European Security Transport Association
ESTA
Representing the cash industry in the EU and in its member states.
ID: 850612124598-41
Lobbying Activity
Meeting with Boriša Falatar (Cabinet of Commissioner Hadja Lahbib), Edouard Schmidt (Cabinet of Commissioner Hadja Lahbib)
19 Sept 2025 · cash payments in the Preparedness Union Strategy
Meeting with Philip Tod (Head of Unit Economic and Financial Affairs)
4 Feb 2025 · External study on the cross-border cash-in-transit (CIT) market commissioned by DG ECFIN - 2025
Meeting with Eric Ducoulombier (Head of Unit Financial Stability, Financial Services and Capital Markets Union)
4 Feb 2025 · Update on the legislative package PSD/PSR, legal tender, digital euro
Response to The scope and effects of legal tender of euro banknotes and coins
3 Oct 2023
The proposal for a Regulation on legal tender of euro cash is a much awaited proposal needed to clarify acceptance of cash and fill the gaps in access to cash. Without a good access to cash, consumers and citizens will have no possibility to pay in cash. Cash is a volume driven business and the current low levels of cash used for payments are threatening its sustainability. The proposal is therefore definitely a right move in the right direction, in mandating the acceptance of cash, but it is not perfect. Regrettably, ex-ante restrictions are not prohibited and will only be monitored by Member States, where different cash cultures will lead to different levels of tolerance for ex-ante exclusions. Allowing ex-ante exclusions to remain undermines the status of legal tender of cash. Similarly, the adequacy of cash access, at a time when banking institutions are widely disengaging from cash, closing branches and removing ATMs will also be left to Member States, were discrepancies are likely to occur in the implementation of the Regulation. Also, a key omission in the definition of legal tender is the provision of change money. ATMs do not deliver coins and change is essential to the smooth operation of cash the suppression of change money is the ultimate stealth weapon against cash. The challenge of change money is of particular importance, as coins are heavy and of low value, and require more proximity than banknotes to be supplied to retailers. No other exceptions to legal tender other than good faith reasons are provided in the Regulation. Particularly, no exceptions exist for public reasons. ESTA feels that all existing cash payment restrictions in Member States should be removed, particularly as an EU-wide limit is being adopted in the context of Article 59 of the anti-money laundering Regulation currently debated in the Parliament and the council. ESTA feels, however, that the draft Regulation should be adopted without changes to allow for a swift implementation, while gaps will subsequently be filled through delegated/implementation acts once the Regulation is adopted.
Read full responseResponse to Review of the CO2 emission standards for heavy-duty vehicles
11 May 2023
Cash in Transit (CIT) armoured vehicles should be considered as special purpose vehicles under Regulation 2018/858/EU and be exempted of CO2 targets under the draft Regulation amending Regulation (EU) 2019/1242 strengthening CO emission performance standards for new heavy-duty vehicles. Emission targets should not interfere with security regulations impacting on health and safety of crews of CIT vehicles. As a consequence, ESTA requests that vehicles allowed to operate as transport arrangements of articles 16, 17 and 18 of the 2011 EU Regulation of 16 November 2011 on the professional cross-border transport of euro cash by road between euro-area Member States, whether used for cross-border or domestic cash transport, in or outside the euro area, should be exempted from the reduced emission targets, as the weight of armouring is bound to increase emissions. The health and safety of crews operating these vehicles should not be endangered because of emission targets. The fleet of CITvehicles represents less than 10,000 vehicles, out of 500,000 HGV produced each year, and is therefore not of a magnitude to undermine the Paris agreement objectives. The draft regulation already provides for the justification of this exemption in its recitals 15 and 21. The details of our position are provided in the attached document.
Read full responseResponse to Proposal for a Directive on cross-border activities of associations
20 Oct 2022
ESTA, the European Cash Management Companies’ Association is pleased to respond to the consultation on a legislative proposal on cross-border activities of international associations. ESTA would support a European status of associations.
