As the legislative discussions progress, we believe it is vital that this project supports innovation, competition and consumer choice. For this purposes, it is fundamental to enable the participation of non-bank payment service providers (PSPs) in the digital euro framework.

In this paper, we address key issues for the non-bank sector, such as the importance of allowing users to hold digital euro in multiple wallets linked to any payment account, have a narrow list of basic services in the Regulation, and guarantee a sustainable business model and a fair compensation model for PSPs.