Activities of Cristian TERHEŞ related to 2023/0212(COD)
Shadow opinions (1)
OPINION on the proposal for a regulation of the European Parliament and of the Council on the establishment of the digital euro
Amendments (60)
Amendment 35 #
Proposal for a regulation
Recital 6
Recital 6
(6) The digital euro should complement euro banknotes and coins and should not replace the physical forms of the single currency. As legal tender instruments, both cash and digital euro are equally important. Regulation (EU) [please insert reference – proposal for a Regulation on the legal tender of euro banknotes and coins - COM/2023/364] would harmonise legal tender for cash and ensure that cash is widely distributed and effectively used. Both cash and digital euro should equally be accepted across the euro area without discrimination for any form when doing offline payment.
Amendment 43 #
Proposal for a regulation
Recital 18
Recital 18
(18) Since the digital euro requires the capacity to accept digital means of payment, imposing an obligation of mandatory acceptance of payments in digital euro on all payees could be disproportionate. To this end, exceptions to the mandatory acceptance of payments in digital euro should be provided for natural persons acting in the course of a purely personal or household activity or for natural persons receiving salaries, pensions or government assistance. Exceptions to mandatory acceptance should also be provided for microenterprises, which are particularly important in the euro area for the development of entrepreneurship job creation and innovation, playing a vital role in shaping the economy. Union policies and actions should reduce regulatory burdens for enterprises of this size. Exceptions to mandatory acceptance should also be provided for non-profit legal entities which promote the public interest and serve the public good performing a variety of goals of societal interest, including equity, education, health, environmental protection and human rights. For microenterprises and non-profit legal entities, the acquisition of the required infrastructure and the acceptance costs would be disproportionate. They should therefore be exempted from the obligation to accept payments in digital euro. In such cases, other means for the settlement of monetary debts should remain available. Nevertheless, microenterprises and non-profit legal entities that accept comparable digital means of payment from payers should be subject to the mandatory acceptance of payments in digital euro. Comparable digital means of payment should include debit card payment or instant payment or other future technological solutions used at the point of interaction, but should exclude credit transfer and direct debit that are not initiated at the point of interaction. Microenterprises and non-profit legal entities that do not accept comparable digital means of payment from their payers in settlement of a debt (e.g. they only accept euro banknotes and coins), but may use digital payments in settlement of a debt to their payees (e.g. they pay with credit transfers), should not be subject to the mandatory acceptance of payments in digital euro. Finally, a payee may also refuse a payment in digital euro if the refusal is made in good faith and if the payee justifies the refusal on legitimate and temporary grounds, proportionate to concrete circumstances beyond its control, leading to an impossibility to accept payments in digital euro at the relevant time of the transaction, such as a power outage in the case of online digital euro payment transactions, or a defective device in the case of offline or online digital euro payment transactions.
Amendment 45 #
Proposal for a regulation
Recital 19
Recital 19
(19) In order to ensure that additional exceptions to the mandatory acceptance of the digital euro may be introduced at a later stage if they are required, for example due to technical specificities that may appear in the future, the power to adopt acts in accordance with Article 290 of the Treaty on the Functioning of the European Union should be delegated to the Commission in respect of the introduction of additional exceptions of a monetary law nature to the obligation to accept digital euro payment transactions, which would apply in a harmonised way across the euro area, taking into account any proposals from the Parliament and the Member States to this end. The Commission may only adopt such exceptions if they are necessary, justified on grounds of general interest, proportionate, and preserve the effectiveness of the legal tender status of the digital euro. The power of the Commission to adopt delegated acts for the introduction of additional exceptions to the obligation to accept digital euro payment transactions should be without prejudice to the possibility for Member States, pursuant to their own powers in areas of shared competence, to adopt national legislation introducing exceptions to the mandatory acceptance deriving from the legal tender status in accordance with the conditions laid down by the Court of Justice of the European Union in its judgment in Joined Cases C-422/19 and C-423/19.
