EN    EN EN 
EN    EN  EUROPEAN COMMISSION 
Brussels, 14.7.2010 
SEC(2010) 878 Volume II/V 
COMMISSION STAFF WORKING DOCUMENT 
 
IMPACT ASSESSMENT 
accompanying document to the  
Proposal for a Regulation (EU) of the Eu ropean Parliament and of the Council No 
xx/yy on the professional cross-border tr ansportation 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 Europe an Parliament and of the Council No xx/yy 
concerning the professional cross-border tr ansportation of euro cash by road 
between euro-area Member States 
  
{COM(2010)377 final} 
{SEC(2010) 877final} 
 
EN    EN CONTENTS 
VOLUME II 
6.2.2. Potential environmental impact.................................................................................... 3 6.2.3. Potential social impact................................................................................................. .4  
6.2.4. Specific options: Non-harmonised rules on the carrying of weapons, National 
derogations from authorised transport type s and Restrictions of the scope of the 
common rules ............................................................................................................... 9 
6.2.5. Potential impact on the secu rity of the transports ...................................................... 11 
6.3. Sub-options............................................................................................................... .. 12 
6.3.1. Extending the geographical scope to EU Member States that have not adopted 
the euro....................................................................................................................... 12 
6.3.2. Extending the scope of goods carried to other cash. .................................................. 14 6.3.3. Restricting the scope to ' point-to-point' transports..................................................... 14 
6.4. Administrative burden................................................................................................ 15 7. Comparison of options and summary of impacts (second-round assessment)........... 16 8. Monitoring and evaluation ......................................................................................... 20 
EN 3   EN 6.2.2.  Potential environmental impact 
The removal of a barrier to transport represented by a national border removes a 
logistical constraint for CIT-transports in  border regions and thus makes it possible to 
plan and carry out CIT-transports in a more optimal way. This will also, ceteris paribus, 
lead to shorter transports overall and a reduction in fuel consumption and related CO 2 
and other emissions. An attempt at quantifyi ng such potential savings was made in the 
external study on the potential market for cross-border cash transport referred to above. 
The estimation of the potential savings in tr avel distance was based on the reduction in 
driving distance when using a cash centre on the other side of the border compared to 
using the domestic cash centre, cf. the blue  area labelled "potential market" in the 
hypothetical example below. 
  
Example A:  
In this example it is 
assumed that there is a cash centre near the Belgium-French border 
at the town of Dinant 
(Cash centre BE) and on the French side of the border in the town 
of Charleville Mezieres 
(cash centre FR). 
The blue area indicates 
the potential market 
for cross-border transport measured in 
terms of the part of 
France, where French  
 
CIT customers have a shorter distance to the cash centre located on the Belgium side of the 
border (Cash centre BE) than the cash centre located on the French side of the border (Cash 
centre FR) and where the French costumers are located within the action radius of the Belgian cash centre. The blue straight line defining the blue area indicates the place where there is an 
equivalent distance to the two cash centres in question. The green pushpin in the blue area 
indicates the centre of the area that is assumed to be the average distance to the potential market. 
  
A general approach was used aimed at assessing the average of the savings in distance 
that may accrue from cross-border CIT tran sport within the potential market zone (for 
further details, see Annex V). This approach was applied to each of  the 19 border areas 
between euro-area countries exam ined in the report. It should be emphasised that this is 
a simplified and theoretical ex ercise, which nevertheless c ould provide some indication 
of the magnitude of these savings. 
EN 4   EN The results show that the typical savings in travel distance is  around 19 km pr outgoing 
or ingoing trip, but also that these distance savings are subject to significant variations 
across the different border areas. In some areas  the savings in distan ce are only around 
2-4 kilometres, while the savings in other border areas are as high as 54 kilometres per trip. The estimated savings pr trip can be ag gregated into total sa vings pr. day and pr. 
year. This shows that cross-border CIT tr ansports can save around 2.8 million km pr 
year in the long-term. This corresponds to 0. 8 percent, respectivel y, out of the total 
kilometres that CIT-vehicles travel per year.  
In terms of associated savings in fuel and CO
2 emissions, the reduced travel distance 
means reductions in fuel consumption estimated  to 0.4 million litres of diesel per year in 
the long-term, while the reductions in CO 2 emissions are some 850 tonnes. 
Facilitating cross-border cash transports ar e thus likely to produce some environmental 
benefits, but of a limited magnitude relative to the total number of kilometres, fuel consumed and CO
2 and other emissions. As mentioned at the beginning of Section 6, the 
savings depend also on the extent to whic h the potential market can be realised. 
6.2.3.  Potential social impact 
If regulatory obstacles to the professiona l cash transport by road are successfully 
removed, leading to a significant increase in cr oss-border transports and a more efficient 
cash cycle, this would strengthen the competitiven ess of the sector as a whole. This is in 
the long-term interest of the workers in the sect or in order to safeguard jobs and salaries.  
The extra qualifications needed by staff in order to carry out cross-border transports, 
such as language skills, knowledge about CI T-legislation and procedures in the host 
country etc, should also provide incentives for the employer to pay higher salaries to 
staff possessing such skills. In this context,  appropriate training is  obviously important. 
Minimum training requirements should theref ore be foreseen as part of common cross-
border rules (which is not required in all eu ro-area countries), which should inter alia 
cover cross-border CIT-legislation and proce dures, applicable nati onal legislation and 
rules covering CIT. 
As explained in the problem definition above , a significant increa se in cross-border 
transports may, however, also have negative social effects in the host countries. This 
concerns notably a possible effect on wage le vels and/or employment in the CIT-sector 
in a given host country, if th ere are significant differences  in salaries compared to 
neighbouring countries. It may therefore be ju stified to mitigate the potential social 
impact in the host country by ensuring a mini mum protection of the workers in line with 
the principles of existing EU legislation. Directive 96/71/EC of the European 
Parliament and of the Council is intended to  provide for a minimum protection to be 
observed in the host country in the case of workers who are posted to perform 
temporary work there. According to the Dir ective, Member States shall ensure that 
workers posted to a host country are guarant eed a number of terms and conditions of 
employment, provided these are laid down by la w or by collective agreements that have 
been declared universally applicable1. These include minimum rates of pay, including 
overtime rates, as well as pa id annual holidays, maximu m work periods and minimum 
                                                 
