The current implementation of the Digital Euro, as proposed by the European Central Bank, raises serious concerns regarding public spending, competition, privacy, and monetary stability.

First, the scale of the proposed budgets is unjustified.

For example, the EUR 56 million allocated to the Alias Lookup

service (PRO-009485) is far beyond what comparable systems typically

require. This is particularly troubling given that standardized and

publicly available solutions already exist. At a minimum, this

raises questions about procurement discipline and value for money.

Second, the tender requirements are structurally

exclusionary. By designing the system to function only on the two

dominant proprietary mobile platforms, the ECB reinforces an

existing duopoly and marginalizes European and Free/Libre

open-source alternatives. This approach contradicts stated EU goals

of competition, digital sovereignty, and technological independence.

Third, the online Digital Euro does not meet citizens'

stated demand for payment privacy. Survey data commissioned by the

ECB itself shows that Europeans want digital cash. Instead, the

proposal delivers a capped, account-like instrument with unclear

liability structures. The lack of confidence in its usefulness is

reflected in the proposal to mandate merchant acceptance by law.

Finally, the offline Digital Euro requirements pose a

fundamental and non-negotiable problem. The combination of

full anonymity, offline operation, transferability, and zero risk to

the recipient and the central bank is not merely an open

engineering challenge --- it is mathematically incompatible.

This is a formally established result in cryptography: without

online reconciliation or a trusted authority, digital assets can

always be copied. No consumer hardware can change this fact;

hardware can only raise the cost of attack temporarily.

As a result, the ECB’s current requirements will result in a

dilemma: either (1) spend hundreds of millions of euros

pursuing an impossible goal, or (2) give up on privacy and

discharge unavoidable double-spending risks to citizens and

law-enforcement, or (3) deploy a vulnerable system with the ECB

remaining fully liable, risking monetary stability from

large-scale fraud, potentially by sophisticated or state-level

actors.

In the current geopolitical and cyber-security environment, this

represents a systemic risk to the Euro, not a technical

detail.

Taken together, these issues risk undermining trust in the Euro and in

the institutions responsible for safeguarding it.

We therefore urge the ECB to pause the current implementation,

reassess its procurement and design assumptions, and switch over to

known alternative solutions with a publicly vetted and

technically proven design, which do not have the same drawbacks as

outlined above. Europe deserves and needs a solution that is competitive,

privacy-preserving, technologically sound, and aligned with

democratic accountability.