ETPPA has raised concerns that proposed digital euro frameworks risk excluding Open Banking providers from Europe's payments ecosystem.
The ECB launched the digital euro project in 2020, stating at the time that the initiative should neither discourage nor crowd out private solutions for digital retail payments in the euro area. Despite this stated objective, ETPPA has reported that the ECB excluded Open Banking providers from participation in its upcoming pilot project, while allowing other categories of PSD2-licensed payment service providers to take part. When the association challenged this decision, it was informed that the pilot's focus is on account-servicing payment service providers.
Legislative proposals compound the concern
According to the official press release, beyond the pilot exclusion, ETPPA has flagged proposals from both the European Council and the European Parliament indicating that PISPs should not hold a right of access to digital euro payment accounts. Specifically, Article 5(3) of the relevant legislative text proposes that PSD2 and the forthcoming PSD3/PSR framework would apply to digital euro transactions, while explicitly excluding payment initiation services from that scope.
The association has argued that digital euro accounts should be treated consistently with standard online payment accounts, enabling licensed Third Party Providers (TPPs), including PISPs, to access them via PSD2-compliant Open Banking APIs for baseline services. ETPPA has warned that any model conditioning access on commercial agreements with the ECB, on bilateral arrangements with banks, or on additional fees and contractual gatekeeping would effectively shut PISPs out of the digital euro ecosystem, reducing consumer choice and weakening competition.
ETPPA has proposed a framework in which no mandatory digital euro scheme membership would be required for basic account access and payment initiation, as defined under PSD2. Voluntary participation in the digital euro scheme would remain available for access to additional functionalities, including offline digital euro and token-based services. This structure, the association noted, would mirror the SEPA Payment Account Access (SPAA) scheme, which allows optimised services to be developed commercially without restricting baseline access rights.
The association has also signalled openness to compromise arrangements under which certain payment initiation services relating to the digital euro could be treated as ancillary services with separate remuneration, provided these do not undermine the core PSD2 principle of non-discriminatory access.
ETPPA has cautioned that restricting TPP access to digital euro accounts would diverge from the objectives of both PSD2 and PSD3, risk slowing digital euro adoption, and could unintentionally increase reliance on non-European payment solutions, including stablecoins and foreign-controlled digital payment ecosystems. The association has stressed that the success of the digital euro depends on preserving openness, competition, and innovation across Europe's payments ecosystem.
