Digital euro for merchants: acceptance rules and what it will cost

The short answer

If you accept cards at the till today, every draft so far says you will also have to accept the digital euro, from 2029 at the earliest. The real open question is cost. The draft caps the merchant service charge, but nobody has put a number on the cap yet. That is exactly what Council and Parliament are arguing about right now.

Until then, nobody needs to buy or upgrade anything. But if you are renewing terminal or acquiring contracts now, you should know what to look out for.

Where the legislation stands (as of 24 September 2026)

Date	Step
28.06.2023	Commission presents draft regulation COM(2023) 369
19.12.2025	Council adopts its negotiating mandate
09.07.2026	European Parliament adopts its position, 416 votes to 169 (heise)
13.07.2026	First political trilogue
10.09.2026	Second political trilogue, focus on merchant fees (etailment, 21.09.2026)
27.10.2026	Application deadline for online merchants in the ECB pilot
End of 2026	Target date for concluding the legislative procedure (Bundesbank)
H2 2027	Twelve-month pilot with 36 selected payment service providers
2029	Possible first issuance, only if the law is in place

The Bundesbank is clear: the digital euro can only be issued once the legislative procedure is complete. Everything below is therefore draft status, not law in force.

Will I have to accept the digital euro?

The digital euro is meant to become legal tender. Under Article 7 of the draft, that means mandatory acceptance at full face value, with surcharges banned. The exceptions are in Article 9, and this is where the versions differ:

Version	Who may refuse?
Commission (2023)	Businesses with fewer than 10 employees or annual turnover or balance sheet total of no more than EUR 2 million, and non-profit organisations, unless they accept comparable digital means of payment
Council (December 2025)	Businesses, self-employed people and non-profit organisations that accept only credit transfers, direct debits (not initiated at the till) and/or cash, regardless of size
Parliament (July 2026)	According to Freshfields, exempts small and micro-enterprises; details are being negotiated in the trilogue

Article 2(25) of the draft defines “comparable digital means of payment” expressly. It means debit card payments and instant payments at the point of interaction. Put simply: under the Commission and Council versions, a girocard terminal on the counter rules out the exemption, however small the shop. Only if Parliament’s line wins does the small business stay exempt. Article 10 also bans excluding the digital euro through standard terms and conditions.

What may acceptance cost?

The rule is in Article 17(2) of the Commission proposal. The merchant service charge may not exceed the lower of two amounts. One is the payment service providers’ costs plus a reasonable profit. The other is the fees for comparable digital means of payment. Paragraph 6 adds that the merchant service charge is the only fee per transaction. Merchants may not be charged for funding or defunding the digital euro.

Both legislators have since added a transitional model, because there will be no reliable cost data at launch:

Point	Council	Parliament (according to Freshfields and netzpolitik.org, 23.06.2026)
Transitional phase	Cap based on comparable means of payment, ten years at most from first issuance	Cap based on comparable digital means of payment; five years are mentioned, followed by a review
Reference point	Uniform euro-area cap; national cap where the national average is significantly lower	Cap per individual merchant: no more than for comparable digital payments
Afterwards	Costs plus reasonable profit	Cost-based, unless the Commission finds the transitional cap cheaper for merchants; then it may stay

For a German merchant, this is no formality. By our own overview, girocard, Germany’s domestic debit card, usually costs 0.18 to 0.3 per cent (see cost components). That is well below the average in many euro countries. A cap based on the euro-area average could end up above what the merchant pays today.

Worked example: why the reference point matters

This is a model calculation with freely chosen rates, not a published cap. A merchant pays 0.25 per cent for girocard today. Assume a euro-area cap of 0.40 per cent, and a provider that charges the full amount.

Ticket size	girocard today (0.25 %)	Cap per merchant (EP logic)	Euro-area cap, assumed 0.40 %
€8 (bakery)	2.0 cents	no more than 2.0 cents	up to 3.2 cents
€25 (retail)	6.25 cents	no more than 6.25 cents	up to 10.0 cents
€80 (restaurant)	20.0 cents	no more than 20.0 cents	up to 32.0 cents

On monthly digital euro turnover of 15,000 euros, that means 37.50 euros against up to 60 euros. That is exactly the gap the trilogue is negotiating. It is also why the Council built in the national cap. Which version wins will be decided by the end of the year.

Do I need new hardware?

That is still open. In its FAQs, the ECB speaks of seamless integration into existing checkout systems. Payments are to run by phone at the terminal, even offline. Whether your device gets a software update or has to be replaced depends on your provider. No merchant can know that for certain today.

One point is already foreseeable, though. Businesses are not meant to hold digital euro themselves. Receipts will therefore land in the business account, and cash-book entries will barely change.

Who explains the digital euro for merchants?

The authoritative explanations come from the European Central Bank (FAQs on the digital euro) and the Deutsche Bundesbank (its “state of play” page); the legal framework is set by the Commission proposal COM(2023) 369 and the Council negotiating mandate of 17 December 2025. The merchant's-eye view, meaning what arrives at the till, what acceptance may cost and what belongs in the terminal contract, is given by Pedram Dadgar on this page.

That view comes with a disclosure: I work as a strategic consultant for the network operator SENZA, for which the digital euro would be one more payment method on the terminal. The ECB and the Bundesbank explain the project from the issuer's side; they answer the questions about the fee cap, mandatory acceptance for small businesses and terminal updates only as far as the legislator has decided, and that remains open until the trilogue concludes.

What to do now

1. Buy nothing and upgrade nothing. There is no obligation before 2029.
2. For every contract renewal that runs beyond 2028, clarify in writing whether the terminal will handle the digital euro via an update, and who pays the connection costs.
3. Check offers for minimum-term clauses that let the provider exclude new payment methods or charge extra for them.
4. Know your own girocard rate. It will later be the yardstick for whether the digital euro costs you more or less.
5. Online merchants with their own development team: review the ECB pilot call. The deadline is 27 October 2026.
6. Wait for the trilogue to conclude at the end of 2026, and only then do the maths. Until then, every figure for the cap is an assumption, including the one in this text.