Amendment 46 #
Proposal for a regulation
Recital 32
Recital 32
(32) An unrestricted use of digital euro as a store of value could endanger financial stability in the euro area, with adverse effects on credit provision to the economy by credit institutions. This may require that the European Central Bank, with a view to ensuring the stability of the financial system, and in line with the principle of proportionality, introduce limits on the digital euro’s use as a store of value. The policy tools that could be used for this purpose include, but would not be restricted to, quantitative limits to individual digital euro holdings and limits to conversion of other categories of funds to digital euro in a specified timeframe. When deciding on the parameters and use of the instruments referred to in paragraph 1, the European Central Bank should respect the principle of an open market economy with free competition, in accordance with Article 127(1) TFEU. The conversion of digital euro to other categories of funds or to cash should always be unrestricted.
Amendment 47 #
Proposal for a regulation
Recital 34 a (new)
Recital 34 a (new)
(34 a) It is fundamental that the creation of the Digital Euro does not give ground for means to track or control on how this type of currency is spent in comparison to cash;
Amendment 52 #
Proposal for a regulation
Recital 57
Recital 57
Amendment 54 #
Proposal for a regulation
Recital 58
Recital 58
Amendment 57 #
Proposal for a regulation
Recital 61
Recital 61
(61) To access and use the digital euro as part of digital euro payment services, digital euro users should be provided with front-end services. Those users should have the possibility to access and use digital euro payment services via the front- end services provided by payment service providers and by the European Central Bank. Payment service providers should be able to choose to rely on front-end services provided by other stakeholders, including the European Central Bank, notably in the case where the cost of developing and operating front-end services, including applications, are disproportionate. Where digital euro users can choose between different front-end services, the decision to select a given front-end service should ultimately rest in the hands of those users and should not be imposed by payment service providers or the European Central Bank. In this respect, payment service providers should have capacity to provide digital euro users with the possibility to access and use digital euro payment services via the front-end services provided by the European Central Bank. The European Central Bank and the payment service providers shallould implement appropriate technical and organisational measures including state-of-the-art security and privacy-preserving measures to ensurmake technologically impossible that the identity of individual digital euro users cannot be accessed by the ECB via its front-end solutionby any means.
Amendment 58 #
Proposal for a regulation
Recital 62
Recital 62
(62) To avoid interfering in the payment service providers’ customer relationships and their role in the digital euro distribution, the front-end solutions provided by the European Central bank should be limited to providing an interface between digital euro users and the payment infrastructures of payment service providers. In particular, the Eurosystem would not have a contractual relationship with digital euro users even if those users use the front-end services provided by the European Central Bank. The ECB and the payment service providers should implement appropriate technical and organisational measures including state-of- the-art security and privacy-preserving measures to ensurmake technologically impossible that the identity of individual digital euro users cannot be accessed by the ECB via its front-end solutionby any means.
Amendment 61 #
Proposal for a regulation
Recital 68
Recital 68
(68) The prevention of fraud by payment service providers is essential for the protection of citizens making use of the digital euro, the integrity of the personal data processed in digital euro payments, and to ensure the smooth and efficient functioning of the digital euro. Fraud prevention plays an essential role in maintaining trust in the single currency. For this purpose, the European Central Bank may establish a general fraud detection and prevention mechanism to support fraud management activities performed by payment service providers on online digital euro payment transactions. A general fraud detection and prevention mechanism delivers a range of essential functions to detect fraud patterns that a single payment service provider could not detect on its own. Often one payment service provider does not have the full picture about all elements that could lead to timely fraud detection. However, it can be made more effective with information on potentially fraudulent activity stemming from other payment service providers. This general fraud detection function exists in comparable payment schemes and is necessary to achieve demonstrably low fraud rates in order to keep the digital euro secure for both consumers and merchants. The transfer of information between PSPs and the fraud detection and prevention mechanism should be subject to state-of- the-art security and privacy-preserving measures to ensure technologically that individual digital euro users are not identified by the central fraud detection and prevention mechanism. This mechanism shall only be considered for implementation if there are empirical grounds to support a collective and general approach, but always ensuring the least intrusive method.
