ECB Opens Call for E-Commerce and Mobile Merchants to Join Digital Euro Pilot

Key Takeaways

• The Eurosystem has opened a call for expression of interest for euro area e-commerce and m-commerce merchants to take part in the 12-month digital euro pilot, with applications due by 17:00 CET on October 27, 2026.
• Participation is voluntary and unpaid, but selected merchants must sign a merchant participation agreement with the ECB and arrange a contract with an acquiring pilot PSP.
• Compliance teams at merchants, PSPs, and acquirers should assess the contractual, operational, and regulatory implications now.

Deep Dive

The Eurosystem has opened a call for expression of interest for euro area e-commerce and m-commerce merchants to take part in the 12-month digital euro pilot, with applications due by 17:00 CET on October 27, 2026. Participation is voluntary and unpaid, but selected merchants must sign a merchant participation agreement with the ECB and arrange a contract with an acquiring pilot PSP. Compliance teams at merchants, PSPs, and acquirers should assess the contractual, operational, and regulatory implications now.

Key requirements include an application assessed by the ECB against eligibility requirements and weighted criteria covering market reach, operational readiness, and suitability to support the pilot. Selected merchants will be invited to enter into a merchant participation agreement with the ECB. They must also establish or adapt their contract with an acquiring pilot PSP. National central banks may separately recruit local merchants through their own calls, so additional eligibility terms may apply. The materials do not specify the liability, data handling, or confidentiality terms, so these should be reviewed closely once the agreement is available.

Timelines are tight. An information session is scheduled for Tuesday, October 6, 2026 at 15:00 CET. Written questions may be submitted via a dedicated form up to two weeks before the deadline, which is roughly October 13, 2026. Applications must be emailed to the ECB by 17:00 CET on Tuesday, October 27, 2026. The 12-month pilot is expected to begin in the second half of 2027. The ECB has also published new FAQs. Note that the final decision on issuing a digital euro will only be taken after the relevant EU legislation is adopted, so the pilot parameters could change as the legislative process evolves.

Recommended actions: (1) Decide whether participation fits the organization's strategy, given that it is unremunerated and requires internal resources. (2) Have legal and compliance review the merchant participation agreement and any amended acquirer contract once available, focusing on liability allocation, data protection (GDPR), confidentiality, exit rights, and the treatment of pilot transactions. (3) Evaluate operational readiness, including checkout integration, reconciliation, fraud controls, and customer support. (4) Attend the October 6 session and submit questions before the cutoff. (5) For PSPs and acquirers, prepare for merchant onboarding, due diligence, and AML/KYC processes tied to pilot merchants. (6) Monitor the legislative process for changes affecting the digital euro's design.

Risk implications are moderate and mainly operational, contractual, and reputational. Because the beta digital euro lacks legal tender status and the pilot runs in a controlled environment, financial exposure should be limited. Risks remain around integration errors, data protection compliance, customer communications, and third-party dependency on the acquiring PSP. Early participants may gain influence over specifications and a readiness advantage, while non-participants should still track the pilot's outcomes to anticipate future acceptance obligations if a digital euro is issued.

Source: European Central Bank