Intended audience
This paper is addressed to the people shaping the digital euro Regulation's user-interface provisions during the H2 2026 trilogue:
- Fernando Navarrete Rojas (EPP, Spain), the ECON rapporteur, and the shadow rapporteurs of the other political groups
- Pasquale Tridico (The Left, Italy), shadow rapporteur, whose amendments were instrumental in shaping the committee's adopted position
- Mattias Levin, acting Head of the Digital Finance unit at DG FISMA (FISMA.B.4)
- Alice Guedel, of Commissioner Albuquerque's cabinet, who holds the digital finance, payments and digital euro brief
- The Rulebook Development Group, the ECB-convened body defining the scheme's certification regime and common standards
Walt (Embedded Engineering ApS) is grateful for the progress already made in advancing the digital euro, and for the care reflected in the Regulation as it stands. This paper does not seek to redirect that work. It seeks to strengthen an already strong proposal by closing one specific gap in the user-interface provisions.
Proposal brief
Give digital euro users the right to access and use their digital euro holdings through any certified user interface of their choice, including one not provided by their own payment service provider. Distributing payment service providers must enable that access through the scheme's common standards.
By opening Article 28 to this commercial access, users benefit from healthy competition and the digital euro's end-user adoption, which bank apps alone are poorly placed to drive, becomes far more likely.
Who we are
Walt is a European, privacy-first mobile wallet built in Copenhagen. Walt focuses on EU sovereign payment solutions by allowing users to replace Google Wallet and Apple Pay with Walt's app. Users add their bank cards into Walt just like they do with Apple Pay and Google Wallet and then start using Walt to tap-to-pay for in-person payments. Walt emphasizes data privacy of user transaction or card details by not storing, sharing, or selling this data.
When the digital euro becomes a working product, Walt would like to enable users to tap-to-pay using their own digital euros. We do not seek to issue or distribute digital euros, only to enable the spend of those euros.
Current state
The digital euro Regulation is in the final stretch of becoming law. Since the European Commission's first proposal in 2023, the text has been negotiated and refined, and now stands close to a form the co-legislators can adopt. On June 23, 2026, the European Parliament's Economic and Monetary Affairs committee (ECON) adopted its own position, and a full plenary vote is expected in early July 2026.
The three institutions then enter trilogue: the negotiation between Parliament, the Council and the Commission that reconciles their three versions into a single final text. This trilogue is expected to complete its finalized text at the end of 2026. Trilogue is the last stage at which the wording of the Regulation can still change, thus any modifications to the legislation need to occur before trilogue concludes.
The digital euro itself is expected around 2029.
The sections that follow quote the text as it currently stands and show where one provision falls short of the Regulation's own stated intent.
Recital 61
The user-facing layer is described only in non-binding terms, in Recital 61 of the proposed regulation (Council general approach, 16695/25). The recital says the choice of user interface for digital euro users should be driven by the user:
Recital 61
Digital euro users should be provided with a digital euro user interface that ensures an easy, harmonised and inclusive access to the digital euro... Users should have the possibility to access and use digital euro payment services via digital euro user interfaces provided by payment service providers or by the European Central Bank and the national central banks... Payment service providers should be able to choose to rely on a digital euro user interface developed by other stakeholders, including the European Central Bank and the national central banks. Where digital euro users can choose between different digital euro user interfaces made available by the same payment service provider... the decision to select a given digital euro user interface should ultimately rest in the hands of those users and should not be imposed by payment service providers or the European Central Bank and the national central banks...
Article 28
But that promise is not carried into the binding Article 28. Only the PSP's own interface and the ECB / national central banks' fallback:
Article 28 - User interface to access and use the digital euro
1. Payment service providers providing digital euro payment services shall make available to digital euro users with whom they have a contractual relationship at least one digital euro user interface for accessing and using all mandatory digital euro payment services. This digital euro user interface shall be provided free of charge to consumers.
