White paper on professional cross border transportation of euro cash by road between Member States in the euro area
Date: 2009-05-18
Institutions: European Commission
Subjects: EU Member State, EU action, European currency, common transport policy, cross-border transport

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 18.05.2009 
COM(2009) 214 final 

WHITE PAPER 

on 

PROFESSIONAL CROSS-BORDER TRANSPORTATION OF EURO CASH BY 
ROAD BETWEEN MEMBER STATES IN THE EURO AREA 

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1. 

INTRODUCTION 

The  physical  euro  was  introduced  in  2002,  but  due  to  strong  differences  between  national 
legislations  it  is  in  practice  very  difficult  to  transport  euro  cash  by  road  between  Member 
States that have adopted the euro (hereinafter 'participating Member States') on a professional 
basis  and  very  little  cross-border  land  transportation  therefore  currently  takes  place.  The 
differences  between  national  legislations  concern  a  wide  range  of  issues  such  as  the 
possession  and  carrying  of  firearms  by  the  security  staff,  training  requirements,  authorised 
transport modalities, armouring and equipment of the security vehicles, the use of intelligent 
banknote neutralisation systems (IBNS), number of staff in the security vehicles, information 
towards  the  police,  licence  rules  and  related  penalties.  Cross-border  transports  may  be 
arranged  on  the  basis  of  ad-hoc  authorisations  from  the  Member  States  of  destination,  but 
even  disregarding  the  administrative  proceedings  involved,  this  still  involves  the  need  to 
comply with two or more different complex sets of national rules. 

The  cash-in-transit  (CIT)  market  is  therefore  currently  organised  along  national  lines.  It  is, 
however, inherent in the logic of the single currency that euro banknotes and coins should be 
able  to  circulate  and  be  transported  as  freely  as  possible  within  the  euro  area.  Facilitating 
cross-border cash transportation is also a natural complement to the European Central Bank's 
Roadmap  for  more  convergence  of  National  Central  Bank  (NCB)  cash  services  and  the 
creation of a Single Euro Cash Area for professional cash handlers. One important element of 
that  Roadmap  is  the  so-called  Remote  access  to  NCB  cash  services,  whereby  a  credit 
institution in one participating Member State may use the cash services of a Central Bank in 
another  participating  Member  State.  That  measure  was  implemented  in  June  2007  but  its 
potential  cannot  be  fully  exploited  until  it  is  actually  possible  to  easily  transport  the  cash 
across the borders. The banks, the large retail sector and other professional cash handlers need 
to  source  and  deliver  their  cash  in  the  most  efficient  manner,  unconstrained  by  national 
borders.  

Due  to  the  nature  of  the  goods  transported,  the  CIT-sector  is  at  the  same  time  exposed  to 
serious  security  threats  and  the  nature  and  level  of  the  risks  may  be  very  different  between 
Member States. It is therefore of paramount importance that cross-border cash transports take 
place  under  conditions  that  ensure  a  high  level  of  protection  for  the  CIT-staff  and  for  the 
general public. 

The establishment of common rules that generally allow cross-border cash transports by road 
between participating Member States, while providing a high level of safety for the CIT-staff, 
would  open  up  the  possibility  for  more  efficient  cash  transport  routes  in  border  regions. 
Commercial  banks  would  thus  be  able  to  use  the  cash  services  of  the  nearest  Central  Bank 
branch  or  CIT  cash  center,  whether  in  their  own  Member  State  or  not.  Retailers,  vending 
machine operators and other professional cash handlers would likewise be able to receive or 
deliver cash from/to the nearest cash center, independently of national borders. Finally, CIT-
companies carrying out transportation in border regions would be able to plan their transport 
routes  and  other  cash  logistics  in  a  more  efficient  manner.  In  general,  more  efficient  cash 
transportation will produce a benefit for the economy as a whole. 

The  European  Central  Bank,  the  banking  sector  and  the  large  retail  sector  have  repeatedly 
called for the  launch of an initiative aimed at lifting  the obstacles  to the  professional cross-
border transportation by road of euro cash in Europe. 

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Against this background, the Commission therefore initiated consultations in May 2008 with a 
view to preparing draft common rules to facilitate the cross-border transportation of euro cash 
by road. 

This initiative reflects the position of the Commission as regards a possible harmonisation of 
the transport of cash mentioned in Article 38 b of the Directive 2006/123/EC of the European 
Parliament and of the Council of 12 December 2006 on services in the internal market. 

2. 

