ECB Opens Merchant Applications for Digital Euro Pilot Covering E-Commerce and M-Commerce Payments

Key Takeaways

• The ECB has launched a call for expression of interest inviting EU-established e-commerce and m-commerce merchants with reach in at least two pilot locations to join the beta digital euro pilot, with applications due by 17:00 CET on October 27, 2026.
• Selected merchants will sign a non-negotiable agreement with the ECB and a contract with an acquiring pilot PSP, which creates legal, operational, and reputational obligations that compliance teams must assess before applying.

Deep Dive

The ECB has launched a call for expression of interest inviting EU-established e-commerce and m-commerce merchants with reach in at least two pilot locations to join the beta digital euro pilot, with applications due by 17:00 CET on October 27, 2026. Selected merchants will sign a non-negotiable agreement with the ECB and a contract with an acquiring pilot PSP, which creates legal, operational, and reputational obligations that compliance teams must assess before applying.

Applicants must be legally established in the EU and able to serve customers in at least two of 19 listed pilot locations. They must operate an active e-commerce or m-commerce platform that is flexible enough to integrate the beta digital euro, and they must be willing to contract with the ECB and an acquiring pilot PSP and to cooperate throughout the pilot. Eligible applicants are then scored against weighted criteria, and they need not meet all of them. Certain sectors will be prioritized and others may be excluded on operational, risk, and reputational grounds. Applications are rejected if they are late, substantially incomplete, or not in English. The ECB may also reject applicants that fail certain procurement-rule criteria under Decision ECB/2016/2 (Articles 30(3), 30(4), 30(5), and 30(7)).

Key dates:
- October 6, 2026: ECB focus session.
- Two weeks before the deadline: last day for written questions.
- October 27, 2026, 17:00 CET: application deadline. The questionnaire (Annex 1) must be submitted in Excel format with the signed declaration (Annex 2).
- Q4 2026 to Q1 2027: merchant selection.
- Q2 to Q3 2027: onboarding and integration.
- Q3 2027 to Q3 2028: operational phase.

The selection outcome will be announced publicly after contracts are signed.

Recommended actions:
- Have legal review the draft non-negotiable participation agreement, covering obligations, feedback requirements, and communication guidelines.
- Review existing acquirer contracts, which may need amendment.
- Assess technical readiness and the resources needed for integration, incident management, reconciliation, and operational reporting.
- Check the accuracy of application statements, since the declaration is signed.
- Plan governance for the ongoing feedback and transaction performance data to be shared.
- Coordinate external communications with the ECB's guidelines, given the public announcement of selected merchants.

Participation brings no financial remuneration beyond payments for goods and services, and no fees are charged by pilot PSPs. Merchants bear their own integration and operating costs. Settlement goes to a non-digital euro payment account, by direct credit or deferred payout, which requires reconciliation controls. The main exposures are operational (integration, incidents, reconciliation), legal (contract terms and PSD-related treatment), data (performance reporting), and reputational (the public association with a central bank initiative).

Source: European Central Bank