The European Commission is doing a targeted consultation regarding digital euro.

If you're in the EU, you should be answering this. They do listen.

https://ec.europa.eu/info/consultations/finance-2022-digital-euro_en

Some of my comments are below:

> "programmable payment features" are likely to become a "ball and chain" around the digital euro as policy-makers will propose poorly considered policies to use the money as a form of social credit, regulating and controlling those who use it, and seriously damaging the credibility of the digital euro.

> Proposals involving "holding caps or interest and fees on large holdings" will undermine the digital euro project as people will prefer stablecoins.

> Blockchain / DLT are the open standards for digital currency and already have a significant ecosystem, so
integration with these standards is critical to a successful digital euro project.

> Ability to accept other types of popular currency (e.g. Bitcoin Lightning Network payment) via QR code would benefit merchants because they would be able to easily service tourists who may not hold digital euros but do have open standards based digital wallet apps on their smart phone.

> Yes, member states and regulated banks should be obliged make cash available in exchange for digital
euros and other digital currencies, including for non-customers. Otherwise banks have the power to
"unbank" a person by voluntarily choosing not to do business with that person.

Relative to holding caps, limitations to transactions, or different interest and/or fees disincentives on large holdings.

> These types of proposals are a poison pill for the digital euro project. They will not prevent the march of progress disintermediating financial institutions, nor large EUR holdings. They only ensure that these things
will take place in the context of on-shore and/or offshore stablecoins, and the digital euro project will be
relegated to obscurity.

> Technological progress does not bode well for legacy financial institutions. However, a well thought out digital euro and a well considered forward-looking regulatory framework can be beneficial to financial institutions in every way, because it will unchain them from legacy regulations and therefore allow them to move forward in the digital future.

Best

> The worst possible scenario for the EU financial system is for its institutions to become trapped between an inflexible regulatory environment and a growing decentralized/offshore financial system which is subject to
self-regulation only. Staving off this nightmare is the key reason why the digital euro project must think big and seriously address the privacy and flexibility needs of individual holders whose expectations have already been established by existing DLT/Blockchain solutions.

> Assuming a bearer-based instrument which provides equivalent respect for the rights of the holder as existing DLT/Blockchain based solutions, this will improve the liquidity retail deposits and reduce liquidity risks by standardizing digital representations of the euro and disrupting EUR based stablecoins.

> Licensed 3rd party intermediaries are too dangerous to the digital euro project to provide any meaningful
value. Such 3rd party providers will always tend to corrupt the project toward their own interests, creating
barriers of entry to the digital euro project which they will then offer to help their customers overcome.
The cryptocurrency economy has already built out a free market of solutions to these is

Relative to AML/KYC requirements for banks:

> Intermediary obligations to know their customers and to investigate suspicious payments are not particularly affected by the form of those payments. Intermediaries already have this infrastructure in place, especially due to the legal tender status of cash, so no additional cost is foreseen.

In case it wasn't obvious:

> The withdrawal of digital euros from a financial institution should be addressed in the same way as the withdrawal of cash.

> Ability to use digital euros without any associated identity is necessary to gain any significant adoption among digital currency users (vs. e.g. stablecoins), and people who are not current digital currency users don't have sufficient incentive to adopt digital euros. So privacy features are critical to the success of the project.