COMMISSION  INITIATIVE  TO  FACILITATE  CROSS-BORDER  TRANSPORTATION  OF 
EURO CASH AND INITIAL CONSULTATION OF STAKEHOLDERS 

As a first step and in order to build on the expertise and input of all interested parties in the 
sector,  a  Working  Group  chaired  by  the  Commission  and  consisting  of  the  European 
organisations of all the major stake holders1 was set up in the first half of 2008. The Working 
Group  held  three  full-day  meetings  between  July  and  December  2008  and  discussed  all 
relevant  issues,  such  as  the  scope  of  the  possible  future  common  rules,  differences  between 
national legislations  and  possibilities of harmonised  cross-border rules in the  different areas 
mentioned at the beginning of Section 1. 

As regards the legal possibilities of facilitating cross-border cash transport, three main options 
were considered: 

•  A full harmonisation of the regulation of CIT-transport in the concerned Member States. 

•  A system where authorisation in one Member State would be valid in all Member States 

('mutual recognition'). 

•  A  set  of  common  rules  that  would  be  valid  in  all  Member  States,  without  prejudice  to 
national  rules  for  certain  aspects  explicitly  indicated  in  the  text.  Contrary  to  a  full 
harmonisation, the common rules would only apply to cross-border transportation. 

Since  there  are  large  existing  differences  between  national  rules  and  in  risk  levels  between 
Member States, it was considered to be extremely difficult to reach agreement on the content 
of a full harmonisation of the rules governing CIT-transport or on an across-the-board mutual 
recognition  of  national  rules.  The  latter  option  could  furthermore  lead  to  cash  transports 
taking place under rules that provide or are perceived to provide inadequate protection of the 
staff and/or the general public. There was therefore a clear preference in the Working Group 
for a set of common rules applying to cross-border transports, which would exist in parallel to 
the existing national rules for domestic cash transports. 

Within the framework of a set of common rules applying to cross-border cash transports by 
road, the Working Group discussed the following main policy options regarding the scope of 
application of possible common rules: 

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The following organisations were represented: CEA (European insurance and reinsurance federation), 
CoESS  (Confederation  of  European  Security  Services),  EBF  (European  Banking  Federation),  the 
Eurosystem,  EPC  (European  Payments  Council),  ESTA  (European  Security  Transport  Association), 
EURICPA  (European  Intelligent  Cash  Protection  Association),  EuroCommerce,  Europol  (European 
Police  Office),  MDWG  (Mint  Directors  Working  Group)  and  UNI-Europa  (Union  Network 
International – Europa). 

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•  The geographical scope. This could include the whole EU-27 or be limited to the euro area. 

•  The  type  of  goods  carried.  The  goods  could  include  not  only  euro  cash,  but  also  other 

currencies and other kinds of valuables. 

•  The definition of cross-border transportation. Cross-border transportation could be limited 
to  only  point-to-point  transports  or  include  also  operations  in  the  home  country  prior  to 
and/or operations in the host country consecutive to the international operation (the latter 
operations are generally referred to as 'cabotage'). 

There were different views in the Working Group on all these issues. 

The main purpose of possible common rules is to facilitate the free circulation of the single 
currency  within  the  euro  area.  This  does  not  exclude,  however,  that  the  territory  of  other 
Member  States  is  included  as  well.  Independently  of  the  geographical  scope,  it  could 
furthermore  be  envisaged  to  include  the  currencies  of  other  Member  States,  of  non-EU 
countries  as  well  as  other  kinds  of  valuables  (such  as  jewellery,  gold,  pieces  of  art  and 
valuable  documents).  Extending  the  scope  to  non-participating  Member  States  and  other 
goods  could,  however,  risk  severely  delaying  or  even  preventing  the  adoption  of  common 
rules by deflecting the discussion from the main concerns. 

Cross-border transportation can be interpreted in a narrow sense to mean the transport of cash 
from a secured point in country A to a secured point in country B, without any intermediate 
stops  ('point-to-point').  Point-to-point  would  mean  that  individual  cash  centres  and  other 
secured points can be serviced across the border under the common rules, but would exclude 
bank  branches,  ATMs  and  retailers  (unless  they  are  equipped  with  a  secured  area  for  the 
unloading/loading  of  the  vehicle).  Only  one  operation  at  a  time  from  one  secured  point  to 
another secured point would be possible. 

However, point-to-point transports correspond to only one part of the cash transports regularly 
carried out by CIT-companies. A wider scope would include also some transport operations 
prior to and consecutive to the cross-border leg of the journey. This would make it possible to 
organise  cross-border  transport  routes  in  the  same  logistically  optimal  way  as  domestic 
transport routes, by servicing several points along the way, including bank branches, ATMs as 
well as retailers. With a view to facilitating the free circulation of euro cash across national 
borders  it  is  therefore  suggested  that  it  should  be  possible,  beyond  the  main  cross-border 
operation, to carry out multi-stop transport operations in the home country as well as in the 
host  country/countries.  As  explained  in  section  3.2  below,  the  combined  duration  of  the 
operations in the home as well as the host country/countries should be limited to one day. 

