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
- …
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:
- 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)