| On 10 July 2027, Regulation (EU) 2024/1624 — the EU Anti-Money Laundering Regulation — becomes applicable across all 27 Member States. One of its provisions establishes a uniform EU-wide ceiling of €10,000 on cash transactions for goods and services, with Member States retaining the option to set lower national thresholds. Several already have: Belgium and the Netherlands at €3,000, France at €1,000–€1,500, Spain at €1,000 for professional transactions, Italy below €1,000. With the legal tender regulation simultaneously moving through trilogue, this is a good moment to ask how these two frameworks are designed to work together. |
The AMLR is a substantial and largely welcome piece of legislation. It replaces a patchwork of national directives with a single, directly applicable rulebook, creates a dedicated EU supervisory authority — AMLA, based in Frankfurt, operational from 2025 — and harmonizes due diligence obligations across Member States. Its primary objectives are financial crime prevention and the countering of terrorist financing. These are legitimate public policy goals, and the regulation addresses them with considerable technical care.
The cash limit provision in Article 80 sits within that broader framework. Its rationale is straightforward: large cash transactions are harder to trace and have historically been associated with money laundering and tax evasion. Setting a common EU ceiling removes the incentive to route transactions through Member States with higher thresholds. From a financial crime perspective, this is a reasonable harmonization measure. At the same time, the AMLR operates in a different policy space from the legal tender regulation currently in trilogue. The legal tender framework is designed to guarantee that cash remains widely accepted and accessible — it requires Member States to monitor acceptance, designate enforcement authorities, and report annually to the Commission. The AMLR, by contrast, restricts the circumstances in which cash can be used for large transactions. The two instruments are not in conflict, but they are also not currently coordinated.
The national thresholds currently in force reflect very different policy choices:
| Country | Cash limit (goods/services) | Notes |
| Belgium | €3,000 | Pre-existing threshold; preserved under AMLR |
| Netherlands | €3,000 | Introduced January 2026; uses AMLR lower-threshold option |
| France | €1,000–€1,500 | €1,000 for consumers; €1,500 for professionals |
| Spain | €1,000 | Applies to professional transactions (Ley 7/2012) |
| Italy | €999.99 | Progressively tightened since 2011 |
| Germany | €10,000 | EU ceiling applies; no lower national threshold |
| Austria | €10,000 | EU ceiling applies; no lower national threshold |
| EU (from 2027) | €10,000 (ceiling) | AMLR Art. 80; Member States may go lower |
Sources: Regulation (EU) 2024/1624, Art. 80; NautaDutilh (Belgium/Netherlands); national legislation for France, Spain, Italy.
The diversity of national thresholds illustrates an important point: what counts as a proportionate limit on cash transactions varies significantly across Europe, reflecting different economies, different cash cultures, and different assessments of the money-laundering risk profile of cash. The AMLR wisely does not impose a single uniform threshold — it sets a ceiling and allows Member States to calibrate below it. That flexibility is appropriate. There is, however, a design gap worth noting. The AMLR’s cash provisions do not include an explicit requirement to assess the financial inclusion implications of national thresholds. The regulation requires due diligence, reporting, and oversight — but not an analysis of whether a given cash limit disproportionately affects people who rely on cash as their primary or only payment method: elderly citizens, people in rural areas, the unbanked, or those who choose cash for legitimate privacy reasons. The legal tender regulation addresses access and acceptance directly; the AMLR does not address them at all.
A further technical point: the AMLR requires obliged entities to conduct customer due diligence for cash transactions at and above €10,000. In practice, the compliance burden associated with this requirement may discourage acceptance of large cash payments at amounts below the formal legal ceiling. This is a known feature of AML regulation, not a flaw — but it means the effective threshold for comfortable cash use in some contexts may be lower than the statutory limit.
The broader context matters here. The AMLR enters into force at a moment when Europe is actively debating the role of cash in its monetary architecture. The legal tender regulation affirms that cash is a right, not a legacy. The digital euro package situates physical and digital money as complementary public instruments. Within that architecture, the question of where AML restrictions on cash are set — and how they are calibrated against inclusion objectives — is not a secondary technical matter. It is part of the same policy conversation.
Sources
1. Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 (AMLR). Official Journal of the EU, 19 June 2024. Art. 80 (cash payment limit); Art. 20 (CDD thresholds).
2. NautaDutilh, ‘The AML Regulation enters into force’, 9 July 2024. Confirms Belgian €3,000 threshold and Member State option.
3. Global Regulation Tomorrow / Taylor Wessing, ‘The Netherlands introduces ban on cash payments of EUR 3,000 or more’, October 2025.
4. Deloitte Legal, ‘The New EU AML Package’, July 2025. Confirms €10,000 EU ceiling and due diligence thresholds.
5. DLA Piper, ‘New EU anti-money laundering rules: What to know’, December 2024. AMLR application date 10 July 2027.
6. National cash limits: France — Code monétaire et financier Art. L112-6; Spain — Ley 7/2012 de 29 de octubre; Italy — DL 201/2011 and subsequent amendments.
7. Council of the EU, press release, 19 December 2025: ‘Single currency: Council agrees position on the digital euro and on strengthening the role of cash’.