Under common cross-border rules, the cash transport services would fall under different legal 
systems,  concerning  in  particular  the  compliance  with  labour  law  principles,  applicable 
collective  agreements  or  other  law  which  refers  to  social  and/or  safety  aspects.  This  could 
lead to significant practical problems in establishing which wage and other social conditions 
apply, especially if a security vehicle operates across more than two countries. 

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In  this  context  it  will  be  crucial  to  provide  clarity  on  the  application  of  Directive  96/71 
concerning  the  posting  of  workers  in  the  framework  of  the  provision  of  services2  to  cross-
border cash transports. 

This Directive aims to reconcile the exercise of companies' fundamental freedom to provide 
cross-border services under Article 49 of the EC Treaty, on the one hand, with the appropriate 
protection of the rights of workers temporarily posted abroad to provide them, on the other. It 
thus  endeavours  to  strike  a  balance  between  the  economic  freedoms  established  by  the  EC 
Treaty  and  employees'  rights  during  their  period  of  posting.  It  identifies  therefore  the 
mandatory  rules  of  general  interest  at  Community  level  that  must  be  applied  to  posted 
workers  in  the  host  country,  and  establishes  a  hard  core  of  clearly  defined  terms  and 
conditions  of  work  and  employment  for  minimum  protection  of  workers  that  must  be 
complied  with  by  the  service  provider  in  the  host  country.  Depending  on  the  particular 
circumstances under which the cross-border transport operations are carried out, in line with 
the definitions included in its Article 1(3), the Directive may be applicable to the cross-border 
transport operations that are the subject of the present White Paper. 

However, it must be recognized that the particular short-term nature of the posting situation in 
the  case  of  cross-border  cash  transport  creates  difficulties  for  the  practical  application  and 
enforcement of the Directive. For instance, the application of the Directive could potentially 
require  that  employers  in  the  CIT-sector  measure  the  time  which  their  staffs  spend  in  each 
country in order to calculate the applicable minimum rates pro rata. 

Hence,  the  practical  application  of  Directive  96/71  in  this  field  will  need  to  be  carefully 
examined with the Member States, other relevant experts3 and the social partners before any 
common rules on cross-border cash transport can be formally adopted. In particular, it would 
be  important  to  ensure  that  the  application  of  the  Community  acquis  or  national  legislation 
does not impose a disproportionate and unnecessary administrative burden on the operators, 
which could in practice have the effect of seriously impeding the possibility of carrying out 
cross-border  operations.  The  clarification  of  these  issues  will  be  an  integral  part  of  the 
assessment of the social impact of the policy options. 

On  this  basis,  the  Commission  is  hereby  launching  a  broad-based  consultation  process  on 
some  envisaged  common  rules,  which  are  annexed  to  this  White  Paper.  The  Commission 
stresses  the  tentative  nature  of  these  envisaged  rules.  The  intention  is  to  facilitate  the 
formulation  of  focused  comments  from  all  interested  parties  by  presenting  already  at  this 
stage  the  main  elements  of  possible  common  rules.  These  envisaged  rules  are  without 
prejudice to the proposal which might be made by the Commission at a later stage.  

All  interested  parties  are  invited  to  submit  their  comments  by  30  June  2009  to  the  address 
indicated at the bottom of section 4. 

2 
3 

OJ L 18, 21.1.1997, p. 1–6. 
Commission Decision 2009/17/EC established a Committee of experts on posting of workers (OJ L 8, 
13.1.2009, p. 26-28). 

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3. 

KEY FEATURES OF POSSIBLE COMMON RULES 

The  envisaged  common  rules  would  apply  to  the  cross-border  transportation  of  euro  cash 
between  participating  Member  States.  Cash  transports  that  take  place  exclusively  within  a 
Member State would therefore not be affected. 

In  order  to  focus  on  the  essential  issue,  namely  the  free  circulation  of  euro  cash  within  the 
euro  area,  Member  States  that  have  not  adopted  the  euro  and  their  currencies  would  not  be 
included  in  the  scope  of  the  common  rules.  However,  the  possibility  of  including  non-
participating  Member  States  and  currencies  via  an  opt-in  clause  should  be  further 
investigated. 

