Dutch legislation for cash

Regulatory framework for cash

• 1. Geldmaat

  Since 2011, Geldmaat (formerly GSN or Geldservice Nederland) has been handling cash transactions on behalf of ABN AMRO, ING, and Rabobank. Geldmaat manages and maintains nearly 4,000 ATMs and deposit safes throughout the country.

• 2. Five-kilometer standard

  The five-kilometer standard for ATMs stipulates that most Dutch citizens must be able to withdraw cash within a radius of five kilometers from their home address. This standard has been in place since 2006 on the basis of a MOB agreement, following the Crone bill for basic payment services. This standard is still in use today and is complied with by Geldmaat.

  The three major banks (the owners of Geldmaat) and DNB have agreed that no more than 0.3% of all Dutch citizens may fall outside this standard. Remote homes in sparsely populated areas in particular sometimes fall outside the standard.

• 3. Cash Covenant

  The Cash Covenant was concluded in 2022 under the direction of DNB. The agreements are intended to ensure that cash continues to function properly as a means of payment at physical counters. The covenant has been signed by the major banks, the Dutch Payments Association, representatives of consumers, retailers, the hospitality industry, gas stations, transport companies, cash processors, and DNB. The covenant will remain in force for five years, until 2027.

  The agreements include ensuring that cash remains available, accessible, and affordable for consumers and merchants. Specific points-of-sale establishments, such as municipal counters and pharmacies, must always accept cash, as consumers cannot easily find alternatives.

• 4. Dutch legislative proposal Chartaal

  The Cash Covenant stipulates that DNB and the Ministry of Finance will investigate how the public interest in cash can be safeguarded after the covenant expires. The outcome has been published in the report TICKET – Future structure of the cash chain (In Dutch – May 2023).

  The Cash Bill obliges banks to maintain accessible and affordable cash. The bill includes the following:

  • Nation wide basic infrastructure
    Large banks must maintain a nation wide basic infrastructure of ATMs.
  • Access and fees
    Many banks will be required to offer their current account holders access to the basic infrastructure:
    – free of charge for consumers
    – at maximum rates for merchants
    Small banks (<50,000 account holders) are exempt.
  • Cash transport
    There is virtually one dominant cash transporter in the Netherlands. To ensure continuity, DNB will monitor financial health and availability. Large cash transporters must report periodically.
  • Supervision by DNB
    DNB must supervise and enforce the obligations in the bill.
  • Acceptance obligation
    The Dutch bill does not contain any rules on the acceptance of cash, as an EU bill has been submitted for this purpose. The Netherlands is in favor, provided it is proportionate and feasible (in Dutch).

  Process

  After consultation, the bill was amended and sent to the Council of Ministers in June 2024. The Council of State issued a recommendation (in Dutch) on October 21, 2024, without significant objections.

  The bill will be sent to the House of Representatives with:

  • Explanatory memorandum
  • Recommendation of the Council of State
  • Further report from the minister
  • Royal Message

  After consideration in the House of Representatives and the Senate, the bill can be passed into law.

  Expected timeline

  • Submission to the House of Representatives: Q1 2025
  • Possible entry into force: January 2026, otherwise July 2026

• 5. Money Laundering Action Plan Act – ban on cash payments ≥ €3,000

  The amendment to the Wwft proposes a ban on cash payments for goods worth €3,000 or more. The aim is to make money laundering more difficult.

  In 2027, an EU-wide limit of €10,000 will be introduced for cash payments between traders and service providers. The Netherlands has deliberately opted for a lower limit: €3,000.

  Contents

  • The ban only applies to transactions with or between traders in goods.
  • Transactions between private individuals (e.g., Marktplaats) are not covered by this ban.
  • The ban applies to all merchants who buy or sell goods; there are no sector-specific exceptions.
  • The ban does not apply to services. European regulations will follow in 2027.
  • The €3,000 limit is in line with neighboring countries to prevent a shift in crime.
  • The limit makes money laundering more difficult but leaves room for cash purchases by citizens.
  • The Wwft Supervisory Authority will supervise and evaluate after three years.

  Timeline

  • Bill passed by the House of Representatives: September 2024
  • Passed by the Senate: June 10, 2025
  • Intended effective date: before January 1, 2026

• 6. Amendment on mandatory acceptance

  During the parliamentary debate on September 24, 2024, on the bill “Action Plan on Money Laundering,” Van Dijk and Flach submitted an amendment for mandatory acceptance up to €3,000. The amendment was passed with 81 votes (in Dutch), remarkably within a bill other than cash.

  Content

  • Part of the amended bill ‘Action Plan on Money Laundering’ (in Dutch).
  • Acceptance obligation for any publicly accessible location or institution that offers products or services to private individuals.
  • Exceptions possible via AMvB, provided they are well-founded.

  Timeline

  • Senate submitted written questions.
  • Minister asked ECB for opinion; ECB sees scope for national acceptance obligation (in Dutch).
  • Preliminary consultation procedure and internet consultation to follow.
  • Senate votes on the entire bill, including amendment.
  • Acceptance obligation only takes effect once Orders in Council have been adopted.
  • Expected effect: mid-2026.

   

• 7. European cash bill

  In June 2023, the European Commission presented the Single Currency Package, which includes a regulation on the status of euro banknotes and coins as legal tender. This is part of the package on the digital euro.

  This regulation would give both physical euros and the digital euro the same legal status, including mandatory acceptance (with exceptions).

  Key points

  • “Euro banknotes and coins offered in payment of a monetary debt must be accepted.”
  • Acceptance mandatory for full face value
  • Charging additional fees not permitted
  • Not applicable to online purchases
  • Exceptions include disproportionate banknote value or lack of change
  • Member States must monitor acceptance and access
  • Annual reports to the European Commission and ECB

  Timeline

  • Negotiations are progressing more slowly than expected
  • Both the European Parliament and the Council must adopt the regulation
  • Expected introduction possibly not until 2027–2028