1 For the full text, see Article 3(1) of Directive 96/71/EC. 
EN 5   EN rest periods, health, safety and hygiene at work, protecti ve measures for pregnant 
women etc.  
In view of the specific character of CIT tran sport services there is however a need to 
clarify the application of Directive 96/71 to cross-border cash transport services. This 
concerns notably the frequent and short-te rm nature of the pot ential work periods 
abroad, for instance once a week but where each period in the host country amount to less than a day. CIT-staff might  furthermore work in more than one host country in one 
day. This situation would require complicated  pro-rata calculations  and consequently 
also a need to measure the number of hou rs that CIT-staff spends in the host 
country(ies). Moreover, the di fferent contractual situatio ns in the CIT-sector may 
require a case-by-case assessment of whethe r the Directive applies. The CIT-company 
may either provide its service (cash deliveries/ pick-ups) under a direct  contract with the 
service recipient (a bank or a retailer) or it may provide  its service to the service 
recipient (in this case a retailer) under a contra ct with the bank of that retailer. In the 
latter case, the Directive may not be applicable. 
In order to create legal certai nty for the concerned operators and in order not to impose 
an unnecessary administrative burden on the ope rators, which could in practice have the 
effect of seriously impeding the possibility of  carrying out such cro ss-border tr ansports, 
the following specific provisions should theref ore apply to cross-bor der cash transports: 
• It should be clarified that the minimum protection of workers foreseen by the 
Directive should apply to all cross-border cash transpor ts carried out under the 
common rules. 
• Furthermore, the minimum protection should be limited to the minimum rates of pay, 
including overtime rates, according to the universally applicable collective 
agreement for the relevant sector (or, failing that, accordi ng to the statutory 
minimum wage). In order to avoid complicat ed pro-rata calculations, these minimum 
rates of pay should, furthermore, be  guaranteed for the duration of the whole  working 
day (also in cases where only part of  the day would be spent abroad).  
These simplifications are justified by the spec ific character of the CIT-sector. However, 
if it follows from existing contracts, regulations or administrative provisions as well as practical arrangements that the worker will carry out his work in another Member State for an extended period, i.e. more than 100 days  (fully or partially spent) in a calendar 
year, it is appropriate that the minimum protection should incl ude all the terms and 
conditions of employment covered by the Di rective (i.e. also holidays, maximum work 
periods and minimum rest periods etc).  
Due to the specific characteristics of the CI T-sector, it is also necessary to foresee a 
derogation from the general rules in the tran sport sector as regards cabotage (limited to 
three cabotage operations in the host Member State within seven days according to the 
recast Regulation on common rules for access to the international road haulage market). 
While the envisaged common rules foresee that the CIT-transport should return to its 
Member State of origin in the same day as  it left (see Secti on 6.2.4), no limit to the 
number of cash pick-ups/deliveries are fores een since a CIT-vehicle that is carrying out 
retail transport may do up to 20-25 such stops a day. 
Table 3 below attempts to give an indication of the situation for cross-border transports, 
if the minimum rates of the host country ap ply (provided it is hi gher than the actual 
salary paid to the worker under his labour c ontract). 'Home' means home country actual 
EN 6   EN salary according to the labour contract and 'Host' means host country minimum rates. It 
should be pointed out that th e minimum rates of pay in th e table may be underestimated, 
since they only include the basic salary in  the relevant collective agreements (if 
universally applicable) but not  possible premiums or allowances therein. The extent to 
which other wage elements may be taken in to account for the calc ulation of minimum 
rates of pay depends on the situation in each Member State and remain s to be clarified. 
The existence of univers ally applicable collective agreements is based on an analysis by 
the lead service of the relevant collective agreements and national legislation and is not based on official communications from Member States. 
The envisaged 'minimum protection rule' woul d ensure that the minimum rates of pay 
according to the universally applicable re levant collective agreements cannot be 
undercut in Belgium, the Netherlands, L uxembourg, France, Italy, Austria, Spain and 
Portugal, which according to the abovementioned analysis all have such agreements. 
EN 7   EN Table 3. Applicable salary if minimum rates of host country applies (statutory minimum 
wage or minimum rates according to uni versally applicable collective agreements) 
In grey 'from-fields': actual gross (pre-tax) salary. In grey 'to-fields ': minimum rates of pay according to 
universally applicable relevant collective agreemen ts (UACA) or, failing that, statutory minimum wages 
(SMW). 
To 
 