Finally,  due  to  their  specific  character,  it  is  suggested  that  high-value  transports  of  euro 
banknotes  and  coins  between  euro-area  Central  Banks  should  not  be  covered  by  the  text, 
provided that they are escorted by the military and/or the police. 

3.1. 

Legal basis 

It is envisaged to base the possible common rules on Article 123(4) of the Treaty establishing 
the European Community, since they appear necessary in order to facilitate the use of the euro 
as  the  single  currency.  This  implies  adoption  by  a  qualified  majority  of  the  participating 
Member States, after consultation of the European Central Bank.  It is also envisaged to use 
the instrument of a Regulation. 

3.2. 

Intraday and daytime transport 

Because  of  the  specific  characteristics  of  the  CIT-activity  and  with  a  view  to  taking  into 
account  the  difficulties  in  organising  safely  multi-day  cash  deliveries,  the  security  vehicle 
crossing the border should start from and return to its Member State of origin in the same day 
and  the  whole  transport  should  take  place  during  daytime  (daytime  is  suggested  as  6.00–
22.00).  However,  night  transport  of  cash  could  take  place,  if  it  is  already  allowed  under 
national  rules  in  the  Member  States  where  the transport  is  taking  place.  The  pick-up  and/or 
delivery of cash within the home Member State prior to the cross-border leg of the journey or 
within  a  host  Member  State  consecutive  to  the  cross-border  leg  would  be  possible,  but  the 
security  vehicle  should  return  to  its  Member  State  of  origin  in  the  same  day  (or  within  24 
hours, if night transport is allowed). 

3.3. 

CIT cross-border licence 

The national inspection authorities should be able to verify that a security vehicle fulfils the 
conditions to carry out cash transport on its territory. A company wishing to carry out cross-
border transportation of euro cash by road should therefore be required to apply for a specific 
CIT  cross-border  licence  from  the  competent  authorities  in  its  Member  State  of  origin.  The 
original or a certified copy of the licence should always accompany the vehicle. 

The exact characteristics of the licence document should be defined and it should be valid for 
a  limited  period  (three  years  is  suggested).  In  order  to  qualify  for  the  licence,  the  applicant 
company should comply with the envisaged common rules, with other applicable Community 
legislation or, where explicitly provided for, with the national CIT-legislation in force. Such 
reference  to  (possible)  national  legislation  would  be  provided  in  two  cases:  i)  advance 
notification  of  national  police  forces,  and  ii)  procedures  for  handling  cash  outside  the  CIT-
vehicle. The first case concerns the competence and organisation of the national police forces 

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where there does not seem to be any compelling reason to harmonise practices. The second 
case concerns occasions when the CIT security staff may come into more direct contact with 
the  general  public  and  thus  expose  them  to  the  inherent  dangers  of  the  trade.  It  therefore 
seems appropriate that any national rules are respected. 

The  company  should,  however,  first  of  all  be  approved  to  carry  out  CIT-transport  by  its 
Member State of origin. If the Member State does not have any specific approval procedure in 
place  for  CIT-companies,  the  company  should  be  able  to  provide  evidence  that  it  has  been 
carrying  out  regular  cash  transports  for  a  certain  specified  time  (12  months  are  suggested) 
with no infringements of the existing national legislation. This rule is intended to ensure that 
CIT-companies engaging in cross-border transport have sufficient prior experience to be able 
to safely carry out cash transport also on another Member State's territory. 

In  order  to  make  sure  that  Member  States  are  sufficiently  informed  about  companies 
established in other Member States wishing to carry out cash transport on their territory, it is 
furthermore  foreseen  that  Member  States  should  exchange  information  on  cross-border 
licences issued and on any decisions to suspend or withdraw a licence and should inform each 
other  in  advance  about  the  names  of  the  companies  that  intend  to  carry  out  transport  on 
another Member State's territory.  

3.4. 

Permitted types of cash transportation 

The authorised CIT transport types and related conditions (rules on armouring of vehicles, use 
of intelligent banknote neutralisation systems, carrying of weapons, number of crew members 
etc.)  vary  considerably  between  Member  States.  This  is  notably  the  case  as  regards  the 
possession and carrying of weapons. In some Member States it is prohibited for CIT security 
staff  to  carry  weapons,  whereas  in  other  Member  States  it  is  mandatory  and  in  others,  it  is 
neither prohibited nor mandatory but allowed. In view of the existing differences, it does not 
seem  realistic  to  propose  one  type  of  transport  that  would  fit  everyone.  In  particular,  the 
national rules on whether CIT security staff shall not/may/must carry weapons should not be 
questioned. 