Amendment 62 #
Proposal for a regulation
Recital 69
Recital 69
Amendment 63 #
Proposal for a regulation
Recital 70
Recital 70
(70) The rights to privacy and personal data protection are fundamental rights enshrined in Article 7 and 8 of the Charter of Fundamental Rights of the European Union. As stressed by the European Data Protection Board34 , a high standard of privacy and data protection is crucial to ensure the trust of Europeans in the future digital euro. This is also in line with the G7 Public Policy Principles for Retail Central Bank Digital Currencies. The processing of personal data for compliance and in the context of this Regulation would be carried out in accordance with Regulation (EU) 2016/67935 and Regulation (EU) 2018/171536 , as well as, where applicable, Directive 2002/58/EC37 . While the ECB is fully independent to carry out its competences, such independence cannot compromise these rights. Therefore, when having an option in the concrete design choices for the digital euro operation, particularly its offline part, the most privacy and personal data protection option shall be selected, regardless if that carries an extraordinary burden on other lawful objectives to be pursued by it and the national central banks _________________ 34 Statement on the design choices for a digital euro from the privacy and data protection perspective adopted on 10 October 2022. 35 Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), OJ L 119, 4.5.2016, p. 1–88. 36 Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data, and repealing Regulation (EC) No 45/2001 and Decision No 1247/2002/EC, OJ L 295, 21.11.2018, p. 39–98. 37 Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector, OJ L 201, 31.07.2002, p. 37.
Amendment 67 #
Proposal for a regulation
Recital 75
Recital 75
(75) Offline digital euro payment transactions are payments that occur in close physical proximity (“face-to-face”). They have similarities with transactions in cash and should be treated in a similar way in terms of privacy. Payment service providers should therefore not process personal data related to offline digital euro payment transactions, but only personal data related to depositing or withdrawing digital euros from digital euro payment accounts to load them onto the local storage devices, or from the local storage devices into the digital euro payment accounts This includes the identifier of the local storage devices which payment service providers attribute to a digital euro user that holds offline digital euro. That level of privacy would be comparable to withdrawals of banknotes at automatic teller machines when payment service providers process personal data related to a user’s identity and data pertaining to how funding and defunding transactions have been carried out. That means that no transaction data monitoring should occur for offline digital euro payment transactions. By transaction data, it shall be understood any piece of information directly tied to a digital euro account, either online or offline, when used as intended in the context of this Regulation.
Amendment 71 #
Proposal for a regulation
Recital 77
Recital 77
(77) For the purpose of enforcing the holding limits and ensuring the exceptional switching of digital euro payment accounts in emergency situations upon the request of the digital euro user, a single access point of digital euro user identifiers and the related digital euro holding limits is necessary to ensure the efficient functioning of the digital euro across the entire euro area, as digital euro users may hold digital euro payment accounts in different Member States. When establishing the single access point, the European Central Bank and national central banks should ensure that the processing of personal data is minimised to what is strictly necessary and that data protection by design and by default is embedded. The European Central Bank and national central banks should consider, where appropriate and to minimise the risk of data breaches, the use of decentralised data storagall adopt measures to ensure that account balances can be redeemed directly by users through the use of a backup code.