 
 
From BE 
 
(2153-
2408 €)
(UACA)   DE 
 
 NL 
(1386-
2067 €)
(UACA) LU 
(1879-
2560 €)
(UACA) FR 
(1297-
1560 €)
(UACA) IT 
(1015-
1798 €)
(UACA) AT 
(1460 €)
 
(UACA)  SI 
(589 €) 
 
(SMW) SK 
(296 €) 
 
(SMW) ES 
(917-
961 €)
(UACA) PT 
(943 €)
 
(UACA) 
BE 
(2365 €)  Home 
(2365 €)  Home 
(2365 €)  Depends  Home (2365 €)  
     
DE (*) 
(1315-2261 €) Depends  Home 
(2135€ / 2261€) Host 
Home  Home      
NL 
(1902 €) Host 
(2153 to 2408 €) Home 
(1902 €)  Normally Host Home 
(1902 €)       
LU 
(2572 €) Home 
(2572 €) Home 
(2572 €)  Home (2572 €)  Home 
(2572 €)       
FR 
(2268 €) Depends  Home 
(2268 €)  Depends  Home 
(2268 €)    Home 
(2268 €)  
IT 
(2083 €)     Home 
(2083 €)   Home 
(2083 €)  Home 
(2083 €)     
AT 
(2077 €)  Home 
(2077 €)    Home 
(2077 €)  Home 
(2077 €) Home 
(2077 €)   
SI  
(1083 €)      Depends Host 
(1460 €)     
SK 
(750 €)       Host 
(1460 €)     
ES 
(1754 €)     Home 
(1754 €)      Home 
(1754 €)  
PT 
(1189 €)          Home 
(1189)  
* Collective agreements in Germany are concluded at th e level of each Land. For sa laries in the relevant 
German Länder, see table 1. 
Sources : Collective labour agreements in the CIT-sector  and national legislation (for minimum rates of 
pay according to universally applicab le collective agreements), Eurostat  (for statutory minimum wages), 
ESTA, 2010 (for BE, ES, FR, LU, NL, AT, PT, SI an d SK). Replies to questionnaire of 17.7.2008 to 
Member States' permanent representations (for IT). Bundesvereinigung Deutscher Geld- und Wertdienste 
e. V. (for DE). The minimum mont hly salary according to collective ag reements does not include possible 
13/14th months or risk premiums. For statutory minimum wages, the data has been adjusted to take extra 
monthly payments into account. Actual monthly salary is actual annual salary divided by 12 including risk allowances etc. 
NB: Euro-area countries with no land borders to othe r euro-area countries are not  included in the table. 
EN 8   EN Based on the information in the table, such a clarified 'minimum protection rule' would 
in practice ensure that CIT-workers that car ry out cross-border cash transports over the 
borders from the Netherlands would be entitle d to the minimum rates of pay in Belgium 
according to its universally applicable coll ective agreements in the CIT-sector. For 
possible cross-border transports  from Germany to Belgium, it would mean that workers 
under collective agreements from Rheinlan d-Pfalz/Saarland woul d be guaranteed the 
Belgian minimum rates, whereas for wo rkers under collective agreements from 
Nordrhein-Westfalen it seems to depend on the profile of the worker (seniority etc), but 
the rates of pay could in any case no t undercut the Belgian minimum rates. 
Staff carrying out cross-border transports from Germany to Luxembourg would also be 
guaranteed the minimum rates in force in Luxembourg. The Austrian minimum rates of 
pay would likewise apply to CIT-staff that carry out cash  transport from Slovakia to 
Austria. 
As already mentioned there is a difference between the minimum rates of pay and the 
actual salary. The latter may in clude elements such as extra monthly payments, risk 
allowances and other extra premiums, which may or may not be part of the minimum 
rates of pay under universally applicable co llective agreements. The definition of the 
concept of minimum rates of pay is in princi ple a matter for the Member States, i.e. in 
this context the host Member State. 
The table below attempts to provide an indica tion of the magnitude of other elements of 
the salary paid to CIT-staff carrying out cash transport compared to the basic salary. It 
should be underlined that these figures ma y not be strictly comparable across the 
Member States, so they should be treated as a rough indication. It presents the actual 
gross "base" salary as well as the other wage  elements in ten of the eleven euro-area 
countries with land bord ers to the euro area. 
Table 4. Gross (pre-tax) base salary and other wage elements 
In euro/year if not otherwise indicated BE DE* ES FR LU NL AT PT SK SI 
Base salary 25 374 21 912 14 421 20 000 27 062 22 830 24 928 12 854 9 000 13 000
Seniority 24 months - 400 476 0  
Risk premiums 2 016 2 800 1 068 0  
Other payments/incentives 3009 4 612 4 021 2 255 1 418  
TOTAL 28 383 21 912 21 048 27 221 30 861 22 830 24 928 14 272 9 000 13 000
TOTAL/12 (€/month) 2 365 1 826 1 754 2 268 2 572 1 902 2 077 1 189 750 
Other wage elements in % of base salary 12 0 32 36 14 0 0 11 0 0
  
