Digital euro: programming without “programmable money”?

The digital euro will not be programmable, we are assured. For conditional payments, however, the ECB fully intends to experiment. On October 6, the institution detailed the full-scale pilot of its digital currency, which is to run for twelve months starting in the second half of 2027 [1]. Thirty-six payment service providers have already begun working with the Eurosystem.

The ECB wants to test four scenarios: online peer-to-peer payments, offline phone-to-phone payments via NFC, offline payments at a merchant, and online or mobile purchases. Its “beta digital euro” is meant to reproduce the characteristics of the future scheme as closely as possible and to be used for transactions in controlled real-world conditions. One particularity: since the European regulation has not yet been adopted, this prototype will be legally treated as “funds” under the current PSD2 regime. It will not have legal tender status [1].

This technical acceleration comes as the ECB has just launched another experimentation campaign [2], in which “conditional payments” will particularly attract the attention of readers of our investigation into the digital euro [3]. The objective: to allow a transaction to be executed automatically when certain predefined conditions are met. Other experiments will focus on AI agents, micropayments and the automation of public services.

The ECB takes care to draw a red line. Programming a payment, it explains, amounts to triggering a transaction when a condition is met. “Programmable money”, on the other hand, would restrict the use of the money itself according to its use, place, time or beneficiary. This latter possibility is excluded by the draft regulation.

Legally, the distinction is fundamental. Technically and operationally, our investigation showed that it could become more delicate: conditions placed around the transaction can result in restrictions of use without modifying the monetary units themselves. Charles Hoskinson, founder of the open-source blockchain Cardano, has just voiced a loud protest before the United Nations.

He fears that the EU will not keep its promise and will eventually put in place a digital euro that refuses, for example, the purchase of gasoline beyond a certain quota [4]. While nothing of the kind is currently planned, his intervention hits the mark: what is a technical impossibility and what depends on a legal rule that may change?

The first wave of experimentation had already tested the reservation of funds needed for certain conditional payments. The next one pushes automation further, while the 2027 pilot is meant to bring the digital euro closer to real conditions of use. The contradiction is glaring: the technology moves forward while politicians are still negotiating the rules that will have to govern it.

Sources and references

[1] European Central Bank, October 6, 2026 — “Digital euro pilot – Focus session for merchants”
https://www.ecb.europa.eu/press/intro/events/html/fs_20261006.en.html

[2] European Central Bank, September 28, 2026 — “Call for expressions of interest in a new wave of digital euro innovation platform activities”
https://www.ecb.europa.eu/press/intro/news/html/ecb.mipnews260928.en.html

[3] InCyber, “Euro numérique : quels garde-fous contre une monnaie programmable ?” (Digital euro: what safeguards against programmable money?)

[4] BeInCrypto, October 6, 2026 — “Hoskinson Warns Digital Euro Could Enable Asset Discrimination”
https://beincrypto.com/hoskinson-digital-euro-asset-discrimination/