European Central Bank President Christine Lagarde emphasized that the next steps rest with EU lawmakers, noting: “It's now for the European Council and certainly later on for the European Parliament to identify whether the Commission proposal is satisfactory, how it can be transformed into a piece of legislation or amended.”
According to the documents, the offline digital euro is designed to function more like cash by limiting the ability to link multiple transactions to the same user. In this model, transaction data would remain solely with the two parties involved and would not be transmitted to external systems.
The framework envisions certified devices, such as mobile phones or smart cards, transferring central bank–signed digital euro tokens directly during in-person payments. However, the system faces technical constraints. A proximity requirement is intended to ensure offline, face-to-face use, but so-called relay attacks, where proxy devices extend near-field communication signals over the internet, are difficult to fully prevent. This could make it challenging to completely block certain non-proximity uses by advanced users.
An expert opinion from the European Data Protection Board acknowledged these limits, stating that “the available countermeasures are very limited,” and concluding that “we will not consider physical proximity as a property of cash that can be reliably enforced in a digital currency.”
While the offline digital euro is designed with stronger privacy protections than online payments, it will not replicate the full anonymity of physical cash. The offline digital euro and the private keys used to manage it would be stored in secure elements within certified devices, including mobile devices and smart cards.
This approach aims to strike a balance between usability, regulatory oversight and privacy, offering greater confidentiality than conventional digital payments while still operating within a controlled and authorized technological framework.
Sources:
https://cointelegraph.com/news/eu-council-endorses-offline-and-online-versions-of-digital-euro
https://www.edpb.europa.eu/system/files/2025-10/digitaleurotokenbasedofflinemodality_en.pdf
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