This staff note examines the key elements of the European Union’s (EU’s) digital finance policy agenda that have yet to be fully implemented. Starting in mid-2025, measures from at least 10 different pieces of legislation that have been adopted or proposed will require implementation steps by financial institutions (FIs) in a very small window of time. This pile-up of implementation measures will not only prove burdensome on FIs, it is likely to lead to overlap, or create inconsistencies and discontinuities in the regulatory framework. 

This note builds upon previous IIF publications on the EU’s digital finance agenda, including on the digital euro project and the European Commission’s (EC’s) payments agenda. Our earlier work has documented how these initiatives interconnect, including through potential impacts of the digital euro project on the business models of payment service providers (PSPs) such as banks, and the challenges of administering digital euro holding limits while maintaining citizen privacy. We also recently raised the issue of the interface of privacy legislation with the EU’s AI Act.