EN    EN EN 
 
EN    EN  EUROPEAN COMMISSION 
Brussels, 14.7.2010 
SEC(2010) 877 final 
  
COMMISSION STAFF WORKING DOCUMENT 
SUMMARY OF THE IMPACT ASSESSMENT 
  
Accompanying document to the 
  
Proposal for a Regulation (EU) of the Euro pean Parliament and of the Council No xx/yy 
on the professional cross-border transportation  of euro cash by road between euro-area 
Member States 
  
and the 
 
 
Proposal for a Council Regulation (EU) No zz/yy concerning the extension of the scope 
of Regulation (EU) of the European Parliament and of the Council No xx/yy on the 
professional cross-border transportation of  euro cash by road between euro-area 
Member States 
 
{COM(2010)377 final} 
{SEC(2010) 878final} 
 
 
 
EN 2   EN COMMISSION STAFF WORKING DOCUMENT 
SUMMARY OF THE IMPACT ASSESSMENT 
 
 
Accompanying document to the 
  
Proposal for a Regulation (EU) of the Euro pean Parliament and of the Council No xx/yy 
on the professional cross-border transportation  of euro cash by road between euro-area 
Member States 
  
and the 
  
Proposal for a Council Regulation (EU) No zz/yy concerning the extension of the scope 
of Regulation (EU) of the European Parliament and of the Council No xx/yy on the 
professional cross-border transportation of  euro cash by road between euro-area 
Member States 
 
EN 3   EN 1. P ROBLEM DEFINITION  
The 16 Member States that have so far a dopted the euro use the same banknotes and 
coins. However, due to strong differences be tween national legislations it is in practice 
very difficult to transport euro cash by ro ad on a professional ba sis between euro-area 
Member States and very little cross-border land transportation therefore takes place. It is a contradiction in terms that there are border barriers to th e professional transport of the 
single currency within the euro area. 
Due to the nature of the goods transported, the cash-in-transit (CIT ) sector is moreover 
exposed to serious security ri sks. It is therefore of pa ramount importance that cross-
border cash transports take place under conditi ons that provide a high level of security 
for the CIT-staff and for the general public. Due to different  national traditions and risk 
environments, security requirements are how ever interpreted very differently across 
euro-area Member States, leading to large di fferences between national rules in a large 
number of areas, such as authorised trans port types, armouring and equipment of the 
CIT-vehicles, the use of inte lligent banknote neutra lisation systems (IBNS), number of 
staff in the CIT-vehicles, the possession and carrying of firearms by the CIT-staff, 
training requirements, information towards th e police, licence rules and penalties.  
Due to these differences between national re gulations, commercial banks, big retailers 
and other professional cash handlers are in practice in most cases prevented from 
contracting with a CIT-company in another Me mber State, even though  it might be able 
to provide for the most efficient (and shorte st) cash pick-up and de livery circuits. They 
are likewise prevented from taking advantage of the cash services of the nearest NCB 
branch or CIT cash center, if it happens to  be located across the border in another 
Member State. Finally, CIT-companies carryi ng out transportation in border regions are 
not able to plan their transport routes and other cash logistics in the most efficient manner, if potential customers are located on  both sides of the border. This situation 
implies a sub-optimal organisation of the cash cy cle in such regions a nd thus also at euro-
area level. This, in turn, means a higher cost of cash and/or a lower service level for the 
customers compared to a situ ation without national regulator y barriers to cross-border 
cash transports. 
In order to allow stakeholders to take full advantage of the single currency, obstacles to 
the free circulation of euro cash within the euro area should be lifted, while ensuring a 
high level of security for the CI T-staff and the general public.  
At the same time, the CIT-market has a loca l character and the potential cross-border 
market primarily concerns border regions. Th e potential geographical market can roughly 
speaking be estimated to some 100 km on each si de of the border for the majority of the 
transports. Measures to lift the barriers to cross-border transport of cash should therefore 
be proportionate. 
2. A
NALYSIS OF SUBSIDIARITY  
The alternative to action at EU level woul d be voluntary bilatera l agreements between 
Member States or even multilateral agreemen ts. However, action at EU level brings 
 
