ESBG acknowledges that access to cash is a relevant concern and may become a crucial issue in light of pandemic-related developments. 

Although access to cash needs to be ensured for the population, especially that in rural and remote areas, the secure management for cash and the maintenance of a wide network of ATMs is expensive for banks. In terms of optimising the cash cycle, payment service providers and other participants in the cash value chain, should pursue two main, complementary strategies, namely shortening, and thus optimising, the cash cycle, and continuing to reduce manual handling and any redundant processes. In parallel, a broader discussion is needed on what cash services banks and other stakeholders render to the wider public and at what cost. Following a proper debate, these “stakeholders” could be widened to include merchants as well as payment services providers and FinTech companies.

Identified Concerns

Despite continuous growth in cashless transactions, we observe an increasing concern about the need to ensure continued access to cash (both notes and coins) from certain parts of the stakeholder community with some expectations that this access should not need to cover its own costs. At the same time banks are required to heavily invest in the development of new means of electronic payments (most notably the further development of pan-European instant payments) while facing competition from digital-only providers that do not support cash services or face-to-face services, do not invest in the necessary infrastructure and yet use the infrastructure provided by banks for the benefit of their own customers. Banks are keen on servicing all their customers, regardless of their digital abilities. However, digitalisation can create tensions and impose choices, in particular in the areas of co-existence of cash and electronic payments and providing services to customer segments that hesitate to or have difficulties in adapting to the digitalisation of payments and other financial services.

In terms of ensuring citizens’ access to cash, banks realise that they are responsible for cash distribution. Handling cash, however, is labour-intensive and the cash cycle consists of various actors adding to complexities in the value chain. A decline in cash usage, where the COVID-19 pandemic has worked as a catalyst, has a logical effect on the related unit costs, as these tend to increase. Given this backdrop, there is need for a proper debate, choices to be made and expectations to be set regarding the cost and type of cash services banks and other stakeholders provide to the wider public. Following a proper debate, these “stakeholders” could be widened to include merchants as well as payment services providers and FinTech companies. Therefore, ESBG supports the need to find a sustainable balance between consumer demand for cash and social responsibility on the one hand and efficiencies in the cash cycle on the other hand.

Why Policymakers Should Act

Without proper intervention, a decrease in usage will result in an increase of per-unit cost for providing cash services. Actors will withdraw from providing cash services as it will no longer be economically attractive, and this will in fact further propel the increase of per-unit costs. Therefore, ESBG advocates for the creation of a forum to discuss how the cash cycle can be optimised as well as under what conditions cash services should be provided by whom.​


Both PSD2 and the Interchange Fee Regulation (IFR) have contributed to decreasing the use of cash, on the one hand by stimulating innovation especially in digital payments, on the other hand by making pricing for card acceptance at merchants more attractive. COVID-19 is also accelerating this development. Some countries have introduced caps above which cash transactions are not allowed – this in an attempt to fight money laundering and terrorist financing. Also, further reductions in the issuance of high denomination banknotes (e.g. the EUR 500 banknote) may contribute to this. Cash fulfils the needs of certain groups but not necessarily the needs of society as a whole, so finding a proper balance is key.