Based  on  current  practices  in  Member  States,  it  is  envisaged  that  there  should  be  four 
authorised types of transportation, which should each provide a high level of security for the 
staff and the general public. There are three different options for banknotes (or banknotes in 
combination  with  coins),  whilst  the  last  transport  type  concerns  the  exclusive  transport  of 
coins.  Operators  should  be  free  to  choose  the  type  of  transport  they  prefer  among  the  three 
options  available  for  banknotes.  However,  it  is  suggested  that,  after  notification  to  the 
European  Commission,  a  Member  State  should  be  able  to  decide  that  the  option  of 
unarmoured or cabin-armoured vehicle equipped with IBNS (option a) below) does not apply 
to its territory, provided that it does not allow comparable transport modalities for domestic 
CIT-transports.  It  is  envisaged  that  there  should  be  at  least  three  CIT  security  staff 
accompanying the vehicle unless the cash is protected by end-to-end IBNS or if only coins are 
transported. Since in the first case, the cash is protected by the IBNS-technology, and in the 
second case, coins are less attractive to steal, it is envisaged that under those options (options 
a), c) and d) below), the minimum required number of CIT security staff should be reduced to 
two.  

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a) Transportation of banknotes in an unarmoured or cabin-armoured vehicle equipped with 
an end-to-end intelligent banknote neutralisation system (IBNS) 

Under this option, the vehicle should either be of ordinary appearance (that is to say not bear 
any signs that it belongs to a CIT-company or that it is used for cash transport purposes) or 
have its cabin armoured and bear very clear markings which indicate that it is equipped with 
end-to-end  IBNS.  The  IBNS  should  comply  with  criteria  to  be  established  (which  should 
include,  inter  alia,  the  requirement  to  be  homologated  in  at  least  one  participating  Member 
State).  

b) Transportation of banknotes in a fully-armoured vehicle not equipped with IBNS 

Under  this  option,  the  vehicle  should  be  whole-body  armoured  to  withstand  gunfire  from 
firearms. The CIT security staff should wear bulletproof vests and comply with the existing 
rules in the Member States where the transport is taking place as regards whether they shall 
not/may/must carry weapons and the maximum permitted calibre. 

As  regards  the  possession  and  carrying  of  weapons,  two  mutually  exclusive  alternatives  are 
put  forward  for  further  discussion;  i)  The  creation  of  a  special  “European  firearms  pass  for 
CIT  security  staff”,  to  be  specified.  The  pass  would  be  issued  by  the  Member  State  that 
granted the cross-border CIT-licence and could only be issued to CIT-staff who already holds 
a  national  firearms  licence  and  are  employed  by  a  company  holding  a  cross-border  CIT-
licence, or ii) CIT-staff should be required to apply for a firearms licence from the national 
authorities  in  the  Member  States  concerned  (provided  they  allow  CIT  security  staff  to  be 
armed). 

Furthermore, and in order to respect the existing national legislation, a procedure needs to be 
foreseen for cases where the security vehicle passes from a Member State where firearms are 
compulsory into a Member State where firearms are prohibited. In this case, the arms should 
be locked up in a strong-box inside the vehicle before entering the territory of the latter and 
remain inaccessible to the CIT security staff until the vehicle enters the territory of a Member 
State  that  allows  CIT  security  staff  to  be  armed.  Once  locked,  it  should  only  be  possible  to 
open the firearms strong-box by remote intervention by the vehicle’s control centre. 

c) Transportation of banknotes in a fully-armoured vehicle equipped with IBNS 

This option combines the protective measures under options a) and b), that is to say both end-
to-end IBNS as well as whole-body armouring of the vehicle. The same rules as under option 
b) should apply, but in addition the vehicle should also be equipped with IBNS in accordance 
with option a) and bear very clear markings indicating this. 

d) Transportation of coins only 

This is the only type of transportation that should apply to cross-border transportation of coins 
only.  Coins  are  heavy  relative  to  their  value  and  therefore  more  cumbersome  and  less 
attractive to steal. This can also be seen from the fact that there have been almost no attacks 
on  vehicles  transporting  exclusively  coins  in  the  Community  in  the  past.  It  is  therefore 
envisaged that the vehicle should bear very clear markings indicating that it is carrying only 
coins. In order to protect the CIT security staff, the cabin of the vehicle should be armoured. It 
should be further discussed whether the CIT security staff should be unarmed or not. 

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3.5. 

Penalties 

It is crucial to ensure that the provisions are enforced and it is therefore essential to foresee 
adequate penalties in case the provisions are not respected. At the same time it is important 
that the penalty is proportionate to the seriousness of the infringement. 

