EPIF is delighted to share with you its position paper on the proposal on the legal tender of euro banknotes and coins.
EPIF very much welcomes the European Commission’s double objective on the proposal to promote the acceptance and the access to euro banknotes and coins. We see cash availability and acceptance as a crucial element for financial inclusion. For EPIF, cash and digitalized means of payment are complementary to one another rather than mutually exclusive.
While we overall welcome this new proposal, we see merit in having further clarifications and improvements in a few elements of the proposal:
- The exemptions to the mandatory acceptance at face value leave scope for interpretation. EPIF would therefore welcome further clarity on what these exemptions entail. EPIF would also see merit in the clarification on the interplay between the exemptions of this proposal and the Digital Euro proposal.
- While legal certainty regarding the mandatory acceptance of cash must be protected, we welcome the possibility to reassess the impacts of mandatory acceptance to ensure proportionality in certain regions and/or for certain players.
- EPIF welcomes that the proposal envisages Member States to take “remedial measures” for the mandatory acceptance to cash. However, more clarity on which actions Member States can take in these cases would be welcomed.
- For certain payment service providers and merchants, imposing a mandatory acceptance of both cash and the Digital Euro might be disproportionate. EPIF therefore calls for a further consideration of the exemptions allowed to mandatory acceptance.
Our detailed views on this proposal can be found in the paper below.