Source: ESTA, 2010. 
* The figure for Germany is an av erage, since collective agreements are concluded at the level of the 
Länder. 
As can be seen from the tabl e, other wage elements consti tute between 0 % and 14 % of 
the base salary ineightof the ten countries in  the table, whereas in Spain and France they 
EN 9   EN represent around a third of the total salary. Other wage elem ents consequently seem to 
represent a large share of the salary in  at least some euro-area countries.  
The social partners in the sector, i.e. UN I-Europa and CoESS have declared that they 
jointly agree that CIT-staff working abroad should be guaranteed the full  host country 
salary (provided it is highe r than the home country salary ), including all other wage 
elements. However, it seems difficult to justify such a derogation from the principles of the Directive on the posting of work ers, which intends to ensure a minimum protection  
for workers. 
A clarified rule on applicable minimum ra tes of pay in the hos t country, as outlined 
above, could thus, with some possible reserv ations regarding other wage elements, be 
considered as an effective 'minimum protec tion rule' in order to mitigate potential 
negative social effects in the host countr ies of an increase in cross-border cash 
transports. 
6.2.4.  Specific options: Non-harmonised rule s on the carrying of weapons, National 
derogations from authorised transport ty pes and Restrictions  of the scope of 
the common rules 
The potential impact of common rules may be reduced if all relevant rules are not 
harmonised, such as national rules on the carry ing of arms and possi bilities of national 
derogations from authorised transport type s. The envisaged common rules annexed to 
the White Paper and subsequently elaborated  in the expert group with representatives 
from Member States' administrations fore see two main derogations from harmonised 
cross-border rules in order to  take into account real or perceived security concerns: 
A. The CIT security staff must comply with the existing legislation in the Member State 
of origin, in the Member State(s) crossed a nd in the host Member State(s) as regards the 
carrying of weapons and the maximum permitted calibre. 
B. Cross-border cash transport may be ca rried out under a number of different 
authorised types of transport, which are modelled on the existing authorised transport 
types in euro-area Member States. It is, however, possible for each Member State to 
decide that one or several tr ansport types do not apply on its territory ("opt-out") as long 
as they do not opt-out from all of them (for  an overview of the main transport options, 
see section 6.2.5 and Annex 4). 
The consultations with Member States' admi nistrations and other stakeholders have 
shown that these exceptions are seen as neces sary 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. 
In order to examine the extent  of the obstacles to cross- border cash transport that may 
result from national weapons legislation, data on national weapons legislation under the 
different transport types foreseen were co llected via a questionnaire to Member States
2. 
                                                 
2 Questionnaire of 17.7.2009, ref Ares(2009)177142. 
EN 10   EN The national weapons legislation may raise seri ous obstacles to cross-border transports 
in two cases: a) if the carryi ng of weapons is prohibited by  national legislation in one 
country and mandatory in another, and b) if a particular type or calibre of weapon is 
prohibited in one country and mandatory in another. 
The analysis of the replies to the abovemen tioned questionnaire shows, however, that in 
almost all cases, the carrying of weapons is  either mandatory or allowed, which is 
mutually compatible, provided that the type and calibre of the weapon is allowed in both countries (for an overview of the replie s see Annex 4). Potential problems with the 
type and calibre are also  limited to a few cases.  
There are in some cases obstacles for some  transport options between some countries, 
which are not necessarily immediate neighbou rs, such as the Netherlands, where the 
carrying of weapons is prohibited under all transport options, and France or 
Luxembourg where the carrying of weapons is  compulsory for some transport types 
(but not for all). In Belgium, CIT-staff is generally armed, but this  is not a requirement 
by law but a result of collec tive labour agreements. CIT-transports from a country 
where the carrying of weapons is mandatory into a Member State where the carrying of 
weapons in general or the par ticular calibre is prohibited may furthermore make use of 
the possibility foreseen by the envisaged co mmon rules of locking the weapons into a 
strong-box in the vehicle. Once locked, the co ntent of the strong-box is inaccessible to 
the CIT-staff in the vehicle and can only be opened by remote control by the control room of the CIT-company once the vehi cle leaves the c ountry in question. 
Although the different national ru les in the field of weapon s are likely to reduce the 
potential cross-border market to some degr ee, it can be concluded that they do not 
create major problems for cross-border tr ansports. Although some transport options 
would be excluded, transport would still be  possible under other options. Furthermore, 
the envisaged common rules also foresee concre te measures to reduce the impact of the 
different national rules through rules on mu tual approval of equivalent weapons 
training, on facilitation of applicat ions for weapons licences etc.  
As for the possibility for Member States of  opting out from one or several transport 
options for their own territory  (provided they do not auth orise comparable transport 
modalities for domestic transports) it is diffi cult to exactly forecast the extent to which 
this possibility might be used. Based on the discussions in the expert group with 
Member States, it seems that opting out mi ght in some cases concern transports in 
unarmoured vehicles (equipped with IBNS), wh ereas it seems likely that transports with 
fully-armoured vehicles will be possible in practically all cases
3. It seems clear that 
cross-border transport will in all cases be possible under at least one transport option. 
The possibility of national opt-outs therefore does not seem to create major obstacles for 
cross-border transports either , although it is likely to re duce the potential cross-border 
market to some degree. 
The maintaining of national weapons legisl ation and opt-out possibilities from the 
authorised transport types are a result of political compromises on security-related 
issues that are very sensitive to Member St ates. However, the proposal foresees in all 
                                                 