EN 4   EN important economies of scale as compared to  bilateral or multilateral action. Only action 
at EU level allows taking into  account the future enlargement of the euro area as the EU 
rules for cross-border transport can be used  by any new participating Member State, 
which is not the case for bilateral/multilateral agreements. 
Furthermore, even though a demand exists as expressed notably by the banking sector, 
more than eight years after the introduction of euro cash Member States have not 
concluded any agreements to facilitate prof essional cross-border transport of cash. This 
suggests that EU action is in practice the only possible way of reconciling diverging 
regulatory regimes (currently 16 in number),  covering a wide range of complex issues 
where security issues (e.g. th e carrying of weapons) and la bour market considerations 
interact. 
3. O BJECTIVES  
The general objective of the present Commissi on initiative is to facilitate the free 
circulation of euro cash within the euro ar ea by removing obstacles to the professional 
transport of euro cash by road between euro-a rea Member States, while ensuring that the 
transports take place under conditions that pr ovide a high level of security for the CIT-
staff and for the general public. 
To facilitate professional cr oss-border transport of euro cash is, moreover, a natural and 
necessary complement to the European Ce ntral Bank's Roadmap for more convergence 
of National Central Bank (NCB)  cash services and the creati on of a single euro cash area 
for professional cash handlers. It is moreove r complementary to the payment services 
directive1 and SEPA – the single euro payments area, which aims at making electronic 
cross-border payments in euro as easy as domestic payments. 
As regards the free circulation of the euro, and due to the local character of the CIT-
market, the specific objective should therefore be to facilit ate transport in such border 
areas between euro-area Member States. 
As regards the security for the CIT-staff a nd for the general public, attacks should as far 
as possible be deterred and if an attack ne vertheless takes place, it should result in a 
minimum of human damage. The specific objective should be that cross-border transports are at least as secu re as domestic transports.  
An increase in cross-border cash transports could, however, at  the same time lead to a 
possible negative effect on wage levels and/or employment in  the CIT-sector in a given 
host country, if there are significant wa ge differences compared to neighbouring 
countries. While Member States should in ge neral not be prevented from using their 
comparative advantages, a social minimum pr otection to be observed in the host country 
should at the same time be ensured for the sta ff in the CIT-sector in  line with the existing 
principles in EU legislation. 
                                                
 
1 Directive 2007/64/EC of the European Parliament and of the Council of 13 November 2007 on 
payment services in the internal market, 5.12.2007. 
 
EN 5   EN 4. P OLICY OPTIONS AND APPRAISAL OF BROAD POLICY OPTIONS  
The appraisal has been organi sed in two rounds starting with  a general appraisal of the 
broad policy options and thereafter a more de tailed assessment of the policy options that 
were considered to have the potential of reaching the objectives. 
The impact assessment (IA) has considered fi ve broad options to achieve the objective: 
(1) a baseline no-change scenario; (2) Bilateral or multilateral agreement between those Member States potentially most concerned by cross-border transports; (3) A set of 
common rules for cross-border transports only ; (4) Full mutual recognition; and (5) Full 
harmonisation of the regulation of all CIT-transport. 
Three sub-options were furthermore considered: a) extending the scope of the rules to EU 
Member States that have not adopted the euro ; b) extending the scope  to other cash and 
possibly valuables; and c) restricting the scope to poi nt-to-point transports only. 
The IA finds that options 1 (no-change) a nd 2 (bilateral/multilateral agreements) would 
not be effective in meeting the objective of f acilitating the free circul ation of euro cash, 
since it seems highly unlikely that such agr eements would materialise spontaneously on a 
larger scale. This is confirmed by the fact that no agreement has so far been concluded 
during the more than eight ye ars that have passed since eu ro banknotes and coins were 
introduced. Furthermore, even in the case of such an agreement, it would still only cover 
part of the euro area and it would not allow taking into account future enlargements of 
the euro area. An agreement at EU level ther efore seems to be a more efficient and in 
practice the only possible approach to facilit ate cross-border cash transport between all 
the concerned countries. 
Option 3 (a common set of rules applicable to  cross-border CIT-tr ansports only) would 
meet the objective of facilitati ng the free circulation of euro  cash. Since it is limited to 
cross-border transports it would furthermor e not go beyond what is necessary to achieve 
the objectives.  
Option 4  (full mutual recognition) would meet th e overarching objective  of facilitating 
the free circulation of euro cash, but it would mean that CIT-companies would be 
allowed to operate across borde rs under several different nati onal sets of rules. This 
would be very confusing for the compet ent national supervisory and enforcement 
authorities. Such a situa tion would be unacceptable in a sector that is by the nature of its 
business exposed to serious security threats a nd would not meet the objective of ensuring 
that the transports take place under conditions th at provide a high level of security for the 
CIT-staff and for the general public. This optio n could also be seen  as disproportionate 
since it could affect th e whole territory of the host Memb er States, unless the scope of the 
option is specifically restrict ed to cross-border operations. 
Option 5 (full harmonisation) would meet the objective of facilitating the free circulation 
of euro cash and would be consistent with a single euro cash area and the single market. 
However, since cross-border euro cash trans port only concerns a limite d part of all euro 
cash transport, it would not be proportionate re lative to the stated objective to harmonise 
the rules for all CIT-transports, whether cr oss-border or not. A full harmonisation would 
furthermore be very difficult in view of th e many sensitive and security-related issues 
involved in the area of CIT, not the l east concerning the posse ssion and carrying of 
weapons. 
 