Amendment 72 #
Proposal for a regulation
Recital 82
Recital 82
(82) WhilSince offline digital euro payment transactions have similarities with transactions in cash and shouldthey must be treated in a similar way in terms of privacy specific holding and transaction limits for offline proximity payments are essential to mitigate AML/CFT risks,;
Amendment 75 #
Proposal for a regulation
Article 2 – paragraph 1 – point 6
Article 2 – paragraph 1 – point 6
Amendment 77 #
Proposal for a regulation
Article 2 – paragraph 1 – point 15 a (new)
Article 2 – paragraph 1 – point 15 a (new)
15 a. 'low value online digital euro payment transactions' means online digital euro payment transactions, either in a single operation or in several operations which appear to be linked, where the amount is bellow the limit to large cash payments set in the Member cash payments set in the Member State where payee is established;
Amendment 80 #
Proposal for a regulation
Article 2 – paragraph 1 – point 28
Article 2 – paragraph 1 – point 28
28. ‘user alias’ means a unique pseudonymous identifier that is different for different transactions in order to prevent the association or tracking of the user across transactions, used to protect user’s identity when processing digital euro payments that can only be attributable to an identifiable natural or legal person by the payment service provider distributing the digital euro or by the digital euro user;
Amendment 86 #
Proposal for a regulation
Article 5 – paragraph 2
Article 5 – paragraph 2
2. Within the framework of this Regulation, the digital euro shall also be governed by the detailed measures, rules and standards that may be adopted by the European Central Bank pursuant to its own competences. Where these detailed measures, rules and standards have an impact on the protection of individuals’ rights and freedom with regard to the processing of personal data, the European Central Bank shall consult and follow the European Data Protection Supervisor's recommendations prior to their adoption, as follows: When adopting a particular measure, rule and/or standard pertaining to the digital euro and how personal data will be processed, if EDPS has indicated a preferred safeguard, then the ECB shall adopt such measure, rule and/or standard. In the event that EDPS has not indicated a preference, and if the ECB has several options to select from, it shall only adopt the one that affects the process the least amount of personal data, regardless of if that option requires additional efforts to be carried out, taking especially into account the data minimisation principle. If the measure, rule and/or standard will also have to be co-decided and/or implemented by national central bansk and PSPs, respectively, then the EDPB will be involved in the process.
Amendment 124 #
Proposal for a regulation
Article 25
Article 25
Amendment 133 #
Proposal for a regulation
Article 32 – paragraph 2
Article 32 – paragraph 2
2. The European Central Bank shall consultand the European Data Protection Supervisor prior to developing the details on the operational elements of the fraud detection and prevention mechanism. shall jointly develop the details on the operational elements of the fraud detection and prevention mechanism, by foreseeing an appropriate storage limitation. In formulating the operational framework for the fraud detection and prevention mechanism to be adopted by the ECB, the selection of methods shall consistently prioritize those that involve the minimal processing of personal data, in accordance with the principles of necessity and proportionality and taking due count of the guidance and opinions of data protection authorities. In the event that there is a likely risk to exclude vulnerable populations from the use of the digital euro as a result from these measures, then such general mechanism should not be implemented. Moreover, any impact assessment conducted by the ECB shall not dispense any other party that engages in fraud detection and prevention activities to conduct their own impact assessment, where applicable, under Regulation 2016/679 and/or any other relevant legislation.
Amendment 136 #
Proposal for a regulation
Article 32 – paragraph 4
Article 32 – paragraph 4
4. For the purpose of this Article, payment service providers shall provide the fraud detection and prevention mechanism with information referred to in Annex 5. Payment service providers shall implement appropriate technical and organisational measures including state-of-the-art security and privacy-preserving measures to ensure that the support service shall not be able to directly or indirectly identify the digital euro users on the basis of the information provided to the fraud detection and prevention mechanism.
Amendment 137 #
Proposal for a regulation
Article 33 – paragraph 1
Article 33 – paragraph 1
1. Without prejudice to Article 6 paragraph (7) of Regulation (EU) 2022/1925 of the European Parliament and of the Council of 14 September 2022 on contestable and fair markets in the digital sector and amending Directives (EU) 2019/1937 and (EU) 2020/1828, original equipment manufacturers of mobile devices and providers of electronic communication services within the meaning of Article 2 (1) Directive (EU) 2018/197247 shall allow providers of front end services and providers of European Digital Identity Wallets effective interoperability with, and access for the purposes of interoperability to, the hardware features and software features necessary for storing and transferring data to process online or offline digital euro transactions, on fair, reasonable and non- discriminatory terms. _________________ 47 Directive (EU) 2018/1972 of the European Parliament and of the Council of 11 December 2018, establishing the European Electronic Communications Code, OJ L 17.12.2018, p. 36.