3 Moreover, an opt-out from the transport type with fully-armoured vehicles is not possible for 
point-to-point transports according to the envisaged common rules. 
EN 11   EN cases solutions that enable cross-border transports (str ong-box, standardised transport 
options, recognition of equivale nt weapons training, etc.).  
The potential impact of common rules may more over be reduced if th ere are restrictions 
foreseen for the scope and definition of cr oss-border transports. The envisaged common 
rules annexed to the White Paper and subseque ntly elaborated in the expert group with 
representatives from Member States' administrations foresee the following restrictions of the scope in order to take  into account real or perceive d security threats or avoid 
undue circumvention of national rules: 
C. Cross-border transportation of euro cash sh all be carried out during daytime (defined 
as 06.00–22.00) and the CIT-vehicle shall depart fr om and return to its Member State of 
origin in the same day (an exception is, how ever, foreseen for point -to-point transports 
that may be carried out within a time-slot of  24 hours, provided that night transport of 
cash is already allowed under the national rule s in the Member State(s) in question). 
D. At least the majority of the number of cash deliveries/pick -ups made by a CIT-
vehicle during the day must be carried out on the territory of the host Member State(s) 
in order for the transportation to be consid ered as cross-border (whereas for point-to-
point transports it is enough that the tr ansport takes place between two different 
participating Member States). 
The restriction foreseen under the specific option C is not expe cted to have any 
significant impact on the extent of cross-border cash transp ortation, since it is common 
practice in the sector that the cash transpor ts are carried out during daytime and that the 
vehicle returns to its cash centre of origin at the end of the shift. It will, however, 
provide legal certainty for everybody involved that it wi ll not be possible for CIT-
vehicles to spend the night under non-secure conditions in another country. 
The restriction foreseen under th e specific option D is a result  of the consultations with 
Member States' administrations and is inte nded to avoid that transports that are 
predominantly domestic fall under the cross-border rules just because a few stops are made at the other side of the border. It is likely that this rule will imply a reduction of 
the potential number of cross-border 'retail'  transports. The consequences of this 
restriction on the cross-border business s hould however not be overestimated in the 
sense that, in practice, CIT Companies would not invest ti me and resources to comply 
with the new cross-border rules for just a fe w customers on the other side of the border. 
6.2.5.  Potential impact on the security of the transports 
Due to the nature of the goods  transported, the CIT-market is characterised by important 
inherent risks. The number and type of a ttacks furthermore vary significantly across 
countries. It is crucial that  common rules for cross-border cash transport provide a high 
level of security for both th e staff and the general public.  
The envisaged common rules have therefor e been the subject of an extensive 
consultation process as outlined in Section 1 above, involving the different stakeholders 
in the sector, such as security transporters , banks, retailers, insurers, manufacturers of 
IBNS, the social partners, Mints, Europol , the ECB and the Eurosystem as well as 
representatives of Member States' administ rations (Finance Ministries, Ministries of 
Interior and Justice, Central Banks and police authorities). 
EN 12   EN In order to ensure a high level of security, the envisaged common rules foresee high 
standards in the relevant fiel ds, such as licensing requirements, the repute and integrity 
of CIT-staff including manage rs and members of the board, appropriate training of CIT-
staff before carrying out cash transports in  another country, due respect of national 
weapons legislation, appropriate communicati on with the national police forces, respect 
of national rules to ensure the security of the cash delivery and pick-up locations, 
mutual information between Member States, authorised transport modalities, including 
rules on the number of staff and on the equipment and arm ouring of the CIT-vehicles, 
compulsory bullet-proof vests for the staff when using armoured vehicles, appropriate 
monitoring and penalties in case of  infringements of the rules. 
An additional safeguard is the envisaged rule that the CIT-vehicle shall depart from and 
return to its Member State of origin in the same day (except for point-to-point transports that may be carried out within a time-slot of  24 hours, provided that night transport of 
cash is already allowed under the national rule s in the Member State(s) in question). 
This rule is intended to ensure that it will  not be possible for CIT- vehicles to spend the 
night under non-secure conditions in another country. 
The envisaged common rules foresee a number of different transport types
4 modelled on 
the existing transport types in Member States , with different rules on minimum level of 
staffing, bullet-proof vests, unif orms etc. However, if a Me mber State considers that a 
particular transport type (or types) does not ensure sufficient security on its territory, it 
may decide that this(ese) transport type(s ) will not be authorised on its territory 
(obviously provided it does not allow comparable transpor t types for domestic CIT-
transports). 
Finally, shorter transports overall due to incr eased possibilities of using a more closely 
located cash centre at the other side of the border may imply a reduction of the risk of 
attacks.  
It can be concluded that the envisaged comm on rules provide a high level of security for 
cross-border transports. 
6.3. Sub-options 
6.3.1.  Extending the geographical scope to EU Member States that have not adopted 
the euro. 
The objective of the Commission initiative is to facilitate the free  circulation of the 
single currency within the euro area. It could, however, be inte resting for other EU 
Member States that the envisaged common ru les cover their territory and possibly their 
currency as well.  
Such a possibility could be pa rticularly relevant for countri es that are close to adopting 
the euro in order to adapt in advance to rule s that will in any case come into force upon 
                                                 