It is therefore envisaged that where there has been an infringement of the terms or conditions 
of  the  CIT  cross-border  licence,  the  granting  authority  should  be  able  to  decide  to  send  a 
warning, to suspend the licence during a limited time or to withdraw the licence completely. 
In order to provide a safety net for the host Member State, it is furthermore suggested that the 
Member State crossed or where the service is rendered should have the right to temporarily 
suspend the licence if there is a serious breach of the rules, that is to say relating to the respect 
of  the  minimum  number  of  CIT  security  staff  or  the  rules  related  to  firearms,  pending  a 
decision  by  the  granting  authority  of  the  Member  State  of  origin.  It  is  finally  foreseen  that 
Member States should inform each other about any infringements and related penalties. 

3.6. 

Other provisions 

In order to deal with serious security threats a special clause on emergency security measures 
would also be foreseen. This could for example concern a number of violent attacks that may 
call for temporary police escorts of all CIT-transports in the territory of a Member State. In 
order to avoid a differentiated treatment of foreign versus domestic operators, such emergency 
measures  should  concern  all  CIT-transports  in  the  Member  State  concerned.  They  should 
furthermore  be  limited  in  time  and  should  be  notified  to  the  Commission.  A  formal  prior 
consent of the Commission should be required for any extension of emergency measures. 

A  number  of  minimum  requirements  for  CIT  security  staff  are  furthermore  envisaged,  as 
regards clean criminal record, physical and mental health, training and language skills. 

The common rules should be without prejudice to the application of existing EU legislation, 
notably in the social and transport fields. 

Finally, it is suggested to carry out a review of the implementation of the common rules two 
years after their entry into force, and subsequently on a regular basis.  

4. 

NEXT STEPS 

The annexed set of envisaged rules will be discussed with Member States' administrations in 
an ad-hoc Expert Group set up for this purpose. The results of these discussions and the input 
received from stakeholders and other interested parties will feed into the impact assessment of 
possible common rules, including the assessment of the different options discussed in Section 
2 above, that the Commission will carry out prior to the adoption of any formal proposal. 

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The Commission invites comments on this White Paper. They may be sent, by 30 June 2009, 
either by e-mail to: 
ECFIN-E3@ec.europa.eu 
or by post to: 
European Commission 
Directorate-General for Economic and Financial Affairs, Unit E.3 

Economic  aspects  of 
B-1049 Brussels. 

regulatory  policy,  Sector  euro  cash  and 

legal 

issues 

Annex:  Envisaged  common  rules  for  the  cross-border  transportation  of  euro  cash  by  road 
between Member States in the euro area. 

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ANNEX 

Envisaged common rules for the cross-border transportation of euro cash by road 
between Member States in the euro area 

The term [Regulation] is used for internal references in the text below, since it is envisaged to 
use the instrument of a Regulation for possible future common rules.  

SECTION  1.  COMMON  RULES  THAT  WOULD  GOVERN  ALL  CROSS-BORDER 
TRANSPORTATION OF EURO CASH BY ROAD 

A. Scope 

Cross-border  transportation  of  euro  cash  under  the  provisions  of  this  [Regulation]  shall  be 
carried out during daytime and the security vehicle shall depart from and return to its country 
of origin in the same day. 

Point-to-point transports may however be carried out within a time-slot of 24 hours, provided 
that  night  transport  of  cash  is  already  allowed  under  national  rules  in  the  Member  State  of 
origin, in the Member States crossed and in the Member(s) State(s) where the service is being 
provided. 

Transports of euro banknotes and coins with a face value exceeding EUR 15 million that are 
(i) carried out between Central Banks of participating Member States and (ii) escorted by the 
military and/or the police shall be excluded from the scope of this [Regulation]. 

B. CIT cross-border licence 

(a) A company wishing to undertake the cross-border transportation of euro cash by road shall 
apply  for  a  CIT  cross-border  licence  from  the  competent  authorities  in  its  Member  State  of 
origin.  

(b)  The  CIT  cross-border  licence  shall  be  granted  for  a  period  of  [three]  years  by  the 
competent  national  authorities  to  companies  located  in  their  territory,  provided  that  the 
following conditions are met: 

- The applicant company must be approved to carry out CIT-transport by the Member State to 
which the application for a CIT cross-border licence is submitted. If the Member State does 
not have a specific approval procedure for CIT-companies going beyond the general rules for 
the security or transport sector, the company must be able to provide evidence that it has had 
regular business transporting cash for at least [twelve] months prior to the application with no 
infringements of the existing national legislation governing such activities. Its managers and 
members of the board shall, moreover, not have relevant offences in their criminal record. 

