The Institute of International Finance (IIF) has published an assessment of the European Commission’s proposed legislation on the digital euro. It gave the bill middling marks.
The IIF is a financial industry global advocacy group headquartered in Washington, D.C. with members in 60 countries. It rated the digital euro bill introduced in June and the impact assessment that accompanied it. The note is a follow-up to its comments submitted in June.
The IIF looked at seven areas. It considered six of those areas “partly addressed” by the proposed legislation. Some of the cost-benefit analysis was “basic and high-level,” while other aspects were dependent on previous studies or missing.
The mechanism suggested for financial stability and bank intermediation in the bill is holding limits. Those limits have yet to be set and it is unclear how they would be enforced, the IIF said.
Payment services providers (PSPs) would have limited ability to recover the costs of implementing digital euro services, such as connecting to the infrastructure and creating wallet software, and caps are placed on fees. Credit institutions would be required to provide basic digital euro services for free. Therefore, “economic and liability model challenges” were also found to be only partly addressed, the study found.
Digital euro development timeline. Source: ecb.europa.eu
Privacy controls on the digital euro have yet to be defined, the study noted, and it is not clear what PSPs will be required to do to meet the requirements, or if they it will even be possible for them at the time of introduction of the digital euro. Anti-Money Laundering and cybersecurity measures also remain to be established.
Governance and conflicts of interest were not addressed in the legislation, the IIF said. As the bank supervisor and “issuer, administrator, and fee-setter for a digital euro,” the European Central Bank (ECB) could find itself in conflicting roles of regulator and operator. There is no independent oversight envisioned for it.
The IIF also repeated its position on interoperability. It said:
“There is little-to-no value in settling for recreating parallel systems that could tie up capital and liquidity, face similar pain points, and be expensive. […] A CBDC would need to operate on platforms where other digital currencies otherwise operate.”
The legislative proposal for the digital euro is being developed in tandem with its infrastructure. The digital euro is expected to be in the investigative phase through October. After that, the ECB may decide to begin testing technical and business solutions. A live digital euro could only be issued after the passage of the legislation.
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It is not hard to see why Sir Keir Starmer ends up doing quite so many foreign trips.
On the road to Mumbai, India, from the airport there were giant pictures of the British prime minister looming over the sealed-off roads cleared for his special VIP convoy.
There was nothing short of a carnival along the roadside to greet the cars.
Image: Sir Keir Starmer during a visit to an FA Premier League training facility in Mumbai. Pic: PA
People who knew nothing about Sir Keir – and were happy to admit so to me – dressed up for the occasion in plumes of feathers and chicken costumes and danced to music. The Labour conference does not come close to that.
This trip has a big first – 125 blue chip business leaders, more than any business delegation in history – are here. The enthusiasm to take advantage of the signed, though not completed, free trade deal is clear.
“I think the importance of this trip is reflected by the huge British delegation we’ve got here today,” said Shevaun Haviland, director general of the British Chambers of Commerce.
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“A hundred and twenty five businesses, biggest UK names Beattie, BP, British Airways, Diageo, Virgin, huge businesses all the way through to incredible AI and energy start-ups from around the UK.”
But business leaders have been clear to me that they haven’t simply joined the delegation to further their activities in India. They want to raise their profile with the prime minister, in order to ensure their voice is heard when it needs to be by the government.
Image: Sir Keir Starmer at a Diwali ceremony in Mumbai. Pic: PA
And the picture some paint of life back in the UK is more challenging. CEO of leading architecture firm Benoy, Tom Cartledge, said how 10 to 15 years ago their business was 90% UK activity, and now it is 90% overseas. He said markets like India are important in part because the UK environment is challenging.
“We’re having to go and find new markets because what we do is design big projects, infrastructure, real estate towers, residential, retail,” he told me.
He went on: “There really is a perception of overseas markets that we are sluggish, low productivity, high tax rates. And that does nothing for the confidence. And in fact, I spoke to an Indian client this morning who said that they are relocating from the head offices to Dubai, because the perception is it’s going to get harder, it’s going to get tougher in the UK and we just do not need that.”
It is rare for business figures on a PM delegation to speak so openly.
Image: The PM visits a Premier league youth training facility with ex-England footballer Michael Owen. Pic: PA
Ms Haviland told me that business figures are using this trip to pass a message to the prime minister.
“We want to see no more tax for business,” she told me, saying that’s the message being conveyed right now in India. I asked what they say back? “They hear us,” she replied. “I think we’ll have to wait and see.”
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Another important voice is Rohan Malik, managing partner of EY. He says there’s an optimistic case for the UK over the medium term but suggested short-term challenges for the government.
“No one likes taxes, but at the same time, they are a necessary way for the government to balance the books.
“If I take a five or seven-year view, I feel more optimistic about the future, because I do think some short-term pain will lead to some long-term gains.”
Does he think the business community could bear paying a bit more?
“I think it’s going to be tricky for the chancellor,” he said.
“I don’t envy her position at all to be looking at different, but she’s got other of disposal businesses, but not like more taxation. At the same time, we have to be prepared to understand how do we try and contribute more towards economic growth?”
The candour is not something I can remember from business delegations in the past. That’s a response to the nervousness about a £20bn-£30bn black hole Chancellor Rachel Reeves will have to fill in the November budget. Overall the delegates remain on side – for now.
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