The focus of our response is on the difficulties to register locally to VAT for our annual conferences, which take place each year in a different EU Member States. Although ESTA is registered to VAT in its country of residence, each temporary registration takes place as if ESTA was not registered anywhere. The local process is similar to any new VAT registration in the host country, as if ESTA was establishing durably in the country, when the registration is only temporary and for the few months before and after the conference, for a modest turnover.
An increasing difficulty faced is that local agents do not want to take any risk with an organisation they don’t know because of the very hefty sanctions under the anti-money laundering policies, and prefer, as a precaution, to forgo a small revenue than take any risk with a “stranger”.
ESTA suggests that host countries’ VAT administrations take into account the existing home country registration and use the VAT Information Exchange System (VIES) to facilitate temporary registrations to VAT. VIES should serve as a proof of fiscal ID for any other EU VAT administration, not just for businesses wanting to verify the VAT status of any business partner.
Read full responseResponse to A New Consumer Agenda
11 Aug 2020
A critical part of consumer protection is to secure their ability to pay with the instrument of their choice.
1. Protecting consumers against spurious fears of contaminations to COVID by cash
The COVID crisis severely affected the freedom of consumers to pay in cash on ground of allegations of risks of contamination with COVID through cash. It was affirmed that e-payment were safer, though contactless payment does not mean contactless shopping.
Monetary authorities pointed out that cash is contamination through cash is unlikely.
2. Contactless means security less
Contactless limits have increased from €30 to €50. However, it means “security less”. In case of fraud, who will be liable for the cost ?
ESTA calls for a strict rule that card operators need to be responsible and liable for any fraud on payment means requiring no security feature.
3. Make legal tender of cash effective: acceptance of cash should be mandatory
At the time of the adoption of the recommendation of the Commission on the scope and effect of legal tender, it issued a memo clarifying its views, where it said the following:
One of the main features of the legal tender status is the mandatory acceptance. A retailer should not refuse cash unless the refusal is based on reasons related to the good faith principle, for example when the retailer does not have enough euro cash to give the change back; or when there is a disproportion between the amount to be paid and the face value of the banknote. The refusal of cash payments cannot be permanent. Such a practice would be contrary to the Recommendation and to the very concept of legal tender.” (Memo 10/92,, 22 March 2010)
With COVID, many retailers have refused cash. Calls against cash creates a cumulative impact: consumers who have been imposed to use cards for payment will not all revert to their good old habits of using cash.
The Commission argued in June 2020 in the ECUJ that is a fundamental right and economic freedom of citizens to have the ability to pay cash.
ESTA calls for a definition of legal tender making it mandatory to accept cash payments.
ESTA calls for a mandatory information to be provided at the point of sale on the right to pay in cash where cards logos are displayed at the point of sale,
4. The need to protect the “unbanked” and the “de-banked”
ESTA wishes to remind that it is not every body’s ability to pay by card or other electronic means of payments.
5. Protection of consumers also calls for EU payments schemes independent from global schemes.
The recent Commission consultation on retail payments included a number of questions to stakeholders on how the Commission could “contribute to reinforcing the EU economic independence” in retail payments, Virtually all EU schemes are backed by one of these schemes. In this regard, ESTA would submit that the Commission should facilitate the transition from the international schemes to an EU independent scheme, such as the one initiated by a number of European banks in the European Payment Initiative (EPI) by facilitating the use of cash, whereby consumers will be reducing the use of their internationally based e-payments by paying with cash, until the new scheme is operational. Cash is actually a readily tool to facilitate the transition and increase the EU independence even before the EPI has achieved a fully operational scheme.
Our full response is attached.
Read full responseResponse to Action Plan on anti-money laundering
4 Mar 2020
Please see the attached full response from ESTA as the 4000 characters allowed in this link do not allow providing a meaningful response to the issues raised in the consultation document.
ESTA, the European Cash Management Companies' association comprising of more than 120 member companies in Europe and beyond, fully supports anti-money laundering policies and the industry itself has put in place stringent procedures against the risk of being used for money laundering purposes. ESTA submit that cash is not an issue for anti-money laundering enforcement authorities as the process of money laundering consists in most cases in getting rid of cash, in order to create an apparent legal trace for the funds being laundered, while cash leaves allegedly no trace.