-  The  applicant  company,  the  staff  employed,  the vehicles  used  and  the  security  procedures 
implemented for the cross-border transportation of euro cash must comply with the rules laid 
down by this [Regulation] and by other applicable EU legislation or, where explicitly referred 
to  by  this  [Regulation],  with  the  national  legislation  in  force  specifically  relating  to  the 
transport of cash.  

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(c)  The  CIT  cross-border  licence  shall  be  drawn  up  in  accordance  with  the  model  [to  be 
defined].  Vehicles  engaged  in  professional  cross-border  transportation  of  euro  cash  by  road 
must, at all times, be able to show the inspection authorities the original or a certified copy of 
a valid licence.  

(d)  Member  States  shall  control  regularly  that  the  rules  laid  down  in  the  [Regulation]  are 
respected,  including  via  random  controls  without  prior  notification  to  the  company.  These 
controls shall take place at least once a year. 

C. CIT security staff 

(a) CIT security staff shall satisfy the following requirements: 

(i) they must not have relevant offenses in their criminal record, 

(ii)  they  shall  have  a  medical  certificate  certifying  that  their  physical  and  mental  health  is 
adequate for the task to perform, 

(iii)  they  shall  have  successfully  followed  at  least  [200 hours]  of  ad  hoc  initial  training,  not 
including any training on the use of firearms. 

The ad hoc initial training referred to in point (iii) shall cover at least [the cross border CIT-
procedures, the relevant CIT-legislations, the rules of behaviour in case of attack, the use of 
the CIT-equipments and the team working rules]. Regular training in these fields shall also be 
required. 

(b)  At  least  one  member  of  the  CIT  security  staff  in  the  vehicle  shall  be  able  to  provide 
evidence of at least A2-level language skills in the official language(s) used in the Member 
State(s) crossed and the Member State(s) in which the service is being provided.  

(c) If none of the members of the CIT security staff are proficient in the official language(s) 
used in of the Member State(s) crossed or in the Member State(s) in which the service is being 
provided, the vehicle shall be in constant radio contact, via the company’s control centre, with 
someone  who  can  provide  evidence  of  at  least  B1-level  language  skills  in  the  language 
concerned,  so  as  to  ensure  that  effective  communication  with  the  national  authorities  is 
possible at all times.  

D. Vehicle equipment 

(a)  The  vehicles  used  shall  all  be  equipped  with  a  global  satellite  positioning  system.  The 
cash-in-transit  company’s  control  centre  shall  be  able  to  locate  its  vehicles  accurately  at  all 
times.  

(b) Vehicles  shall  be equipped with appropriate communication tools to allow contact to be 
made at any time with the control centre of the company operating the vehicles and with the 
competent national authorities. The emergency numbers to contact the police authorities in the 
Member States crossed or in the Member State(s) in which the service is being provided shall 
be available on board the vehicle. 

(c) When vehicles are equipped with intelligent banknote neutralisation systems (IBNS), these 
shall comply with the requirements laid down in Annex […]. 

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E. Advance notification of national police forces 

The  present  rules  are  without  prejudice  to  the  application  of  national  rules  that  require  the 
police to be notified of all cash-transport operations in advance.  

F. Procedures for handling cash outside the CIT-vehicle in the Member State(s) in which 
the service is being provided 

The  present  rules  are  without  prejudice  to  the  application  of  national  rules  governing  the 
handling of cash outside the CIT-vehicle in the Member State concerned.  

G. Mutual information 

(a) Member States shall transmit to the Commission the rules mentioned under E and F and 
shall immediately inform it of any change affecting them. The Commission shall ensure that 
those  rules  are  published  in  all  the  official  languages  of  the  participating  Member  States 
through the appropriate channels, with a view to informing swiftly all the actors involved in a 
CIT cross-border activity.  

(b) Member States shall keep a register of all the companies to which they have delivered a 
CIT cross-border licence and shall inform each other about its content. They shall update the 
register with any change affecting it, including any decision to suspend or withdraw a licence 
pursuant to Article […] and shall immediately inform each other of the update.  

(c)  A  company  holding  a  CIT  cross-border  licence  shall  inform  the  granting  authority 
sufficiently  in  advance  about  the  names  of  the  Member  States(s)  in  which  it  will  carry  out 
CIT-transport. The Member State of origin shall subsequently immediately notify the Member 
State(s) concerned that the cross-border activity is to start. 

