to fulfil their contractual obligations towards customers, while having to respect all applicable privacy protection regulations, such as the General Data Protection Regulation. In its Opinion on the digital euro, the ECB also suggests considering the possibility of offering increased privacy for certain low-risk, low-amount payments in digital euro in online mode.[22]
Fourth, we would implement state-of-the-art security and privacy-preserving measures to ensure privacy protection. And we will deploy strong governance safeguards. Independent data protection authorities will oversee compliance with EU data protection rules and regulations, which are the strongest privacy and security laws in the world. And provisions in the proposed regulation envisage data protection authorities being consulted at an early stage.[23]
Let me conclude.
The digital euro is a common European project.
First and foremost, it is about preserving everyone’s freedom to use a public means of payment anywhere in the euro area, even as payments go digital. And it is crucial to strengthen our collective resilience and autonomy in a more fragile global environment.
That is why it is so important to set an ambitious pace. But money is trust. The digital euro will need broad support. We are therefore committed to supporting your work as co-legislator. And we are engaging with all stakeholders.
In this spirit, I will continue to be available in order to engage with you throughout the preparation phase and beyond. Together, we can build the euro’s digital future.
Thank you.
Compliments of the European Central Bank


In June 2023 the European Commission put forward two proposals to ensure that citizens and businesses can continue to access and pay with euro banknotes and coins across the euro area, and to set out a framework for a possible new digital form of the euro that the European Central Bank may issue in the future, as a complement to cash. See Proposal for a Regulation of the European Parliament and of the Council on the legal tender of euro banknotes and coins, European Commission, COM(2023) 364 final, 28 June 2023; and Proposal for a Regulation of the European Parliament and of the Council on the establishment of the digital euro, European Commission, COM(2023) 369 final, 28 June 2023.
For more information, see the letter from Piero Cipollone to Irene Tinagli, Chair of the Committee on Economic and Monetary Affairs of the European Parliament, on the “Update on work of digital euro Rulebook Development Group and start of selection procedure for potential digital euro providers” of 3 January 2024.
For more information, see ECB (2024), “Calls for applications for digital euro component providers”, MIP News, 3 January; and the letter from Piero Cipollone to Irene Tinagli, op. cit.
The resulting framework agreements could be used to develop the following digital euro components: i) alias lookup; ii) secure exchange of payment information; iii) fraud and risk management; iv) offline component; and v) a digital euro app and related software development kit. These framework agreements would include only part of the scope of the digital euro service to be offered, as other elements, such as the settlement component, would be sourced in parallel within the Eurosystem.
An ‘EU National’ means any legal entity with registered offices in an EU member state or any natural person that has the nationality of an EU member state.
The eligibility criteria that apply to applicants also apply to sub-contractors.
From 0.08% to 0.15% per transaction, see the Scheme Fee Study by CMSPI and Zephyre in 2020.
The Eurosystem established a Rulebook Development Group for the digital euro scheme to obtain input from the financial industry, consumers and merchants. The Group consists of 22 public and private sector experts with experience in finance and payments. See ECB (2023) “Members of the Rulebook Development Group”, 15 February. Over the past ten months, this group has been preparing a draft digital euro rulebook and will continue its work this year.
See ECB (2024), “Update on the work of the digital euro scheme’s Rulebook Development Group”, 3 January; and the letter from Piero Cipollone to Irene Tinagli, op. cit.
ECB (2022), Study on the payment attitudes of consumers in the euro area (SPACE), December.
See ECB (2023), “A stocktake on the digital euro”, 18 October, which presents the findings of the investigation phase of the digital euro project and is the basis for the work during the preparation phase. See also “Opinion of the European Central Bank of 31 October 2023 on the digital euro (CON/2023/34)”.
See David Andolfatto, Assessing the Impact of Central Bank Digital Currency on Private Banks, The Economic Journal, Volume 131, Issue 634, February 2021, Pages 525–540. The paper finds that the introduction of a central bank digital currency has no detrimental effect on bank lending activity and may, in some circumstances, even serve to promote it. Competitive pressure leads to a higher deposit rate which reduces profit but expands deposit funding through greater financial inclusion and desired saving.

