ECB Appia consultation: 127 replies back central bank money, but the market splits over how many networks

The ECB Appia consultation drew 127 replies, and the report published on 28 October shows broad backing for central bank money as the anchor of a tokenized European financial system. The replies do not agree on how many networks should carry that money. Respondents split between one network, several, and a limited list of eligible ones, according to the Eurosystem report.

“No decisions have been taken at this stage,” the ECB wrote in its news item. The 21-page report goes further: it says it reflects market feedback only and “does not reflect any Eurosystem preference” on design or architecture. Those choices stay open and will be assessed in the work leading to a blueprint due by 2028.

The document records what the market asked for and sets no policy. Appia is the initiative of the ECB, the euro area national central banks and Danmarks Nationalbank to design a tokenized financial system for Europe. The roadmap came out on 11 March 2026, and the consultation ran until 22 April with 18 open-ended questions. Replies to the first part are published on the ECB website. Replies to the second part, which asked for offers to contribute, are confidential.

The report attributes no view to a named firm and gives no percentage for any position. It says “many”, “most” and “several”, and two opposing camps can both be “many”.

Who answered the Appia consultation: 30 tech and data providers, 27 banks and dealers, three investors

Technology and data providers formed the largest group, ahead of banks and dealers. The ECB says it sorted respondents on a best-efforts basis, so the categories are approximate.

Investors and issuers together sent six replies out of 127, fewer than the eight from trading platforms. Technical and data providers alone sent five times as many. The report also records a caution about the next phase: several respondents warned that leaning too heavily on individual contributors could distort the process, and called diversity and representativeness a safeguard against vested interests.

By geography, 85 replies (67%) came from the EU, with the largest shares from Germany, Spain, France, Italy and the Netherlands. The United States sent 21 (17%), more than the 14 (11%) from non-EU Europe, where Switzerland and the UK led. The rest of the world accounted for seven (5%).

Central bank money by default, stablecoins as a complement

The strongest message concerns the settlement asset. Respondents want central bank money to remain the final settlement asset of a tokenized market, and they want the design to offer it “by default, rather than as an add-on”. The reasons given are monetary sovereignty, settlement finality, legal certainty and resilience. If you need a refresher on what separates this money from a commercial bank balance, our guide on how banks create money and what central bank money is covers it.

They also see a central bank role beyond settlement. In collateral, that means accepting and mobilizing tokenized assets for credit operations. In liquidity, it means letting central bank money balances move efficiently between DLT platforms and the existing TARGET Services, so that cash does not get stuck on separate venues.

Private tokens get a place, one level down. Many respondents favored a two-tier system that combines tokenized central bank money with private settlement assets, calling it more feasible and better for innovation. Tokenized deposits and euro stablecoins are described as complementary assets that could support additional or more advanced uses. The condition is spelled out: “the singleness of money should be ensured and the hierarchy of assets should remain clear”.

Some respondents went a step further and asked that euro stablecoins and tokenized deposits be supported alongside tokenized central bank money, so that a broad range of euro settlement options exists. The report gives no count for that view and names no stablecoin or issuer.

Respondents also said monetary policy transmission could suffer if the market came to rely on foreign-denominated currencies or liquidity pools. The text names no currency or token. For where stablecoin trading against the euro stands today, see our piece on USDC’s share of euro stablecoin trading, based on Kaiko data.

The real split in the ECB Appia consultation: one network, several, or a short list

On this point the text is plain: respondents did not converge on a single model. They described a trade-off, and three positions come out of it.

One network

Many respondents saw settlement on a single network as the most effective way to cut fragmentation, concentrate liquidity, simplify governance and standardize processes. The costs they listed are concentration of activity, a network that would become systemically important, lock-in to one technology or vendor, and weaker incentives to innovate.

Several networks

Many other respondents considered a multi-network system the more likely market outcome, and the one best able to keep central bank money as the anchor across new networks. It would be more resilient and fit more business models. In exchange it needs more interoperability and carries a higher risk of fragmenting liquidity, collateral and compliance.

A limited list of eligible networks

The third option came from the respondents themselves. Central bank money would settle on a limited number of networks, chosen under transparent eligibility criteria and common standards. Some called this a realistic medium-term setup, others a credible long-term target. Its main danger, in their assessment, is that without enforceable standards the design turns into “a set of silos”.