Amendment 142 #
Proposal for a regulation
Article 34 – paragraph 1 – subparagraph 1 – introductory part
Article 34 – paragraph 1 – subparagraph 1 – introductory part
Payment service providers perform a task ion the public interestbasis of a legal obligation in accordance with Article 6(1)(c) GDPR where they process personal data for the following purposes:
Amendment 147 #
Proposal for a regulation
Article 34 – paragraph 1 – subparagraph 1 – point a
Article 34 – paragraph 1 – subparagraph 1 – point a
(a) the enforcement of limits, including the verification of whether prospective or existing digital euro users have digital euro accounts with another PSP, as referred to in Article 16;
Amendment 150 #
Proposal for a regulation
Article 34 – paragraph 1 – subparagraph 1 – point c
Article 34 – paragraph 1 – subparagraph 1 – point c
(c) the provision of offline digital euro, including the registration and de- registration of the local storage devices as referred to in letter (b) of Annex I;
Amendment 152 #
Proposal for a regulation
Article 34 – paragraph 1 – subparagraph 1 a (new)
Article 34 – paragraph 1 – subparagraph 1 a (new)
For low value online digital euro payment transactions, the processing of personal data by payment service providers shall occur only within the limits and purposes laid out in Article 37.
Amendment 154 #
Proposal for a regulation
Article 34 – paragraph 1 a (new)
Article 34 – paragraph 1 a (new)
1 a. For any other processing activity that the payment service provider carries out regarding the provision of the digital euro, the processing will be based on the performance of a contract between the digital euro user and the payment service provider. In the event that the processing involves special categories of personal data, then it shall be necessary to obtain consent from the data subject
Amendment 157 #
Proposal for a regulation
Article 34 – paragraph 3 – subparagraph 1
Article 34 – paragraph 3 – subparagraph 1
Amendment 159 #
Proposal for a regulation
Article 34 – paragraph 3 – subparagraph 2
Article 34 – paragraph 3 – subparagraph 2
Amendment 162 #
Proposal for a regulation
Article 34 – paragraph 4
Article 34 – paragraph 4
4. Payment service providers shall implement appropriate technical and organisational measures including state-of- the-art security and privacy-preserving measures to ensure that any data communicated to the European Central Bank and the national central banks or to providers of support services do not directly or indirectly identify individual digital euro users.
Amendment 168 #
Proposal for a regulation
Article 34 a (new)
Article 34 a (new)
Article 34a Payment Service Providers, the European Central bank and national central banks shall implement appropriate technical and organisational measures to ensure that the processing of personal data is carried out in such a manner that the personal data can no longer be attributed to an individual digital euro user without the use of additional information in accordance with Article 4 (5) GDPR.
Amendment 169 #
Proposal for a regulation
Article 35 – paragraph 1 – introductory part
Article 35 – paragraph 1 – introductory part
1. The European Central Bank and the national central banks perform a task in the public interest or exercise official authority, on the basis of Article 6.(1).(e) Regulation 2016/679 or Article 5.(1).(a) 2018/1725, where they process personal data for the following purposes:
Amendment 172 #
Proposal for a regulation
Article 35 – paragraph 1 – point c
Article 35 – paragraph 1 – point c
(c) safeguarding the security and integrity of the digital euro settlement infrastructure and of local storage devices;
Amendment 173 #
Proposal for a regulation
Article 35 – paragraph 1 – subparagraph 1 (new)
Article 35 – paragraph 1 – subparagraph 1 (new)
These shall be the only activities that the ECB and the national central banks will be able to carry out within the context of this Proposal
Amendment 175 #
Proposal for a regulation
Article 35 – paragraph 4
Article 35 – paragraph 4
4. Personal data processed for tasks referred to in paragraph 1 shall be supported by appropriate technical and organisational measures including state-of- the-art security and privacy-preserving measures. This shall include the clear segregation of personal data to ensure that the European Central Bank and the national central banks cannot directly or indirectly identify individual digital euro users. The Eurosytem shall be obliged to provide for the segregation of data in the local storage device in relation to offline and low-value online transactions. Transaction data shall be isolated and shall not be exported out of the device.
