Opinion 26/2025 regarding the European Commission Draft Implementing Decision pursuant to Regulation (EU) 2016/679 on the adequate protection of personal data by the United Kingdom

16 October 2025

Opinion 26/2025 535.7KB

United Kingdom

The Digital Euro and its token-based offline modality

20 October 2025

Support Pool of Experts projects

An expert opinion

Over the last year, the EDPB has been working to ensure the highest standards of data protection and privacy in the context of the establishment of the digital euro. For example, the EDPB has adopted a joint opinion with the European Data Protection Supervisor (EDPS) on the Proposal for a Regulation on the establishment of the digital euro.

Decisions regarding the design of the digital euro have significant implications for the rights and freedoms of European individuals as well as for their ability to use data protection-friendly and digital payment methods in the future.

Taking into consideration the joint opinion by the EDPB and the EDPS, the EDPB requested an expert to make an in-depth assessment of the practical feasibility of the “token-based offline modality”, which the EDPB supports. The EDPB also asked the expert to investigate how this solution, suggested by the European Commission and the Eurosystem, can be implemented to ensure the very high level of protection envisaged.

As a result, this report explores the technical feasibility, inherent limitations, possible approaches, and security considerations related to the development of a cash-like, anonymous, and double-spending resistant offline modality for the digital euro.

The EDPB launched this project in the context of the Support Pool of Experts (SPE) programme following a proposal of the Berlin Data Protection Authority (DPA).

The project was completed by the external expert Prof. Dr.-Ing. Tibor Jager in September 2025.

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