4 For transports of banknotes only or banknotes and coins these are: unarmoured vehicle of 
ordinary appearance equipped with IBNS, unarmoured vehicle with clear markings that it is 
equipped with IBNS, cabin-armoured vehicle equipped with IBNS, fully-armoured vehicle not equipped with IBNS, fully-armoured vehicle equipped with IBNS, whereas for coins only the 
envisaged transport types are: unarmoured vehicle and cabin-armoured vehicle. 
EN 13   EN joining the euro area. Meanwhile, it could be  an advantage if euro cash and possibly 
also the still existing national cash could be transported as easily as possible across the 
border. On the other hand, if di fferences in salaries are very  substantial it could also 
give CIT-companies in the (low -cost) country such an adva ntage that it could have a 
substantial negative social imp act in the host country(ies).  
Table 5 below shows the actual salaries paid to CIT-staff in the most relevant non-euro 
area Member States bordering the euro area, co mpared with the actual salaries in the 
neighbouring euro area countries. Salaries may vary according to, for instance, years of 
experience, qualifications a nd age and may in some cases  have changed since the 
information was collected. For these reasons, the information below should be seen as 
indicative.  
Table 5. Actual gross salaries in the CIT-sector in some EU Member States with land 
borders to euro-area Member States.  
Non-euro area 
Member State Actual monthly salary Actual monthly salary in bordering 
euro-area country, or in the case of 
Germany, the bordering Bundesland
(bordering non-euro area country in 
parenthesis)  
Poland 
 472 € 
 
 Czech Republic  
605 € 
 
Hungary 513 € 
 
Exchange rates used (1 € =): 
4,2 PLN, 25,5 CZK, 273 HUF.  Mecklenburg-Vorpommern & 
Brandenburg 1315 € (PL) 
 
Sachsen 1289 € (PL, CZ) 
 
Bayerna2121-2195 € (CZ) 
 
Austria 2077 € (CZ, HU) 
 
a Depending on the location ("Ortsklasse").  
Sources : ESTA, 2010 (for PL, CZ, HU and AT). Bundesvereinigung Deutscher Geld- und Wertdienste e. 
V. (for DE). Actual monthly salary is actual annual salary divided by 12 including possible risk 
allowances, premiums etc. 
N.B. In Germany, collective agreements ar e concluded at the level of each Land. 
Based on the information in the table, salary  differences between the listed euro-area 
countries and neighbouring non-eu ro area countries are very substantial. Salaries are 
over 60 % lower in Poland than in the ne ighbouring German Länder of Mecklenburg-
Vorpommern, Brandenburg and Sachsen. Salaries in the Czech Republic are somewhat higher, but still less than half of those than  in neighbouring S achsen and over 70 % 
lower than in the bordering Land of Bayern. Compared to Aust ria, salaries in the Czech 
Republic are around 70 % lower, whereas sa laries in Hungary are 75 % lower. 
Salary differences of this magnitude may have  a significant negative  social impact in 
the host country. Such an impact could however  be substantially mitigated by the 'safety 
net' outlined in section 6.2.3. The foreign comp any would thus be obliged to pay at least 
the Austrian minimum rates of pay to CIT-wo rkers that are posted there. As regards the 
German Länder referred to above, there is  however currently not any universally 
EN 14   EN applicable (within the meaning of Directiv e 96/71/EC) collective agreement in the CIT-
sector (neither any statutory minimum wage).  
A possibility for other EU Member States to be covered by the comm on rules, for their 
territory and possibly their currency, could have a more significan t impact in Germany 
in the absence of universally applicable  collective agreements there. The legal 
possibility to declare collective agreements  as universally app licable does, however, 
exist5, but it is a matter of German national co mpetence whether to use this possibility.  
Since there will in many cases be an increased need for cross-border euro cash 
transportation in the run-up to the changeover, it would facilitate the preparations of the 
changeover if the common cross-border rules w ould at least apply du ring the run-up to 
the changeover, e.g. as from the date of  the decision to lift the derogation from 
participating in the euro (which is taken around six months in advance of the actual 
changeover). Transport of the still existing national cash could also be included, but 
falls outside the general objectiv e of the present initiative and generally seems to be of 
lesser importance. 
6.3.2.  Extending the scope of goods  carried to other cash. 
Some stakeholders in the banking sector ha ve argued that there is a need also for 
delivery and repatriation of other EU an d EEA currencies, which should not be 
prevented. This would not contribute to achi eving the objective of the initiative, which 
is to facilitate the circulation of euro cash, but could be desirable from a general point of 
view. It may also reduce costs if CIT-vehicles  are able to transport euro cash and other 
cash in the same vehicle. 
Broadening the scope of the common ru les might, however, also complicate the 
adoption process for comparatively little added value.  
It does therefore not seem necessary to genera lly include other currencies than euro cash 
in the scope of the envisaged common rules. 
6.3.3.  Restricting the scope to ' point-to-point' transports 
Restricting the scope to point -to-point transports would ex clude the large majority of 
transports in terms of kilometres driven , hours worked and ca sh points serviced 
(although not in terms of value of euro transported). The po tential economic, and also 
environmental, impact would thus be much  reduced. The strong limitation of the scope 
would, on the other hand, also reduce possible social consequences and could facilitate 
the application of the rules on minimum protection of cross- border workers in Directive 
96/71 on the posting of workers. 
The objective of the present Commission initiative is, however, to facilitate the free 
circulation of euro cash within the euro ar ea and this sub-option would not remove the 
                                                 
