this post was submitted on 10 Oct 2026
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🇧🇪 Does Belgium’s ban on cash transactions on basic accounts violate the EU PSD? (belgae.social)
submitted 3 days ago* (last edited 3 days ago) by autonomousPunk@belgae.social to c/Law@europe.pub
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Belgium has a ban on cash transactions with “basic” bank accounts. At the same time, the EU Payment Services Directive (PSD) says:

Article 35
Access to payment systems

  1. …
    Payment systems shall not impose on payment service providers, on payment service users or on other payment systems any of the following requirements:

(a) restrictive rule on effective participation in other payment systems;

Superficially, a cash ban would seem to block participation with another payment system. Of course the definition of “payment system” is relevant:

(7) ‘payment system’ means a funds transfer system with formal and standardised arrangements and common rules for the processing, clearing and/or settlement of payment transactions;

Cash is a payment system of the central bank. Does cash meet that definition?

Update: Belgium’s transposition of the law explicitly excludes cash as a ‘payment system’ :

Royal Decree of 11 MARCH 2018
Annex I.B. The following shall not be considered as payment services within the meaning of this Law:

  1. The execution of payment transactions exclusively in cash and going directly from the payer to the beneficiary, without the intervention of any intermediary

(^ machine translated)

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