The payments received by businesses and public sector organisations would be transferred immediately to their commercial bank account. Any payments they make would be funded instantly from their commercial bank account.
The waterfall functionality would allow users to make or receive payments in digital euro above the holding limit by linking a digital euro account to a commercial bank account. When receiving a payment, this would allow automated conversion of retail central bank digital currency in excess of a holding threshold into a bank deposit held in a linked commercial bank account chosen by the end user. Similarly, a reverse waterfall would ensure that end users can make a payment even if the amount exceeds their current digital euro funds. Additional liquidity would be pulled from the linked commercial bank account and the transaction would be completed in digital euro at its full value.
The counterfactual to a digital euro is not a benign status quo. In the absence of a digital euro, the emergence of potentially dominant private operators in the digital payments market could have a strong impact on the financial sector. This is a real possibility, as demonstrated by PayPal’s recent decision to launch its own US dollar-denominated stablecoin for use in digital payments. Private providers of payment services, including PayPal, have no incentive to limit the take-up of their stablecoins or the range of services they offer. Quite the opposite: their objective is to expand their customer base and gain market share. See Panetta, F. (2023), “Shaping Europe’s digital future: the path towards a digital euro”, introductory statement at the Committee on Economic and Monetary Affairs of the European Parliament, Brussels, 4 September.
See ECB (2023), “ECB selects “European culture” and “Rivers and birds” as possible themes for future euro banknotes”, press release, 30 November.
While use of and preferences for cash payments are on a declining trend, the importance of cash remains high. Overall, 60% of the euro area population considered having the option to pay with cash to be very or fairly important. See ECB (2022), “Study on the payment attitudes of consumers in the euro area (SPACE)”, December. The Eurosystem cash strategy aims to ensure that cash remains widely available and accepted as both a means of payment and a store of value.
Together with technology experts, the ECB is considering all state-of-the-art security and privacy measures that could be suitable for a mass retail payment product such as a digital euro. Pseudonymisation, clear segregation of data, hashing and other cryptographic techniques would ensure that the Eurosystem would not be able to identify individuals making or receiving payments in digital euro. End users’ payment data would be pseudonymised so that they could not be directly identified and the Eurosystem could not link any of the data it processes to an identified end user. See also ECB (2023), op. cit. (footnote 7).
The design of the online digital euro would provide more privacy than current digital payment solutions in terms of the data visible to the central infrastructure provider for payment processing. In its role as digital euro infrastructure provider, the Eurosystem would not be able to identify the individuals behind digital euro transactions. Only PSPs would know the correspondence between end user actual identity and payments data processed by the central infrastructure provider. This is unprecedented in the area of electronic retail payments and would offer greater personal data protection compared with current payment solutions, which concentrate a large amount of payments data in the hands of infrastructure and scheme services providers, allowing them to connect it to end users.
This would include an opt-in rather than an opt-out for allowing payment service providers to process a user’s personal data for commercial purposes or to provide additional services. The digital euro scheme would ensure that users would be able to make an informed decision and would not be forced to allow use of their personal data (beyond what is necessary for compliance with legal requirements) in order to make full use of basic digital euro services. See ECB (2023), “A stocktake on the digital euro”, 18 October, section 6.2.
See Panetta, F. (2022), “A digital euro that serves the needs of the public: striking the right balance”, introductory statement at the Committee on Economic and Monetary Affairs of the European Parliament, Brussels, 30 March; and ECB (2022), “Digital euro – Privacy options”, presentation to the Eurogroup, 4 April.
See “Opinion of the European Central Bank of 31 October 2023 on the digital euro (CON/2023/34)”.
See Article 5(2) on Applicable law and Article 32(2) on General fraud detection and prevention mechanism, Proposal for a Regulation of the European Parliament and of the Council on the establishment of the digital euro, European Commission, COM(2023) 369 final, 28 June 2023.

The post Speech ECB | Preserving people’s freedom to use a public means of payment: insights into the digital euro preparation phase first appeared on European American Chamber of Commerce New York [EACCNY] | Your Partner for Transatlantic Business Resources.


ECB | Eurosystem Accepts a Fifth Rating Agency

Blog post by Diana Gomes and Anamaria Piloiu | The Eurosystem has accepted Scope as a new rating agency alongside Fitch, Moody’s, S&P and DBRS. This has a number of implications, including a wider range of credit opinions and expertise being considered for monetary policy purposes.
Credit rating agencies are private companies which assess the creditworthiness of issuers of financial instruments – be they governments, commercial banks or corporates. Many investors in the financial markets rely on rating agencies because it would be too costly for them to evaluate the credit risk of each issuer or debt instrument themselves. Central banks also use these ratings in their regular activities. That is why the recent acceptance of a fifth rating agency ­– Scope Ratings – has important implication for the Eurosystem and financial markets.
The ECB and the national central banks of the euro area use the rating information provided by these agencies during the implementation of monetary policy operations, either via the provision of loans to banks or via the direct purchase of assets in the financial market. For instance, the Eurosystem grants loans only against adequate collateral, which must be credit-rated. The credit risk information provided by ratings is important to mitigate financial risks to the ECB and the national central banks of the Eurosystem. The Eurosystem adheres to prudent and transparent standards and therefore only accepts high-quality assets in its monetary policy operations. Concretely, this means that the assets which the Eurosystem accepts as collateral or for purchases must meet minimum credit quality requirements and comply with specific eligibility conditions. To be eligible as collateral, assets need to have at least a BBB- (or the equivalent in another rating schema) from at least one accepted rating agency. In lending operations, the rating also affects how much money a commercial bank can borrow using an asset as collateral. The lower the rating, the higher the so-called haircut applied by the Eurosystem. Until recently only four rating agencies – Fitch Ratings, Moody’s, S&P Global Ratings and DBRS Morningstar – were accepted by the ECB. Chart 1 shows the share of financial assets rated by these four agencies.

