| In June 2025, the Netherlands passed a mandatory cash acceptance obligation — one of the first in the eurozone. Six months later, on 1 January 2026, the same government introduced a prohibition on cash payments for goods above €3,000. Both measures are now in force simultaneously. De Nederlandsche Bank’s most recent annual survey, published in October 2024, found that 38% of Dutch cinemas and 21% of pharmacies still refused cash. In January 2026, the ECB issued a formal opinion raising concerns about specific exceptions in the Dutch acceptance framework. The Netherlands offers a case study in how acceptance legislation interacts with the broader design of a cash framework. |
The background to the Dutch situation is one of the most accelerated cashless transitions in Europe. According to the Dutch Payments Association, cash accounted for 54% of point-of-sale transactions in 2014. By 2024, that figure had fallen to around 20%. De Nederlandsche Bank (DNB) has monitored this decline through its annual retail acceptance surveys since 2022, documenting not just average acceptance rates but sector-by-sector variation.
The 2024 DNB survey, conducted by research firm Locatus across 5,000 retail locations, found that overall cash non-acceptance — measured by PIN-only signage — stood at around 4–5% of all retail outlets. The aggregate figure, however, masks significant sectoral divergence. Cinemas reached 38% non-acceptance in 2024, up from 27% in 2023. Pharmacies reached 21%, up from 16% in 2023. Car parks stood at 21%. Libraries showed an improvement, falling from 14% to 4%. Chain retailers refused cash at a higher rate (6%) than independent retailers (4%), and non-acceptance was concentrated in larger cities.
Against this backdrop, the Netherlands passed its mandatory cash acceptance legislation in June 2025. The legal obligation requires businesses to accept cash at the point of sale from consumers, with a set of exceptions currently being finalised. DNB has been designated as the supervisory authority. The Dutch Payments Association noted at the time that the acceptance obligation did not include rules on the acceptance of cash per se, as the EU legal tender regulation was being developed for that purpose. The national law was designed to complement, not pre-empt, the European framework.
The January 2026 ECB opinion — Opinion CON/2026/3 — addressed the implementing rules for the Dutch acceptance framework in some detail. The ECB observed that one proposed exception, covering cash refusals for payments made between 22:00 and 06:00, was difficult to reconcile with the concept of legal tender under EU law. Accepting cash is, in principle, mandatory at all times: an exception for night hours would, as the ECB noted, effectively deny legal tender status to euro cash for one third of the day. The ECB also flagged that the combination of exceptions in the Dutch framework required careful assessment in terms of proportionality and consistency with the Court of Justice ruling in Hessischer Rundfunk (C-422/19 and C-423/19, January 2021), which established that restrictions on cash acceptance are permissible only subject to conditions of public interest and proportionality.
The current state of the Dutch cash framework can be summarised as follows:
| Measure | Date in force | Key features |
| Cash Covenant (private) | April 2022 | Voluntary standards: ATM coverage, cash availability, acceptance pledges by retail associations |
| Mandatory acceptance obligation | June 2025 (law); implementing rules in progress | Legal duty to accept cash at POS; DNB as supervisor; exceptions under finalisation |
| Prohibition on cash payments ≥ €3,000 (goods) | 1 January 2026 | Applies to professional traders of goods; services excluded; individuals-to-individuals excluded |
| Cash Payments Act (Wet giraal betalingsverkeer) | Expected 2026–2027 | Will codify consumer right to pay in cash; caps ATM fees; sets access standards |
Sources: Dutch Payments Association (Betaalvereniging NL); Cash Essentials; ECB Opinion CON/2026/3 of 22 January 2026.
The coexistence of an acceptance mandate and a transaction restriction in the same national framework has attracted attention from legal scholars and payment practitioners. Taylor Wessing, writing in January 2026, described the situation as a ‘cash paradox’: the acceptance obligation requires businesses to take cash; the €3,000 prohibition requires them to refuse it above a certain threshold. In practice, the two provisions address different transaction types and are not technically in conflict — the acceptance obligation covers everyday retail transactions, while the prohibition targets large commercial transactions involving goods traders. The ECB noted that businesses should be mindful that the two obligations operate in parallel. The broader pattern across Europe is one of increasing legislative activity on both sides of the cash question: access and acceptance obligations on one hand, AML-justified transaction restrictions on the other. The Netherlands is one of the more advanced cases of a country attempting to manage both simultaneously through legislation, with active central bank supervision. DNB’s annual acceptance surveys provide a level of granular monitoring — by sector, by region, by chain versus independent — that most other Member States do not yet have. The methodology, and the findings it produces, may be of interest as the EU legal tender regulation’s monitoring provisions are finalised in trilogue.
One data point from the 2024 DNB survey is worth noting separately. Of the retailers who displayed non-cash signage (25% of those surveyed), 7% used signs that were potentially ambiguous — such as ‘Pay by PIN’ or ‘PIN?’ — where customers might infer a cash refusal when the retailer in fact accepted both. DNB had called on retailers to reduce such signage; the 2024 figure was down from 12% in 2023. The distinction between explicit refusal, ambiguous signage, and genuine acceptance matters for the design of monitoring frameworks under the legal tender regulation, where measuring ‘ex ante unilateral exclusions of cash payments’ is identified in the Commission’s proposal as a key indicator for Member State annual reports.
Sources
1. De Nederlandsche Bank (DNB), ‘Cash acceptance in the Netherlands slightly down’, October 2024. Annual Locatus survey of 5,000 retail locations. Sector data: cinemas 38%, pharmacies 21%, car parks 21%.
2. De Nederlandsche Bank (DNB), ‘No more decline in cash acceptance at most Dutch points of sale, except for car parks, cinemas and pharmacies’, October 2024.
3. ECB, Opinion of the European Central Bank of 22 January 2026 on the acceptance of cash and cash payment restrictions in the Netherlands (CON/2026/3). EUR-Lex: CELEX:52026AB0003. Specific concern: night-hours exception and proportionality under Hessischer Rundfunk.
4. Taylor Wessing, ‘The cash paradox: the Dutch AML reforms as of 1 January 2026’, January 2026. Analysis of the parallel acceptance obligation and €3,000 prohibition.
5. Cash Essentials, ‘Improving Cash Resilience in the Netherlands’, 2025. Background on Cash Covenant (April 2022) and Cash Payments Act.
6. Dutch Payments Association (Betaalvereniging NL), ‘Dutch legislation for cash’, updated March 2026. Timeline of Cash Covenant, acceptance obligation, and Cash Payments Act.
7. NL Times, ‘Over 80 new laws and rules changes will take effect in the Netherlands on Jan. 1’, December 2025. Confirmation of €3,000 cash prohibition entry into force.
8. Court of Justice of the EU, Hessischer Rundfunk, joined cases C-422/19 and C-423/19, 26 January 2021. Established proportionality conditions for cash acceptance restrictions.