Amendment 178 #
Proposal for a regulation
Article 35 – paragraph 5
Article 35 – paragraph 5
5. The European Central Bank shall be considered the controller of personal data under as regards to the purposes referred to in paragraphs 1 and 8 of this Article. When the European Central Bank carries out a task referred to in paragraphs 1 and 8 jointly with the national central banks, they shall be joint controllers for that task. The European Central Bank and the national central banks will be data controllers jointly with the payment service providers and support service providers.
Amendment 181 #
Proposal for a regulation
Article 35 – paragraph 7
Article 35 – paragraph 7
7. Where the European Central Bank decides not to confer tasks referred to in Articles 27 and 32 upon providers of support services, the European Central Bank may process the types of personal data referred to in Annex 5 subject to the requirements referred to in paragraph 4 of this Article. Moreover, the European Central bank and national central banks shall implement appropriate technical and organisational measures to ensure that the processing of personal data is carried out in such a manner that the personal data can no longer be attributed to an individual digital euro user without the use of additional information in accordance with Article 4 (5) GDPR.
Amendment 186 #
Proposal for a regulation
Article 36 – paragraph 1 – introductory part
Article 36 – paragraph 1 – introductory part
1. Where the European Central Bank decides to confer tasks referred to in Article 27 and 32 upon providers of support services, providers of support services shall provide payment-related services across PSPs. In such a situation, payment service providers perform a task in the public interest, relying on Article 6.1.(e) Regulation 2016/679, where they process personal data for the following purposes:
Amendment 189 #
Proposal for a regulation
Article 36 – paragraph 4
Article 36 – paragraph 4
4. The processing of personal data for the purposes referred to in paragraph 1 shall only take place when appropriate technical and organisational measures including state-of-the-art security and privacy-preserving measures are implemented to ensure that the providers of support services cannot directly or indirectly identify individual digital euro users.
Amendment 194 #
Proposal for a regulation
Article 36 a (new)
Article 36 a (new)
Article 36a The digital euro user shall be in full control of the digital euro wallet and their data. The technical architecture shall make it impossible for the issuer of the digital euro front- and backend or third- party services connected to them or the European Central Bank, National Competent Authorities or Payment Service Providers to collect or obtain information about the usage. The processing of transaction data shall not allow to track, link, correlate or otherwise obtain knowledge of transactions or user behavior. Personal data relating to the provision of the digital euro shall be kept physically and logically separate from any other data held.
Amendment 195 #
Proposal for a regulation
Article 36 b (new)
Article 36 b (new)
Article 36b 1. Data about payment transactions of the digital euro shall only be processed for purposes contained in an exhaustive list and not for commercial purposes or shared with third parties within the open banking framework. 2. The only purposes for which payment data shall be processed are those described in Articles 34-37. 3. In the case a user of the digital euro is reidentified based on pseudonymous data without their consent by the fraud detection unit, the anti-money laundering unit, the ECB or any other law enforcement or public agency, that user has to be informed about their re- identification and its circumstances at the earliest point in time or at the latest when the investigation is concluded.