EN 6   EN The three sub-options are considered as rele vant. However, including such diverse items 
as valuables in general under the scope of common rules is  rejected since it risks 
complicating the legislative effort and deflect it from the core objective of the initiative. 
The detailed analysis of impacts therefore concerns a set of common rules for cross-
border transport together with sub-option a), part of sub-option b)  and sub-option c).  
5. D ETAILED ASSESSMENT OF IMPACTS  
The second-round assessment includes a detaile d assessment of the economic, social and 
environmental impacts of the broad option 3 - common cross-border ru les – and the three 
sub-options. It also assesses the possible im pact on the security of the transports.  
The different impacts depend to a large degree on the size of the potential market and the 
extent to which it can be re alised. In order to collect information on the current CIT-
market and to estimate the size of the potentia l market for cross-border cash transport by 
road, if current regulatory obstacles to such  transports are lifte d, DG ECFIN launched an 
external study that was carri ed out by Ramböll Management2. According to this study, it 
is estimated that the potential long-term market, assuming that all obstacles to 
professional cross-border euro cash transports  by road are lifted, would amount to around 
2.6 % of the total market (expre ssed in terms of the value of all euro cash ordered to CIT-
companies), which would correspond to  some 77 000 cross-border transports3 potentially 
being carried out each y ear in the 11 euro-area countries that have land borders to other 
euro-area countries. This is a large increase compared to  the current situation and 
indicates that there is a potential for a si gnificant increase in cross-border euro cash 
transports if regulatory obstacles are lifted. 
The above estimation is based on current traffic flows. It is, however, difficult to predict 
what the effects of opening th e cross-border market may be. Cross-border cash  transports 
means not only potentially cheaper service, but also potentially better service for which 
customers may be willing to pay more. As an ex ample, a big retailer may be better served 
from a cash center across the border that could more easily deliver/pick-up cash on a daily instead of on a weekly ba sis. Lifting obstacles to cr oss-border transport could in 
this example have a positive imp act on the costs/risks of the re tailer (less storage/security 
costs and risks involved) which could have  a positive impact on the CIT-business as 
more frequent deliveries and addi tional turnover would be created.  
The facilitation of cross-border cash transports is also likely to produce some 
environmental benefits, due to shorter transports overall.  
A significant increase in cross-border transpor ts may, however, also have negative social 
effects in the host countries. This concerns  notably a possible e ffect on wage levels 
and/or employment in the CIT-sector in a given host country, if there are significant 
differences in salaries compared to nei ghbouring countries. The impact assessment shows 
                                                
 
2 Available at the website of  the European Commission at: 
http://ec.europa.eu/economy_finance/articles/ euro/2010-02-26-cross-border-cash_en.htm   
3 A transport meaning a CIT-vehicle that crosses th e border twice; once on its outbound journey 
and once on its homebound journey. 
 