In addition, cash is conspicuous and cumbersome to transport illegally cross border, particularly when large sums are involved. There are much quicker, safer, easier and secure ways to move illegal funds than transporting cash. Cash is therefore not a convenient means for criminals.
This also means that the largest part of money laundering is conducted with non-cash channels as the hundreds of billions of Euros and dollars of the Panama and Paradise papers (where no cash was involved) have shown: too strong a focus on cash would distract from where the efforts should be aimed. This does not imply that cash is never concerned in money laundering, but that cash is clearly not the priority.
Illegal activities conducted generally in cash, such as drug trafficking, can also be conducted using C2C e-money payment instruments (such as Swish in Sweden where access to cash is limited).
Furthermore, as the July 2019 Commission communication states, a large majority of suspicious reports referred to FIUs are based on cash transaction (particularly in the context of the process of getting rid of cash mentioned above). The elimination of cash would not mean that there are less suspicious transactions, simply that LEAs would see much less of them since it is very difficult to monitor large numbers of small wire transactions, in reality, are connected to each other. It shows that cash (in large volumes) is a weakness, not an asset, for criminals.
The future of AML policies has to ensure that AML does not risk becoming a hindrance to legitimate bona fide operators and business, as our response illustrates. Particularly, authorities will have to balance risk of the penalties in relation to KYC/due diligence processes with the fact that economic/commercial operators have very limited means and tools to check the accuracy of information given to them, notably in relation to ultimate beneficial owners.
We therefore submit that new additional restrictive measures against cash in the context of anti-money laundering policies would not contribute effectively to the fight against money laundering, and could in the contrary be counterproductive. It should not be overlooked that the objectives of criminal activities is to generate profits, not specifically cash. The reduction of cash in circulation in a number of countries is not known to have been paralleled by a reduction of criminal activities.
These points and a few others are developed in the attached document, which we hope will be of interest to the Commission.
Read full responseResponse to Communication on latest developments in relation to the euro coins
18 Jul 2017
ESTA is pleased to have this opportunity to respond to the Commission roadmap on euro coins of 19 June 2017. This response follows ESTA’s response to the Commission questionnaire of July 2014 on 1 and 2 €c coins. ESTA understands that no decision has yet been adopted on the four scenarios presented in the Commission communication of 2013, although some Member States have discontinued the use of 1 and 2 €c coins in their jurisdiction.
The main focus on the discussion was left, at the time, on reducing the cost of production of these coins. ESTA’s position strongly expressed at the time was to favour any solution that, whilst allowing a reduction of the cost of the coins, would keep all specific characteristics unchanged (size, thickness and electromagnetic signature notably) so as to avoid any change/reprogramming and adaptation of sorting machines. ESTA also spoke against any solution that would lead to the production of new coins which would coexist with previous coins, and would make the adaptation of sorting machine difficult and costly, if two series of coins would have to be processed at the same time.
ESTA reiterates this position today.
The discussion back in 2014 did not solely focus on production cost savings of 1c & 2c coins, but also looked at the issue from a holistic point of view, including the processing and cash cycle management of the coins, taking into consideration the entire life span of the coins. This is of significant importance as some options leading to an initial reduction of the cost of production of coins may end up with a negative balance if these solutions generate in fine higher coins management costs.
Also, ESTA would be wary of options aiming at increasing tolerances or reducing quality checks for low value coins (which to some extend would amount to the same consequences) which could reduce the performance of machines and have very substantial impact on coins processing, if this leads to a large number of coins being rejected or for coins processing machines to jam more frequently than is already the case for 1c & 2c coins. If this is the case, the cost saving achieved in the production process of the coins may well be offset by increased processing costs.
This is particularly relevant as processing of 1 and 2 €c coins is subject to frequent jamming which slows down the speed of processing and requires proportionally more staff than the processing of higher value coins.
ESTA has also shared with the Commission the administrative difficulties that exist in some countries for the delivery of coins to National Central Banks, which go from specific packaging requirements to limited number of offices where coins can be delivered during short opening hours. This does not only concerns 1 and 2 €c coins but is an important factor that needs to be integrated in the assessment of cost efficiency that the Commission suggests in its Roadmap.
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