5 See updated 'Gesetz über zwingende Arbeitsbedingungen für grenzüberschreitend entsandte und 
für regelmässig im Inland beschäftigte Arbeitnehmer und Arbeitnehmerinnen', Bundesgesetzblatt 
Nr 20, 23.4.2009. 
EN 15   EN major part of the current regulatory obstacles. It therefore only partially meets the stated 
objective. 
6.4. Administrative burden 
Administrative costs are defined as costs incurred in meeting legal obligations to 
provide information on th eir action or production. 
As regards the CIT-companies, the informa tion obligations that are foreseen under the 
envisaged common rules would only concern those companies that are interested in 
carrying out cross-border cash transport and t hus choose to apply fo r a CIT cross-border 
licence. 
The administrative costs for these CIT-comp anies will be limited. They will need to: 
– Inform the granting authority sufficiently in advance about the names of the Member 
States in which they intend to carry out CIT-transport. 
– Provide the host Member State in advance with the names of the persons that may 
carry out such transport on its territory. 
– Depending on national legislation, cash-trans port operations may need to be notified 
to the police in advance. 
The administrative costs of public authorities will in most cases be relatively limited. 
However, those countries that currently do not issue any specific CIT-licence, will need to designate a national authority that verifi es that the conditions for a cross-border 
licence are fulfilled, grants the licence and communicates with the granting authorities of other Member States. National public  authorities will notably need to: 
– Examine and grant applications for cross-border licences. 
– Keep a register of the companies to which they have delivered a licence. 
– Notify those Member States where these companies intend to carry out transport. 
– Inform each other about their specific training requirements. 
– Establish a central national c ontact point to which CIT-sta ff of other Member States 
my submit an application for a weapons licence and inform each other about the 
contact details of th is contact point. 
– Provide for validation of equivalent weapons  training for CIT-staff of other Member 
States. 
– Transmit to the Commission national rules on the role of the national police forces, 
on the security of cash/pick-up locations a nd on IBNS that have been homologated 
by them. 
EN 16   EN 7. COMPARISON OF OPTIONS AND SUMMARY OF IMPACTS (SECOND -ROUND 
ASSESSMENT ) 
The present impact assessment has analysed the economic, environmental, security-
related and social impact of the retained broad option 3: Common rules for professional 
cross-border transport of  euro cash by road , together with four sp ecific options in order 
to take into account security-r elated or other sensitive issues, in comparison with the 
baseline no-change option. In addition three general sub-options have been analysed. 
The results are summed up in table 6 at the ne xt page on the basis of the same criteria as 
in the first-round assessment (Section 5): 
• Effectiveness: The extent to which options achiev e the objectives of the proposal;  
• Efficiency:  The extent to which objectives can  be achieved for a given level of 
resources/at least cost, notably administ rative costs for all pa rties involved (cost-
effectiveness); 
• Coherence:  The extent to which options ar e coherent with the overarching 
objectives of EU policy. 
• Proportionality: Community action should not go beyond what is necessary to 
achieve the objectives set. 
EN 17   EN The table first compares the retained broad option 3 with the base -line option 1, without 
taking into account possible derogations and re strictions to the scope according to the 
specific options A-D, i.e. a 'full application'  of common cross-border rules. The effect of 
each of the four specific opti ons compared to a full applica tion of the broad option 3 is 
then summarised. The broad optio n 3 including the effect of th e four specific options is 
thereafter compared with the baseline and fi nally the effects of each of the sub-options 
are compared with the broad option 3. 
Table 6. Comparison of the retained broad op tion with the baselin e and effect of the 
related specific options and the general sub- options vis-à-vis the retained broad option. 
(0 no change/baseline, + positive, (+ ) some improvement, - negative) 
Main options: Effectiveness 
in reaching 
objectives Efficiency 
in reaching 
objectives Coherence 
with overarching EU 
objectives Proportionality 
1. No change 0 0 0 0 
3. Common cross-
border rules (full 
application)  ++ ++ ++ ++ 
A. Derogation for 
national weapons 
legislation Reduction Reduction Reduction Neutral 
B. Transport type 
opt-out possibility Reduction Reduction Reduction Neutral 
C. One-day and 
day-time transport Neutral Neutral Neutral Neutral 
D. Majority of 
stops abroad Reduction Reduction Reduction Neutral 
3. Common cross-
border rules 
(with specific 
options A-D)  +(+) +(+) +(+) ++ 
Sub-options:     
a) Extension of the 
scope to MS 
outside the euro 
area Some 
improvement Some 
improvement Improvement Neutral 
b) Extend the 
scope to other cash Neutral Some 
improvement Improvement Neutral 
c) Restricting the 
scope to point-to-
point transports Reduction Reduction Reduction Neutral 
EN 18   EN The analysis has shown that the introduction of common EU rules applicable to cross-
border transports as outlined in the present impact assess ment (Option 3) would be 
effective in reaching the stated objective of f acilitating the free circul ation of euro cash 
within the euro area by removing obstacles to the professional transp ort of euro cash by 
road between euro-area Member States, while  ensuring that the transports take place 
under conditions that provide a high level of  security for the CIT-staff and for the 
general public. The potential increase in cross-bo rder transports will to some extent be 
reduced by necessary exceptions and derogations from and rest rictions to the scope of 
such rules (specific options A-D).  
The common rules would furthermore be an efficient way of reaching the objective, 
since they focus exclusively on cross-border transports and do not attempt to harmonise 
domestic CIT-transports. On the other hand, th is implies that two sets of CIT-rules will 
