Publications & Research

The IMIA has been actively following and engaging with central banks and policymakers on the euro cash legislative proposal as well as national cash infrastructure and access and/or acceptance conditions and policies over the past two years. Through our exchanges with policymakers as well as cooperative associations, we felt that an up-to-date overview would be useful for the community.

This overview highlights the differences in approaches, parameters used, and institutions involved, such as:

-          Is the legislative initiative on cash access trying to increase the number of access points (Hungary), or legislate on still cash-user-friendly access to cash situation (Austria), or in effect allowing the number of cash access points to decrease by consolidation (Belgium)?

-          Is access to cash legislation looking into improving deposit conditions (Belgium) and including specifically focus on depositing of coins (Netherlands, Sweden) and availability of small denominations (Lithuania)?

-          In terms of acceptance does the legislation only cover transactions where both seller and customer are physical present, therefore excluding vending and parking machines (Norway), or is mandatory acceptance only foreseen for a restricted definition of ‘essential goods’ (Sweden)? What are the permitted exceptions – good faith or also security reasons (Netherlands, Slovakia)? Can non-acceptance be penalised (Spain)?

Read the brief.

·       Due to its unique crisis-resilience and crisis-prevention attributes, euro cash infrastructure needs to be legally secured and uniformly supported, guaranteeing easy-and-convenient access and widely applied mandatory acceptance.

·       Private electronic and digital payment methods and the potential digital euro alone are not sufficient in the digital age to support the crisis-resilience of the European economy and its citizens.

Crisis-resilient payments systems depend on the diversity of payment methods. It is therefore essential that cash legislation is in place that supports the formation of a cash payment habit in ‘good times’ to enable cash as an effective means of payment in crisis times and electronic payments outages. The current fragmentation in the EU cash policies and conditions effectively weakens the cyber and financial crisis preparedness of the community and its citizens.

The cash payment habit cannot be quickly restored when it has been lost. Governments must act now to protect it – and harmonise efforts across the EU.

Read the brief.

Legal Tender Euro Cash Digital CBDC Payments Acceptance Mandatory Access European Commission Right to Pay Deposit Withdrawals Banks Credit

The IMIA calls for clarity on whether the Proposal implies and guarantees euro cash payments acceptance obligation at point-of-sale. The IMIA is concerned that the obligation for Member States to only intervene with remedial measures when a level of non-acceptance of payments in cash undermines the principle of mandatory acceptance implies that ex ante unilateral exclusions of payments in cash are not per se prohibited, as long as refusals of cash payments are not ‘widespread and structural’.

The IMIA argues that it is crucial that legal tender status of euro cash should not be discriminated but consistent to the legal tender status of the digital euro. The Proposal is notably inconsistent with the proposed legal tender status implications for the digital euro, where, apart for microenterprises and private citizens, unilateral exclusions of payments in the digital euro are outright prohibited across the eurozone, and non-acceptance shall be penalised. Read the position paper.

IMIA is of the opinion that it is needed to guarantee absolute obligation to accept cash payments at the point-of-sale, business-to-consumer or government service-to-consumer transactions, uniformly across the eurozone, securing euro cash as a free payment choice to citizens. Therefore, legislative action at EU level is needed to enhance legal certainty and enshrine the legal tender status of euro cash in secondary law. Read the position paper.

IMIA’s view on why it is pertinent to promote and maintain cash payments as reliable and viable and free consumer choice option and therefore advocating safeguarding and investing in cash infrastructure (for wide access and acceptability) as a public good. Cash is the only form of public money intuitively known, understood, utilised and, crucially, trusted by citizens. It provides the society with personal as well as public data safety and privacy, universal inclusiveness, and personal as well as national crisis-resilience. Read the brief.