PDPedram Dadgar“Mr. Pay” · Payments · Sales · Frankfurt
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Payments guideRegulation & law

Digital euro: what is coming for merchants, and what will acceptance cost?

Anyone who takes cards today will, under every draft so far, also have to accept the digital euro. What remains open is above all one number: the fee cap. What the Commission proposal says, where Council and Parliament diverge and what a merchant really has to do before 2029.

The short answer

Anyone who accepts cards at the till today will, under every draft available so far, also have to accept the digital euro, from 2029 at the earliest. What that costs is the question that is really open: the draft caps the merchant service charge, but the cap has not yet been put into numbers, and that is exactly what Council and Parliament are arguing about right now.

Until then nobody needs to buy or retrofit anything. But anyone renewing terminal or acquiring contracts now should know what to look out for.

Where the procedure 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 targeted conclusion of 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 puts it plainly: the digital euro can only be issued once the legislative procedure has been concluded. Everything below is therefore draft status, not applicable law.

Do I have to accept the digital euro?

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

Version Who may refuse?
Commission (2023) Enterprises 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) Enterprises, self-employed persons 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

The draft expressly defines “comparable digital means of payment” in Article 2(25): debit card payments and instant payments at the point of interaction. In plain terms: anyone with a girocard terminal on the counter does not fall under the exception under the Commission and Council versions, however small the shop. Only if Parliament’s line prevails does the small business stay exempt. In addition, Article 10 prohibits 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, either the payment service providers’ costs plus a reasonable profit, or the fees for comparable digital means of payment. Paragraph 6 adds: the merchant service charge is the only fee per transaction; the merchant may not be charged anything for funding and defunding the digital euro.

Since then, both legislators have added a transitional model, because there will be no reliable cost data at the start:

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 remain

For a German merchant this is no formality. According to our own overview, the girocard usually costs 0.18 to 0.3 per cent (see cost components), clearly less than the average in many euro countries. A cap based on the euro-area average could lie above what the merchant pays today.

Worked example: why the reference point matters

Model calculation with freely chosen rates, not a published cap: a merchant pays 0.25 per cent for girocard today. Assume a euro-area-wide cap were 0.40 per cent and the provider 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 turnover of 15,000 euros in digital euro, that would be 37.50 euros against up to 60 euros. That is exactly the difference the trilogue is negotiating, and exactly why the Council built in the national cap. Which version prevails will be decided by the end of the year.

Do I need new hardware?

That is open. The ECB writes in its FAQs of seamless integration into existing checkout systems; payments are to run by phone at the terminal, even offline. Whether your own device gets a software update for this or has to be replaced depends on the provider, and no merchant can know that reliably today. One point, however, is already foreseeable: businesses are not supposed to hold digital euro themselves. Receipts will therefore land in the business account, and cash-book entries will barely change.

What I advise merchants to do now

  1. Buy nothing, retrofit nothing. There is no obligation before 2029.
  2. For every contract renewal running beyond 2028, clarify in writing: will the terminal handle the digital euro via update, and who bears the connection costs?
  3. Check the offer for whether minimum terms allow new payment methods to be excluded or charged extra.
  4. Know your own girocard rate. It will later be the yardstick that shows whether the digital euro becomes more or less expensive for you.
  5. Online merchants with their own development team: review the ECB pilot call, deadline 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.

Sources

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