The ECB wants merchants for a digital euro pilot in which nobody pays a fee and nobody holds the money

What happened

The European Central Bank published a call for expression of interest on 15 September 2026, inviting e-commerce and mobile commerce merchants established in the European Union to take part in its digital euro pilot. Applications go to a dedicated address by 17:00 CET on Tuesday 27 October 2026, an information session is set for 6 October, merchants are to be selected between the fourth quarter of 2026 and the first quarter of 2027, and the pilot itself is expected to start in the second half of 2027 and run for twelve months. Successful applicants sign a non-negotiable agreement with the ECB, published alongside the call, and a contract with one of the acquiring payment service providers already selected. What is being tested is not the digital euro. The document is careful and repeats itself on the point. Section 2 says the beta digital euro 'will not constitute a digital euro within the meaning of the proposed Regulation on the establishment of the digital euro and will not have legal tender status'. Footnote 1 says it will be 'a liability (representation of value in the books of the Eurosystem) subject to the rules for cashless payment transfers', that the online version 'will be considered as "scriptural money", falling under the current definition of "funds", under the revised Payment Services Directive', and that it 'will not be a banknote and/or a coin, and it will not constitute an account held directly with the ECB or any other Eurosystem central bank'. The pilot covers four use cases across person-to-person and person-to-business payments in proximity and remote settings; this call is for the remote business use case only. Nobody is paid and nobody pays. The call states that selected merchants 'will not receive financial remuneration for their participation beyond the payments received for the goods or services purchased by Eurosystem staff, nor will they be required to pay any fees or financial compensation to pilot PSPs for the provision of pilot payment services'. The settlement arrangement is equally plain: under the operational phase, 'merchants will receive the value of beta digital euro transactions in its designated non-digital euro payment account via a direct crediting or deferred payout'. So a merchant accepts the instrument at checkout and is credited in ordinary money, and never holds a balance in the thing being piloted. The customers are the central bank. The ECB's own news item of the same date says the pilot 'will involve staff from participating Eurosystem central banks, selected PSPs and selected merchants offering everyday services at the ECB and the euro area national central banks (e.g. cafeterias and restaurants)', and that national central banks may recruit further local merchants through separate calls. The pilot page describes participants as 36 payment service providers licensed in the euro area, selected merchants, and staff from the ECB and 19 national central banks, who will test the beta digital euro 'in everyday situations, for example paying in a cafeteria or for other services'. The 36 providers were chosen from over 50 applicants to a call launched in March 2026. The pilot locations are nineteen countries, listed identically in footnotes 4 and 9: Austria, Belgium, Croatia, Cyprus, Estonia, Finland, France, Germany, Greece, Ireland, Italy, Latvia, Lithuania, Luxembourg, Netherlands, Portugal, Slovakia, Slovenia and Spain. Malta uses the euro and is on neither list, and the document gives no reason. The selection rules are procurement rules. Eligibility requires establishment in the Union, reach across at least two pilot locations, an active e-commerce or m-commerce platform, and willingness to contract with the ECB and an acquiring provider; those who clear it are then scored against weighted criteria. The call says 'certain merchant sectors will be prioritised, and others may be excluded based on operational, risk and reputational considerations'. Applications are inadmissible if late, substantially incomplete or not in English, and the ECB may reject applicants under named articles of Decision ECB/2016/2, its own rules on procurement. The pilot page states the wider timetable: the ECB 'aims to be ready for a potential first issuance of the digital euro during 2029, assuming the digital euro Regulation is adopted in 2026', and will only decide whether to issue once the Regulation has been adopted.

Why it matters

The pilot is built so that it cannot answer the question the digital euro project is actually stuck on. The unresolved fight over the Regulation is about money: what a merchant may be charged to accept the instrument, what a payment service provider may earn for distributing it, and what holding limits protect bank deposits. This pilot pays merchants nothing, charges them nothing, lets providers earn nothing from them, and settles merchants into ordinary accounts. Twelve months of it will produce evidence about checkout integration, failed transactions, payment completion times and reconciliation, which is real and useful engineering evidence, and no evidence whatever about the economics. The ECB is testing whether the plumbing works, not whether anyone would use it at a price. The design of the closed loop is worth stating plainly, because it determines what the results can mean. The individual end users are Eurosystem staff. A meaningful share of the merchants are the canteens and restaurants that already serve the ECB and the national central banks. This call adds online merchants, which is what makes it more than an internal exercise, but the demand side remains employees of the institution that issues the instrument, paying in an environment their employer controls. Adoption findings from that population are not adoption findings, and the document does not claim otherwise: its stated objectives are operational and technical readiness and user experience, not take-up. What the beta instrument is, legally, is the most interesting thing in the document. It is a Eurosystem liability to third parties, which is central bank money in substance, and it is simultaneously not legal tender, not a banknote or coin, not an account at a central bank, and not the digital euro the draft Regulation would create. Online it is classified as scriptural money falling within the existing definition of funds under the payment services directive. So the Eurosystem is issuing direct claims on itself to the public, at small scale, under the legal clothing of ordinary electronic money, more than two years before the instrument it is standing in for could exist. That is a sensible way to avoid prejudging a legislature, and it is also a central bank taking retail liabilities onto its books without the statute that was supposed to authorise it. The settlement rule is the quiet concession to the banks. Because a merchant is credited in its existing account by direct crediting or deferred payout rather than holding beta digital euros, no deposit leaves the banking system for longer than a transaction takes, and the pilot cannot generate the disintermediation that the holding limit debate exists to prevent. Every structural feature the banking industry has objected to is either absent or neutralised here. That makes the exercise safe, and it means a successful pilot will not have tested the risk. The timetable is the concrete news for anyone planning against this. A first issuance is targeted for 2029, conditional on a Regulation being adopted in 2026, with a twelve-month pilot from the second half of 2027 in between. Read the other way, a Regulation that slips past this year moves everything, and the ECB says explicitly that it will only decide to issue once the law is in place.

What is not settled

Malta's absence is unexplained. The euro area's member states are the natural population for a Eurosystem pilot, both footnotes list nineteen countries, the pilot page counts nineteen national central banks, and Malta is on none of them. Whether its central bank declined, was not ready, or was left out for a reason the ECB has not published cannot be determined from the documents read here, and it matters because a merchant serving Maltese customers cannot count them towards the two-location requirement. Who the payment service providers are is not in this call. The pilot page links a list of the 36 selected, the call refers merchants to it, and the acquiring subset that merchants must contract with is not identified in the document read here. A merchant applying now is agreeing to establish or amend a relationship with a counterparty the call does not name, on terms set by an agreement it describes as non-negotiable. The exclusions are discretionary and undefined. The call says certain merchant sectors will be prioritised and others may be excluded on operational, risk and reputational considerations, and points to weighted criteria in an annex. Which sectors, and on whose judgement, is not stated in the body of the call, and reputational exclusion by a central bank from a payments pilot is a decision worth publishing the basis for. And the relationship between this pilot and the legislation is the largest open question. The instrument is expressly not the one in the draft Regulation, the Regulation is still in negotiation, and the ECB says it will decide on issuance only once the text is adopted. If the adopted text changes the design, the pilot will have validated an infrastructure for something slightly different, and the document does not say what happens to the twelve months of findings in that case. It also does not say what happens to the beta liabilities on the Eurosystem's books when the pilot ends.