Chart 1
Historical evolution of the use of credit rating agencies for monetary policy purposes

EUR billions (main axis) and percentages (secondary axis)

Sources: Eurosystem collateral database and authors calculations

The acceptance of Scope Ratings is a milestone for the Eurosystem. It offers a more diversified set of credit opinions, and therefore improves the ability to adapt and respond to evolving market dynamics. The addition of a new rating agency also broadens the pool of eligible collateral assets when the newcomer provides credit assessments of assets and issuers that are not rated by the other accepted agencies. Banks can then further diversify their collateral pools for central bank lending, which ultimately makes the implementation of monetary policy smoother.
The recognition of the fifth rating agency is also a milestone for the rating provider market. New players mean more competition, which is good for issuers as they can choose from a greater variety of agencies. Investors, too, benefit from a wider range of expertise, but also from greater transparency resulting from the Eurosystem’s efforts and requirements related to improving disclosures around ratings, processes and methodologies.
The Eurosystem conducts its own due diligence
Precisely because these ratings are so important, the Eurosystem conducts its own due diligence and does not mechanistically rely on them. To do so, the Eurosystem closely studies rating methodologies, rating reports and other relevant publications to fully understand how the rating decisions are made. This gives the Eurosystem a nuanced understanding of the information contained in credit ratings, for example by allowing it to disentangle qualitative judgment in rating decisions. This means that, in certain circumstances, the Eurosystem may deviate from the rating agencies’ opinions and apply discretionary measures such as country waivers. The most recent example was the acceptance of Greek sovereign debt instruments as collateral and for bond purchases in certain asset purchase programmes during the period when the associated sovereign rating was below the minimum acceptable rating threshold.
To be able to conduct its own due diligence, the Eurosystem accepts only credit rating agencies that are registered with the European Securities and Markets Authority (ESMA) and comply with the relevant acceptance criteria. The criteria cover crucial aspects such as rating disclosure, transparency and rating quality. For instance, credit rating agencies have to demonstrate a broad rating coverage across Europe and across asset classes. More specifically, a rating agency must demonstrate historical (at least three years) and current rating coverage for several asset classes, of at least: (i) 10% of eligible euro area assets; (ii) 20% of the nominal amount of eligible euro area assets; (iii) in two-thirds of the euro area countries. This rating coverage requirement is needed to ensure the Eurosystem’s risk protection and the efficient execution of its monetary policy framework. At the same time, this may help stimulate competition at the European level and support the integration of fragmented EU capital markets into a larger-scale EU capital market union, as more companies can benefit from a rating which allows them to potentially access the financial markets for funding.
The Eurosystem has consistently been open to additional credit rating agencies and engaged with external stakeholders such as smaller rating agencies, members of the European Parliament or ESMA. Of course, a number of ESMA-registered agencies – currently 29 – have specific focuses on certain assets or jurisdictions, which makes it difficult for them to comply with the Eurosystem rating coverage requirements and acceptance criteria. Importantly, the acceptance of a credit rating agency by the Eurosystem does not imply an endorsement of its ratings. It should also not be regarded as an assessment by the Eurosystem of the intrinsic quality of the rating agency. Instead, the acceptance is merely an acknowledgment that the rating agency complies with the Eurosystem’s needs for conducting its own scrutiny effectively.
Accepting Scope Ratings marks a milestone which fosters competition, transparency and the diversification of credit opinions in the credit rating agency industry, which benefits not only the Eurosystem, but also issuers and investors.
The views expressed in each article are those of the authors and do not necessarily represent the views of the European Central Bank and the Eurosystem.
For more information, please contact the authors:
> Diana Gomes, Senior Financial Risk Expert, ECB
> Anamaria Piloiu, Senior Financial Risk Expert, ECB
Compliments of the European Central Bank.The post ECB | Eurosystem Accepts a Fifth Rating Agency first appeared on European American Chamber of Commerce New York [EACCNY] | Your Partner for Transatlantic Business Resources.