co-exist in the (border regions  of the) national territory of  the concerned Member States. 
Common cross-border rules would also well m eet the criterion of  proportionality. The 
EU rules would remove national regulatory obs tacles to cross-borde r transport of euro 
cash, while the national regulation of purely dom estic transports would remain in force. 
The facilitation of cross-border cash tran sports is also likely to produce some 
environmental benefits, due to shorter tran sports overall, although these benefits are 
expected to be of a relatively limited magnitude.  
On the basis of extensive consultations with stakehol ders and Member States' 
administrations, the common rules together with the specific options foresee high standards in the relevant security-related fields, the preservation of national rules in sensitive areas such as weapons legislati on and possibilities for Member States of 
opting out from specific transport types if th ey do not consider them compatible with 
the national environment. These common rules are therefore expected  to provide a high 
level of security for cross-border transports. 
A significant increase in cross-border cash transports may also produce negative effects 
on wage levels and/or employment in the CIT- sector in a given host country, if there are 
significant wage differences compared to neighb ouring countries. In view of the specific 
nature of CIT transport services, notably th e frequent and short-term nature of the 
potential work periods abroad, a clarificati on of the rules on the minimum protection of 
workers foreseen by Directive 96/71 on the posting of workers should therefore be 
foreseen. The analysis shows that such a rule could be an effective safety-net in order to 
mitigate potential negative social effects of an increase in cross-border cash transports. 
As for the different sub-options, the extensi on of the scope of the common rules to EU 
Member States outside the euro area that ar e close to adopting the euro would to some 
degree contribute to the free circulation of eu ro cash within the euro area by allowing 
countries that are close to adopt ing the euro to adapt in adva nce to rules that will come 
into force upon joining the euro. It would above  all facilitate the changeover to the euro 
and furthermore be coherent with overarchi ng EU objectives such as realising the 
potential of the single market and crea ting a more competitive and connected economy. 
Extending the scope to other cas h does not contribute to th e stated objective of the 
initiative but fits into the overarching EU objectives and may increase efficiency by reducing costs. It might, however, also complicate the adoption process of common 
EN 19   EN rules for relatively little added value. Restri cting the scope to point -to-point transports 
would significantly reduce the benefit of the common rules and only partially allow 
meeting the stated objective of the initiative. 
The present impact assessment therefore recommends Option 3 – A set of common 
rules that would be valid in all euro-a rea Member States but limited to cross-
border transports ('common cross-border rules'), together with the specific 
derogations and restrictions to the scope foreseen under the specific options A-D. 
This policy option would fulfil the objective of facilitating the free circulation of 
euro cash within the euro area, and would do so in the most ef ficient way relative 
to the other broad policy options, while en suring that the transports take place 
under conditions that provide a high level of  security for the CIT-staff and for the 
general public. It is furthermore recomme nded that Option 3 is completed with 
sub-option a), i.e. the extension of the common rules to the t erritory of other EU 
Member States that are about to introduce the euro. 
EN 20   EN 8. MONITORING AND EVALUATION  
In order to monitor the implementation of common cross-border rules and possibly 
propose measures to improve th e functioning of the system it seems appropriate to set 
up 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 which woul d help the Commission in assessing the 
effectiveness of the new rules. The Comm ittee should also consult the relevant 
stakeholders, including the social partners , and take their view s into account as 
appropriate. 
A formal review should be foreseen two years after the entry into force of the common 
rules and the Commission should prepare a report on the functioning of the new 
framework. The review should also include c onsultations of the stakeholders in the 
sector, including the social partners. Based on the result of  the review, the Commission 
could make a proposal to revise the Regul ation. The review should thereafter be 
repeated every five years. 
For this purpose, specific indicators shou ld be identified which match with the 
operational objectives pursued by the Regulation. These indicators will serve to assess 
the performance of the new framework. 
The following table gives an indi cation of possible indicators: 
Specific objectives Indicators 
Number of CIT cross-border licenses 
granted/withdrawn 
Number of cross-border cash transports Facilitate the free circ ulation of the euro 
between euro-area Member States 
Number of opt-outs by Member States 
from the standard transport types  
Cross-border transports to take place under 
conditions that provide a high level of 
security for the CIT-staff and for the 
general public Number of attacks on cross-border CIT 
transports and related injuries or deaths, in 
relation to the number of cross-border cash 
transports and compared to domestic 
transports 
Social minimum protection to be observed 
in the host country for the staff in the CIT-
sector in line with the existing principles 
in EU legislation  Evolution of salaries and other terms and 
conditions of employment in Member 
States where significan t numbers of cross-
border cash transports take place 
As regards enforcement of the common rules,  public authorities shall ensure that the 
cross-border rules are resp ected, including via random inspections. Detailed rules on 
penalties are also foreseen, ranging from warning, fine, to suspension and ultimately 
withdrawal of the cross-border licence. The extent of enforcement work will however 
depend on the extent of cross-border operations.