2. Payment service providers... shall ensure that: (a) the digital euro user interface they make available displays the official digital euro logo; (b) digital euro users can quickly and easily access and use digital euro payment services...
3. The European Central Bank and the national central banks shall make a digital euro user interface available to all payment service providers. Where a payment service provider does not offer a digital euro user interface itself... the payment service provider shall offer digital euro payment services to the digital euro users through the digital euro user interface provided by the European Central Bank and the national central banks...
4. The European Central Bank and the national central banks shall ensure that the digital euro user interface referred to in paragraph 3: (a) supports the provision of all the mandatory digital euro payment services set out in Annex II; (b) uses the logo of the payment service provider which offers digital euro payment services. The European Central Bank shall not have access to any personal data in relation to the digital euro user interface it makes available...
The problem
Recital 61 states that "the decision to select a given digital euro user interface should ultimately rest in the hands of those users and should not be imposed by payment service providers or the European Central Bank and the national central banks". However, the binding provisions of Article 28 do not carve out the open-market participation needed to enable competition in the digital euro market. Instead, the article constrains the market to only the largest pre-existing incumbents.
- The user-choice principle is recital-only. The user-choice principle described in the recital is not reinforced in the article.
- What choice does exist is PSP-mediated. Recital 61 scopes user choice to interfaces "made available by the same payment service provider." A citizen cannot choose a certified wallet their PSP did not itself select - so whether a new entrant reaches the market is decided by the incumbents it would compete against.
- "Developed by other stakeholders" risks a white-label outcome. Recital 61 only enables interfaces "developed by" other stakeholders. The regulation already makes the ECB's fallback app carry the PSP's logo, and that same branding instinct could be applied to third parties. The result would narrow the industry to white-label suppliers sitting behind the PSP's app, rather than wallets a user can choose by name.
The proposed solution
To address the need to open the wallet interface to a wider market, both Article 28 and Article 2 must be revised complementarily.
Amend Article 28
Bring weight to the user-choice principle in the recital by creating enforcement via the article. Add the following to Article 28:
A digital euro user shall be free to access and use digital euro payment services through a digital euro user interface of their choice, including a certified third-party user interface not offered by the user's own payment service provider. Distributing payment service providers shall enable such access through the common standards of the scheme rulebook. A certified third-party user interface may be provided under its own name. The payment service provider remains responsible for the distribution of digital euro payment services under Article 13 and Directive (EU) 2015/2366.
Amend Article 2
Two changes to the Article 2 definitions make that right operative. First, the existing definition of "digital euro user interface" (point 20a) is tied to the user's own provider - access to services "provided by their respective payment service providers" - which would defeat the new right; widen it to admit a certified third-party provider. Second, add definitions of the third-party interface and of its provider, so the new paragraph rests on defined terms:
20a (amended). "digital euro user interface" means a digital interface through which digital euro users can access and use digital euro payment services provided by their respective payment service providers or by a certified third-party user interface provider.
(new) "certified third-party user interface" means a digital euro user interface developed, operated and provided by a certified third-party user interface provider.
(new) "certified third-party user interface provider" means a provider of a digital euro user interface, other than a payment service provider distributing the digital euro or the European Central Bank, that meets the security, privacy and certification requirements of the digital euro scheme rulebook.
Why this serves the digital euro's own objectives
Privacy that reaches the user
Privacy is one of the digital euro's headline commitments to citizens and a precondition for them adopting it. But the Regulation's guarantee is institutional ("the ECB cannot identify users") and says nothing about what the distributing intermediary's interface sees. Whoever controls the interface sees what the user does there, and a PSP that monetises data has little incentive to minimise what its interface sees. The privacy guardrail erodes unless the user has the option to choose within an open, competitive market.