EN 7   EN that significant differences in salaries seem to exist between some neighbouring euro-
area countries. Salary differences are furtherm ore very substantial between some of the 
countries that have not yet adopted the euro  and their neighbours in the euro area. It 
therefore seems justified to mitigate the potential social impact in the host country by 
ensuring a minimum protection of the workers in  line with the principles of existing EU 
legislation.  
Directive 96/71/EC on the posting of work ers is intended to pr ovide for a minimum 
protection to be observed in the host country  in the case of workers who are posted to 
perform temporary work there. However, cons idering the specific nature of CIT transport 
services, notably the frequent and short-term nature of the potential work periods abroad 
and the different contractual situations, ther e is a need to provide for the analogous 
application of Directive 96/71/EC to all cross-border cash transport services in order to provide legal certainty for opera tors and ensure the practical applicability of the Directive 
in this sector. The proposal therefore include s some specific provisions in order to create 
legal certainty for the concerned operators,  notably by ensuring th at cross-border CIT 
workers are guaranteed the relevant minimum rates of pay of the host country according to the Directive. 
The broad option 3 is furthermore developed into four specific options in order to take 
into account security-related  or other sensitive issues: 
Option A.  National rules on the carryi ng of weapons by CIT-staff remain fully in force. 
Option B . A number of CIT-transport types are esta blished, with opt- out possibilities for 
the individual Member States. 
Option C.  Restriction of the scope of cross-bord er transport to one day and daytime, 
meaning that the CIT-vehicle shall depart from  and return to its Member State of origin 
in the same day and the transport sh all be carried out during daytime. 
Option D.  The majority of the number of cash de liveries/pick-ups made by a CIT-vehicle 
during the day must be carried out on th e territory of the host Member State(s). 
The consultations with Member States' admi nistrations and other stakeholders have 
shown that these exceptions are seen as necessary in order to ensure a high level of security and that they are a necessary pr econdition for achieving a sufficient consensus 
on common cross-border rules for cash transports. 
The analysis has shown that although th ese options may imply a reduction of the 
potential cross-border market, they are not ex pected to create major obstacles for cross-
border transports and the proposal foresees in all cases solutions that  enable cross-border 
transports (strong-box for weapons in the ve hicle that can only be opened by remote 
control by the control room, standardised tr ansport options, recogni tion of equivalent 
weapons training etc.).  
As regards the security  of the transports, the proposal foresees high standards in the 
relevant security-related fields, the preservati on of national rules in sensitive areas such 
as weapons legislation and pos sibilities for Member States  to opt out from specific 
transport types if they do not consider them compatible with the national environment. It 
 
EN 8   EN is therefore concluded that the envisaged common rules prov ide a high level of security 
for cross-border transports. 
The administrative burden, finally, is considered  to be relatively limited and would in the 
case of CIT-companies only concern those co mpanies that choose to  apply for a cross-
border licence. 
6. C OMPARISON OF OPTIONS  
The impact assessment concludes that the pref erred option is a set of common rules that 
would be valid in all euro-area Member States but limited to cross-border transports (option 3), together with the specific derogati ons and restrictions to  the scope foreseen 
under the specific options A-D. This polic y option would fulfil the objective of 
facilitating the free circulation of euro cash w ithin the euro area, and would do so in the 
most efficient way relative to the other broad policy options, while ensuring that the 
transports take place under conditions that pr ovide a high level of security for the CIT-
staff and for the general public. It is furthe rmore recommended that Option 3 is extended 
to the territory of a Member State that is about to introduce the eu ro, since there will 
normally be an increased need for cross-border  euro cash transportation in the run-up to 
the changeover. The extension should apply as from the date of the decision of the 
Council to abrogate its derogation from participating in the euro. 
7. M
ONITORING AND EVALUATION  
A Committee on the cross-border transport of euro cash, with representatives from the 
Commission, the Member States covered by the common rules and representatives of the 
European Central Bank, should be set up in order to monitor the implementation of the 
new rules and possibly propose measures to  improve their functioning. The Committee 
should also consult the relevant stakeholders, including the social part ners, and take their 
views into account  as appropriate. 
A formal review should furthermore be fo reseen with a Commission report to the 
European Parliament and the Council at the late st two years after the entry into force of 
the common rules. The review should also in clude consultations of the stakeholders in 
the sector, including the social partners . Based on the result of the review, the 
Commission could make a proposal to re vise the Regulation. The review should 
thereafter be repeated every five years.