ECB digital euro consultation ends with record level of public feedback – ECB and European Commission consensus on introduction of digital euro

While the ECB’s analysis of the public feedback from the consultation is not yet available in January 2021 the officials in Frankfurt and in Brussels already seem to know that there is a case for a digital euro.

By Hartmut Seibel, Brussels – 23/03/2021

• The ECB received over 8,000 responses received in an online survey by mid-January 2021.

• Privacy, security and pan-European reach ranked highest in European citizens’ priorities

• A detailed analysis is to be published by the ECB in spring 2021, ahead of decision on project launch

The European Central Bank (ECB) concluded a public consultation on the digital euro on 12 January 2021 and said it would now analyse in detail the large number of responses. 8,221 citizens, firms and industry associations submitted responses to an online questionnaire. This is apparently a record for ECB public consultations.

A public consultation had been launched on 12 October 2020, following the publication of the Eurosystem’s “report on a digital euro”. The ECB said it would publish a comprehensive analysis of the public consultation in the spring of 2021, which will serve as an important input for the ECB’s Governing Council’s decision whether to launch a digital euro project.

An initial analysis of raw data showed, according to the ECB, that privacy of payments ranked highest among the requested features of a potential digital euro (41% of replies), followed by security (17%) and pan-European reach (10%).

Fabio Panetta, Member of the ECB’s Executive Board and Chair of the ECB task force on a digital euro, was quoted saying: “The high number of responses to our survey shows the great interest of Europe’s citizens and firms in shaping the vision of a digital euro.” “The opinions of citizens, businesses and all stakeholders are of utmost importance for us as we assess which use cases a digital euro might best serve” he added.

A so-called ‘Eurosystem task force’, bringing together experts from the ECB and 19 national central banks of the euro area, reportedly identified possible scenarios that would “require the issuance of a digital euro”.

These scenarios refer to an increased demand for electronic payments in the euro area that would require a European risk-free digital means of payment, a significant decline in the use of cash as a means of payment in the euro area, the launch of global private means of payment that might raise regulatory concerns and pose risks for financial stability and consumer protection, and a broad take-up of central bank digital currencies issued by other central banks.

A digital euro would be an electronic form of central bank money accessible to all citizens and firms – like banknotes, but in a digital form – to make their daily payments in a fast, easy and secure way. It would complement cash, not replace it. The Eurosystem, according to the ECB, would continue to issue cash in any case.

A digital euro, according to the ECB, would combine the efficiency of a digital payment instrument with the safety of central bank money. The protection of privacy was identified as a key priority, so that the digital euro can help maintain trust in payments in the digital age.

Fundamental questions remain

The ECB initiative and the consultation raises many fundamental questions that are directly relevant to all citizens in the euro countries and beyond as well as to credit and payment institutions and banking associations in Europe.

The following initial set of questions seeks to concentrate on some of most salient points but is far from exhaustive:

• How would a digital euro (also referred to as “CBDE” – “central bank digital euro”) – once introduced – impact on the preservation of the privacy of payment transactions for the payment users?
• How would a digital euro impact on the ecological footprint of the ECB, of the relevant central banks, the users, and the payment systems currently in place? Is there any rough estimate (order of magnitude) of the ecological impact of a digital euro? Has any ecological impact study or analysis been undertaken to date? Could the introduction of a digital euro not be counterproductive to European efforts to combat or reduce the risks of climate change? The ECB surprisingly mentioned in its October 2020 “report on a digital euro” that the digital euro could represent an option for reducing the overall costs and ecological footprint of the monetary and payment systems. Any reduction of the ecological footprint of the monetary and payment systems due to any use of a digital euro would appear surprising and it would be important to understand in more detail how such initial conclusion could be reached. The ECB did not yet mention any concrete elements that would sustain their conclusion.
• Given that European citizens already increasingly benefit from efficient electronic payment solutions (including “instant payments”) for euro transactions what would be the added value of a digital euro for the European payments landscape? In other words: what are the possible scenarios that the so-called ‘Eurosystem task force’ (bringing together experts from the ECB and 19 national central banks of the euro area) reportedly identified that would truly “require the issuance of a digital euro”? In other words, what is the business case for a digital euro?
• If the ECB would also get directly involved in end-to-end payment solutions addressed to end-users how could such role be reconciled with its overall role as guardian of the monetary policy and the payment systems of the Eurozone within the European Union and the other mandates of the Eurosystem while acting at the same time as banking supervisor of the credit institutions in Europe? Would there not be too many risks of conflicts of interest?
• Would it be appropriate if the Eurosystem and its central banks become direct ‘competitors’ of credit institutions or payment institutions when providing payments services directly to consumers and to the public overall?
• If a digital euro would provide an alternative to bank deposits would it not undermine the banks’ essential intermediation function? How would the current architecture of the European banking system cope with such a profound change where the Eurosystem’s central banks would, for the first time, enter into direct dealings with consumers and end-users?
• How would issuing a ‘central bank digital euro’ (CBDE) impact mid-term or long-term on the situation of socially or technologically disadvantaged parts of our society in the European Union? How could the more fragile groups of our society (who typically rely on simple means of payment such as cash) that may be unable to use a digital euro be better assisted in the event of such technological evolution?

While the answers to the above initial questions are far from clear and the ECB have explained that they would publish a comprehensive analysis of the public consultation in the spring of 2021 it appears interesting that the ECB as well as the European Commissioner responsible for “An Economy that Works for People” have already made up their mind, in principle, about the introduction of a digital euro (“CBDE”).

[Update on the question of the digital euro to come soon]

References:

• “joint statement by the European Commission and the European Central Bank on their cooperation on a digital euro” issued by Commissioner and Executive Vice President Valdis Dombrovskis on 19 January 2021.
• “Report on a digital euro” issued by ECB & the Eurosystem from October 2020.
• For clarity: The “Eurosystem” is the monetary authority of the ‘euro area’ in the European Union. It comprises the European Central Bank and the national central banks of the EU Member States whose currency is the euro. For more detail refer to https://www.ecb.europa.eu/ecb/orga/escb/eurosystem-mission/html/index.en.html