Competition and sovereignty
A core rationale for the digital euro is reducing dependence on a few non-European platforms. Confining the interface to PSPs' own apps re-concentrates the user relationship in incumbents. European independent wallets are exactly the competitive, sovereign alternative the project says it wants. The Union has just affirmed this logic by opening mobile NFC to third-party wallets under the DMA; the digital euro should embody the same principle.
Adoption depends on meeting diverse needs
The digital euro succeeds only if a broad cross-section of Europeans actually use it, and banks are not well positioned to address that range. Opening the interface lets providers build for specific users - for example, a family interface pairing a child's spending with parental controls and savings education, the kind of feature banks rarely prioritise.
Summary
Put the user's free choice of a certified wallet into the binding text of Article 28, widen it beyond the user's own PSP, and protect the wallet's own brand and certification. Doing so increases the overall likelihood of the digital euro's mass market adoption within the euro area, and strengthens competition on user experience. This should be written into legislation now before the interface model settles.
Appendix
The following texts show the full contents of the Articles that Walt proposes.
Article 28
Article 28 - User interface to access and use the digital euro
1. Payment service providers providing digital euro payment services shall make available to digital euro users with whom they have a contractual relationship at least one digital euro user interface for accessing and using all mandatory digital euro payment services. This digital euro user interface shall be provided free of charge to consumers.
1a. A digital euro user shall be free to access and use digital euro payment services through a digital euro user interface of their choice, including a certified third-party user interface not offered by the user's own payment service provider. Distributing payment service providers shall enable such access through the common standards of the scheme rulebook. A certified third-party user interface may be provided under its own name. The payment service provider remains responsible for the distribution of digital euro payment services under Article 13 and Directive (EU) 2015/2366.
2. Payment service providers providing digital euro payment services shall ensure that: (a) the digital euro user interface they make available displays the official digital euro logo; (b) digital euro users can quickly and easily access and use digital euro payment services through a digital euro user interface;
3. The European Central Bank and the national central banks shall make a digital euro user interface available to all payment service providers. Where a payment service provider does not offer a digital euro user interface itself or when such digital euro user interface is temporarily unavailable, the payment service provider shall offer digital euro payment services to the digital euro users through the digital euro user interface provided by the European Central Bank and the national central banks. The latter shall not entail the establishment of any contractual relationship between digital euro users and the European Central Bank or national central banks.
4. The European Central Bank and the national central banks shall ensure that the digital euro user interface referred to in paragraph 3: (a) supports the provision of all the mandatory digital euro payment services set out in Annex II; (b) uses the logo of the payment service provider which offers digital euro payment services. The European Central Bank shall not have access to any personal data in relation to the digital euro user interface it makes available to the payment services providers.
Article 2
20a. "digital euro user interface" means a digital interface through which digital euro users can access and use digital euro payment services provided by their respective payment service providers or by a certified third-party user interface provider.
"certified third-party user interface" means a digital euro user interface developed, operated and provided by a certified third-party user interface provider.
"certified third-party user interface provider" means a provider of a digital euro user interface, other than a payment service provider distributing the digital euro or the European Central Bank, that meets the security, privacy and certification requirements of the digital euro scheme rulebook.
References
- Council of the European Union, general approach on the Regulation on the establishment of the digital euro, 16695/25, 17 December 2025 (official legislative text; source of the Article 28 and Recital 61 wording quoted throughout) - https://data.consilium.europa.eu/doc/document/ST-16695-2025-INIT/en/pdf
- European Parliament, ECON committee adoption of its position on the digital euro, 23 June 2026 (committee stage; plenary early July, then trilogue) - https://www.euronews.com/business/2026/06/23/european-parliament-backs-long-awaited-digital-euro-to-reduce-us-dominance-in-payments
- Regulation (EU) 2022/1925 (Digital Markets Act), the precedent for opening mobile NFC access to third-party wallets - https://eur-lex.europa.eu/eli/reg/2022/1925/oj
Contact: Cole Bittel, Embedded Engineering ApS - cole@walt.is - walt.is