Several respondents warned against limiting central bank money to one network or a narrow set that cannot meet market needs. In that case, they said, settlement assets not anchored in central bank money could serve those needs on other networks, weakening the anchor. The report does not name those assets. Stablecoins would fit the description, but that is our reading, not the report’s wording.

Two questions remain open. The first is control: whether central bank money can settle on more than one network while the Eurosystem keeps control of it is, the report says, still to be assessed. The second is ownership. Respondents did not choose between a network run by the Eurosystem and services offered on networks run by the market. They concluded that ownership counts for less than the ability to guarantee central bank control, neutrality and open access.

The report names no blockchain, and public chains get no vote

Anyone looking for a verdict on Ethereum or any other public chain will not find one. The report names no blockchain and does not put public and private ledgers against each other.

The closest passage is about strategic autonomy. Several respondents wanted European governance of core infrastructure, or at least majority European shareholding and majority European representation in decision-making bodies. Others argued that building on top of global networks could be enough, provided lock-in is reduced through open standards, portable data and clear exit strategies. Consensus and validation, data and identity were the functions flagged as needing European entities.

Open-source code got a similar treatment. Respondents valued it because it can be audited and forked, but said its contribution to autonomy depends on Europeans taking part in the governance and maintenance of the projects. Privacy brought its own tension: positions must stay hidden from other participants while supervisors and auditors must be able to verify transactions. Several respondents suggested selective disclosure, permissioned visibility or zero-knowledge proofs.

Autonomy was not meant as isolation. Many respondents insisted that connections with the rest of the world remain essential, including for the appeal of the euro.

Standards drew the most offers of help

Interest in contributing was high: 103 respondents (81%) submitted several proposals, 11 (9%) submitted one, and 13 (10%) submitted none. The building block on asset interoperability and standards attracted more than 70% of respondents, while the other five each drew around half.

On method, respondents asked for a staged approach, starting with foundations and moving to harder domains as experience grows. Where market practice has already converged, they want it written into an Appia rulebook. Where it has not, they prefer experiments over prescriptive action by public authorities. Identity came up as a sore point, with conflicting KYC and anti-money-laundering requirements, and several respondents saw certifying tokenized assets at network level, rather than by self-certification, as a potentially major benefit.

The law is unfinished as well. Respondents asked for clarity on how Appia fits with MiCA, the Central Securities Depositories Regulation and the Settlement Finality Directive, and said further legislation would be needed in some areas.

Appia timeline: market work before the end of 2026, tests in 2027, blueprint by 2028

Next steps are listed too, though only some carry a date.

Pontes is the part that already runs. It links market DLT platforms with TARGET Services, and the Eurosystem has provided tokenized central bank money through it since 21 September. The ECB release named 13 market participants, among them Deutsche Bank, Santander and Société Générale, plus Axiology, Cashlink, Clearstream and SWIAT as market DLT operators. It said enhanced features and longer operating hours would arrive gradually, with full implementation expected by 2028. The Eurosystem has also accepted tokenized securities as collateral since 30 March. Under its January release, that covers marketable assets issued in central securities depositories using DLT-based services, while work continued on whether assets issued and settled entirely on DLT networks could qualify.

The next visible step is a call for stakeholders on three priority topics: tokenized deposits and payments, tokenized securities, and shared network governance. The Eurosystem says scope and the selection of participants will be communicated in due course. A separate stakeholder group on European market-wide standards is being set up, with a call for nominations also expected in due course. Findings from these groups and regular progress updates are to appear on the ECB website.

Banca d’Italia repeated the main point on 29 October in its own note: the report takes no position on architectural models, and the blueprint is planned for 2028.

What the Appia report changes for now

For someone holding crypto, nothing changes today. The report describes no product or token for the public, sets no rule and removes no option. Appia and Pontes concern wholesale transactions, while the digital euro is a separate retail project that the report does not mention.

For stablecoin issuers, banks and tokenization platforms, the questions that affect them are still open. Private euro tokens are in the discussion as complements, under central bank money, but no eligibility rules for networks exist yet. The Eurosystem gives no date for a decision short of the 2028 blueprint.

The next dated commitment is the market work due to start before the end of 2026. The Eurosystem has not yet said who will be selected or how.