Opinion of the European Central Bank of 14 August 2025 on implementing measures concerning access to cash (CON/2025/22)

OPINION OF THE EUROPEAN CENTRAL BANK of 14 August 2025 on implementing measures concerning access to cash (CON/2025/22) Introduction and legal basis

On 16 July 2025, the European Central Bank (ECB) received a request from the Irish Minister for Finance (hereinafter the ‘Minister’) for an opinion on a draft Finance (Provision of Access to Cash Infrastructure) (Section 5) Order 2025 (hereinafter the ‘first draft law’) and a draft Finance (Provision of Access to Cash Infrastructure) (Section 10) Order 2025 (hereinafter the ‘second draft law’, and together with the first draft law, the ‘draft laws’). The ECB’s competence to deliver an opinion is based on Articles 127(4) and 282(5) of the Treaty on the Functioning of the European Union and Article 2(1), first, second and third indents, of Council Decision 98/415/EC , as the draft laws relate to currency matters, means of payment and the Central Bank of Ireland (CBI). In accordance with Article 17.5, first sentence, of the Rules of Procedure of the European Central Bank, the Governing Council has adopted this opinion.

1. Purpose of the draft laws

1.1 The overall purpose of the draft laws is to implement certain aspects of the Finance (Provision of Access to Cash Infrastructure) Act 2025 (hereinafter the ‘2025 Act’) . 1.2 The first draft law implements the provision of the 2025 Act that requires the Minister, in consultation with the CBI, to specify criteria to ensure sufficient and effective access to cash infrastructure in respect of each of the eight NUTS 3 regions in Ireland (hereinafter the ‘access to cash criteria’). The access to cash criteria must specify: (a) the minimum percentage of the population of the region concerned that ought to be within a radius of not less than 5 kilometres and not more than 10 kilometres of an automated teller machine (ATM); (b) the minimum number of ATMs that ought to be available per 100 000 people in the region concerned; and (c) the minimum percentage of the population of the region concerned that ought to be within a radius of not less than 5 kilometres and not more than 10 kilometres of a cash service point. In setting the access to cash criteria the Minister must take into account: (a) the need to ensure the continued provision of sufficient and effective access to cash for individuals and SMEs, and (b) in the case of the first draft law, the level of access

to the cash infrastructure available to individuals and SMEs as at 31 December 2022, adjusting for the exit of two banks from the Irish market: Ulster Bank Ireland DAC and KBC Bank Ireland plc . On that basis, the first draft law proposes, in respect of each NUTS 3 region in Ireland, the access to cash criteria of: (a) a specified percentage of the population that must be within a radius of no more than 10 kilometres of an ATM, ranging from 96 % to 100 %; (b) a minimum number of ATMs per 100 000 people, ranging from 73 to 94; and (c) a specified percentage of the population that must be within a radius of no more than 10 kilometres of a cash service point, specified at 100 % or 99 % . As outlined in the consultation letter from the Minister, the access to cash criteria in the first draft law are indicative and will be finalised following consultation with the CBI. 1.3 The second draft law implements the provision of the 2025 Act that concerns the designated entities responsible for maintaining access to cash levels in Ireland . Designated entities are credit institutions that meet certain conditions as outlined in the 2025 Act. These conditions are met where, for two consecutive quarters, a credit institution holds (a) a percentage share of current accounts in Ireland, and (b) a percentage share of household deposits in Ireland. The 2025 Act empowers the Minister, following consultation of the CBI, to set the percentage shares for current accounts and household deposits, respectively. The respective percentage shares must be set between the following ranges: (a) at least 5 % and not greater than 15 % of the total number of current accounts of credit institutions in Ireland; and (b) a share of at least 5 % and not greater than 15 % of the total value of household deposits of credit institutions in Ireland. On that basis, the second draft law provisionally proposes the percentage share of current accounts at 10 %, and the percentage share of household deposits at 10 %, as this is the mid-point between the minimum and the maximum range. The second draft law and the respective percentage shares will also be finalised following consultation with the CBI.

2. Observations

2.1 The ECB was consulted on a draft version of the 2025 Act and adopted an opinion thereon . 2.2 The ECB considers it important that all Member States take appropriate measures to ensure that credit institutions and branches operating within their territories provide adequate access to cash services, in order to facilitate the continued use of cash . Sufficient and effective access to cash is necessary to preserve the effectiveness of the legal tender status of cash. If citizens do not have easy access to cash, they will not be able to use it as a means of payment and store of value . The ECB welcomes the establishment of the access to cash criteria in the first draft law, to ensure a

minimum availability of ATMs and cash service points that credit institutions have to maintain in Ireland in accordance with the 2025 Act. The ECB notes that the 2025 Act provides for situations that may trigger a review of these values . Moreover, the ECB notes that, in addition to ensuring the adequacy of access to cash through the access to cash criteria set in the first draft law, the 2025 Act also includes the possibility to remedy local deficiencies for individuals and SMEs . 2.3 The access to cash criteria and the conditions for identification of designated entities in the draft laws are indicative. The ECB understands that the CBI is conducting related data collection exercises and that these values are therefore subject to consultation with the CBI and consideration by the Minister of the data collected. 2.4 On 28 June 2023 the Commission published a proposal for a Regulation of the European Parliament and of the Council on the legal tender of euro banknotes and coins (hereinafter the ‘proposed regulation on the legal tender of euro cash’), which includes an obligation for Member States to ensure sufficient and effective access to cash throughout their territory. The proposed regulation on the legal tender of euro cash provides that, following its adoption, the Commission will adopt implementing acts on a set of common indicators of general application in the euro area, which would allow Member States to effectively monitor and assess the acceptance of payments in cash and access to cash throughout their territory, in all their different regions, including urban and non-urban areas. The ECB will be consulted by the Commission on the preparation of such implementing acts . Once the implementing acts on the common indicators are adopted by the Commission, the access to cash criteria set out in the first draft law would need to be reviewed and, if necessary, adjusted accordingly.

This opinion will be published on EUR-Lex.

Done at Frankfurt am Main, 14 August 2025.

[signed]

The President of the ECB

Christine LAGARDE