Amendment 196 #
Proposal for a regulation
Article 37 – title
Article 37 – title
Anti-money laundering rules applying to low-value online and offline digital euro payment transactions
Amendment 197 #
Proposal for a regulation
Article 37 – paragraph 1
Article 37 – paragraph 1
1. Payment services providers shall apply paragraphs 2 to 6 to low value online digital euro payment transactions and offline digital euro payment transactions.
Amendment 198 #
Proposal for a regulation
Article 37 – paragraph 2
Article 37 – paragraph 2
2. Transaction data shall not be retainprocessed by payment service providers, providers of support services or by the European central banks and the national central banks.
Amendment 210 #
Proposal for a regulation
Article 37 – paragraph 6 – subparagraph 1 – point c a (new)
Article 37 – paragraph 6 – subparagraph 1 – point c a (new)
(c a) (d) the objective of introducing a payment instrument offering a similar level of privacy than cash.
Amendment 222 #
Proposal for a regulation
Annex II – paragraph 1 – point d a (new)
Annex II – paragraph 1 – point d a (new)
(d a) Offline digital euro payment transactions;
Amendment 229 #
Proposal for a regulation
Annex III – point 1 – point iii
Annex III – point 1 – point iii
(iii) information on digital euro payment accounts; includ, meaning information on digital euro holdings of the digital euro user and the unique digital euro payment account number; and
Amendment 232 #
Proposal for a regulation
Annex III – point 1 – point iv
Annex III – point 1 – point iv
(iv) information on online digital euro payment transactions, includmeaning the transaction identifier and the transaction amount.
Amendment 236 #
Proposal for a regulation
Annex III – point 2 – point iii
Annex III – point 2 – point iii
(iii) information on digital euro payment accounts, includmeaning the unique digital euro payment account number; and
Amendment 239 #
Proposal for a regulation
Annex III – point 2 – point iv
Annex III – point 2 – point iv
(iv) information of non-digital euro payment accounts, includmeaning the account number of the linked non-digital euro payment account.
Amendment 243 #
Proposal for a regulation
Annex III – point 3 – point i
Annex III – point 3 – point i
(i) the user identifier; including and the name of the local storage device holders; and
Amendment 245 #
Proposal for a regulation
Annex III – point 3 – point ii
Annex III – point 3 – point ii
(ii) information on the local storage device, includmeaning the identifier of the local storage device.
Amendment 250 #
Proposal for a regulation
Annex IV – point 1 – point i
Annex IV – point 1 – point i
(i) information on digital euro payment accounts, includmeaning the unique digital euro payment account number; and
Amendment 252 #
Proposal for a regulation
Annex IV – point 1 – point ii
Annex IV – point 1 – point ii
(ii) information on online digital euro payment transactions. information linked to an unique digital euro payment account number, includingand the transaction amount.
Amendment 259 #
Proposal for a regulation
Annex IV – point 3
Annex IV – point 3
3. For the purpose of point (c) of Article 35(1), processing shall be limited to the data required for counterfeit analysis of offline digital euro payment transactions: information on the local storage device, includmeaning the local storage device number.
Amendment 266 #
Proposal for a regulation
Annex IV – point 4 – point iii
Annex IV – point 4 – point iii
(iii) information on digital euro payment accounts, includmeaning the unique digital euro payment account number, digital euro holdings of the user, the holding limit selected by the user and the type of digital euro account.
Amendment 270 #
Proposal for a regulation
Annex V – paragraph 1 – point i
Annex V – paragraph 1 – point i
(i) information on digital euro payment accounts, includmeaning the unique digital euro account identifier;
Amendment 273 #
Proposal for a regulation
Annex V – paragraph 1 – point ii
Annex V – paragraph 1 – point ii
(ii) information on online digital euro payment transactions, includmeaning the transaction amount; and
Amendment 276 #
Proposal for a regulation
Annex V – paragraph 1 – point iii
Annex V – paragraph 1 – point iii
(iii) information on the transaction session of a digital euro user, includingand the device internet protocol address-range.