As digital means of payment advance, ATM networks decline. This has prompted a reshaping of access to cash worldwide. This is happening faster than many consumers, businesses and governments are willing to accept. Far from a legacy issue, the discussion is transforming itself into a regulatory question with passionate politics from both sides. At the forefront of regulatory processes addressing this new reality, Europe is pioneering discussions and policy that might soon become a reference point across the planet on how to preserve physical money in an increasingly digital payments landscape.
Access to Cash Gains Political Momentum in Europe
European countries are increasingly moving to protect access to physical cash, even as consumers and businesses continue to adopt digital payment methods. While several of these initiatives began as political proposals, they have crystallised into a broader regulatory shift in which governments are treating cash as an essential tool for financial inclusion, consumer protection, and national crisis preparedness.
This trend is highly relevant for banks, retailers, fintechs, payment providers, and cash infrastructure companies. Depending on the jurisdiction, businesses may be required to maintain ATM availability, accept cash payments, enable cash withdrawals, or contribute to the cost of physical cash networks.
Belgium is actively advancing measures to legally protect cash access and payments, while Sweden has officially enacted binding legislation requiring cash acceptance in essential sectors. At the EU level, institutions are advancing negotiations on the European Commission's proposal to codify and clarify the meaning and effects of the legal-tender status of euro banknotes and coins.
Belgium: Federal Government Advances on Binding "Cash Action Plan"
In Belgium, the federal government is moving from the current sectoral protocol on ATM access toward a legally binding framework. Under initiatives involving Minister for Consumer Protection Rob Beenders and other federal ministers, the government has launched a Cash Action Plan intended to preserve the availability and accessibility of cash, including by enabling cash withdrawals in shops. The government frames this strategy as a consumer-protection measure, particularly for seniors, people less comfortable with digital banking, and consumers who prefer cash because of concerns about phishing and online fraud.
On ATM coverage, the plan would require banks to ensure sufficient access to cash within set distances of consumers' homes: 2 km in urban areas, 3 km in mixed areas, and 5 km in rural areas. The framework is also expected to include commitments on the physical accessibility, functioning, cleanliness, safety, and telephone reachability of ATM sites, including for elderly people and people with disabilities. The Economic Inspectorate would be empowered to monitor compliance, and sanctions could follow in cases of non-compliance.
For banks operating in Belgium, the initiative represents a shift from the existing sectoral protocol toward a binding legal framework. However, the legal transition is not yet complete: the Council of Ministers has approved a preliminary draft law creating the legal basis for binding agreements with the banking sector, but the text still requires further legislative steps before it becomes fully operative.
This follows the scheduled expiry of Belgium's current 2023 ATM protocol, whose commitments run until 31 December 2027. Rather than simply renewing the existing sectoral arrangement, the federal government is preparing a legal basis in 2026 for a binding agreement with the banking sector, with the first agreement expected to cover the 2027–2032 period and to be tacitly renewable thereafter. As a result, Belgium is not yet operating under a fully new binding framework, but is moving toward one.
Sweden: Cash Acceptance Law Fully Enacted and Active
Sweden has gone further. In one of Europe's most concrete legislative steps to protect cash use, the Swedish Parliament (Riksdag) passed a law on access to cash on 27 May 2026, and the changes officially entered into force on 1 July 2026.
Staffed grocery stores and pharmacies are now legally required to accept cash payments, although exemptions are allowed for staff safety (e.g., high robbery risks) or disproportionate financial burden. Major banks are legally obligated to guarantee nationwide cash-dispensing and deposit services, ensuring local businesses have access to change-handling and daily-taking services. Under the new rules, no more than 0.3% of the population may reside more than 25 kilometres from the nearest cash withdrawal facility, while no more than 1.22% of the population may live more than 25 kilometres from the nearest cash deposit or daily cash deposit location.
The legislation is motivated by payment preparedness, financial inclusion, cybersecurity concerns and national resilience. Both the Swedish Civil Defence and Resilience Agency and the Riksbank recommend that the public have access to several payment methods, including cash, as an essential contingency measure.
Upon passing the bill, the Riksdag issued a formal instruction (tillkännagivande) to the government to investigate whether certain public services, such as regional healthcare centres and municipal facilities, should also be legally required to accept cash.
The EU: Legal Tender Regulation Negotiations Ongoing
At the EU level, the central initiative is the European Commission's proposal COM(2023) 364 final, which would codify and clarify the meaning and effects of the legal tender status of euro banknotes and coins. The proposal does not create the legal tender status of euro cash from zero: euro banknotes and coins already have legal tender status under EU law. Instead, it would make the practical meaning of that status binding. Three core elements of legal tender are identified: mandatory acceptance, acceptance at full face value, and the ability to discharge payment obligations.
The proposal would also set rules on exceptions, cash acceptance, and access to cash across the euro area. In practice, this would strengthen the principle of mandatory cash acceptance, subject to limited exceptions, while seeking to prevent businesses from circumventing cash-acceptance rules through unilateral or standardized 'no cash' arrangements. The initiative has been supported by the European Central Bank, while the European Parliament's position seeks to reinforce safeguards around cash acceptance. As of July 2026, negotiations are still ongoing, proceeding under the ordinary legislative procedure, and are unlikely to face any major setbacks.
What is Coming
For banks, retailers, fintechs, and payment providers in Europe, the direction is: cash access is becoming a regulatory and operational necessity rather than a legacy infrastructure question. Companies operating across the continent should monitor EU and national levels alike as negotiations, national discussions and implementations are set to affect ATM strategy, payment acceptance policies, cash-handling costs, and customer-access requirements.
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