SECTION  2.  SPECIFIC  RULES  ENVISAGED  FOR  THE  FOUR  AUTHORISED 
TYPES OF TRANSPORT 

A. Transportation of banknotes in an unarmoured or cabin-armoured vehicle equipped 
with IBNS 

Companies  holding  a  CIT  cross-border  licence  may  carry  out  daytime  cross-border 
transportation of euro banknotes by road using a vehicle equipped with IBNS, provided that 
the following conditions are met:  

(a) the vehicle must either be of ordinary appearance or have its cabin armoured and bear very 
clear  markings  indicating,  in  the  official  language(s)  of  the  Member State(s)  crossed  and  of 
the Member State(s) in which the service is being provided, that it is equipped with an IBNS. 

(b)  the  intelligent  banknote  neutralisation  system  used  must  comply  with  the  principles  laid 
down in [Annex …] and have been homologated in at least one participating Member State.  

(c) there must be at least two CIT security staff per vehicle and these must be unarmed; they 
must not wear a uniform if the vehicle in which they are is of ordinary appearance. 

(d)  a  Member  State  may  decide  that  the  present  [Article]  does  not  apply  for  cross-border 
transportation of euro cash by road carried out on its territory, provided that it does not allow 
comparable  transport  modalities  for  domestic  CIT-transports.  The  Member  State  concerned 

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shall notify its decision not to apply this [Article] to the Commission, which will ensure that a 
corresponding information notice is published in the Official Journal of the European Union. 
It will take effect one month after its publication. 

B. Transportation of banknotes in a fully-armoured vehicle not equipped with IBNS 

Companies  holding  a  CIT  cross-border  licence  may  carry  out  daytime  cross-border 
transportation  of  euro  banknotes  by  road  using  a  fully-armoured  vehicle  not  equipped  with 
IBNS, provided that the following conditions are met: 

(a) The CIT security staff must comply with the existing rules in the Member State(s) crossed 
and in the Member State(s) in which the service is being provided as regards the carrying of 
firearms and the maximum permitted calibre. When entering the territory of a Member State 
that does not allow CIT security staff to be armed, any firearms in the possession of the CIT 
security staff must be placed in an on-board strong-box which meets the European standard 
[EN 1143-1]. Such firearms must remain inaccessible to the CIT security staff throughout the 
journey  across  that  Member  State’s  territory.  They  may  be  removed  from  the  strong-box 
when  entering  the  territory  of  a  Member  State  that  allows  CIT  security  staff  to  be  armed. 
Opening  the  firearms  strong-box  must  require  remote  intervention  by  the  vehicle’s  control 
centre and must be conditional upon verification, by the control centre, of the vehicle’s exact 
geographical location. 

(b) Armed CIT security staff must: 

[Option  1:  be  in  possession  of  a  “European  firearms  pass  for  CIT  security  staff”.  The  pass 
shall be granted by issuing the company with documents that conform to the model provided 
in  Annex  […].  This  pass  shall  be  granted,  upon  request,  to  CIT  security  staff  who  hold  a 
firearms  licence  issued  in  accordance  with  the  applicable  national  legislation  and  are 
employed  by  a  company  holding  a  CIT  cross-border  licence,  and  must  be  issued  by  the 
Member State that granted that CIT cross-border licence. 

CIT security staff must be able to show the European firearms pass to the police authorities if 
a check is carried out in connection with the cross-border transportation of euro cash by road. 
Armed CIT security staff must have received a minimum of [30] hours’ training in the use of 
firearms and must subsequently receive training in their use at least [once a year].] 

[Option 2: apply for a firearms licence from the national authorities of the Member State(s) 
crossed and/or the Member State in which the service is being provided, where those Member 
States allow CIT security staff to be armed.] 

(c)  There  must  be  at  least  three  CIT  security  staff  per  vehicle.  They  must  wear  bulletproof 
vests capable, at the very least, of withstanding projectiles of type 44 Magnum and respect the 
norm [NIJIIIA] or equivalent. 

(d)  The  parts  of  the  vehicle  in  which  the  CIT  security  staff  are  must,  at  the  very  least,  be 
armoured  to  withstand  gunfire  from  firearms  of  type  kalachnikov/AK47  and  respect  the 
standard [EN 1522, class FB4+] or equivalent. 

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C. Transportation of banknotes in a fully-armoured vehicle equipped with IBNS 

Companies  holding  a  CIT  cross-border  licence  may  carry  out  daytime  cross-border 
transportation of euro banknotes by road using a fully-armoured vehicle equipped with IBNS, 
subject to the conditions set out in Section 2, points B and A b. The vehicle shall, furthermore, 
bear very clear markings indicating, in the official language(s) of the Member State(s) crossed 
and  of  the  Member State(s)  in  which  the  service  is  being  provided,  that  it  is  equipped  with 
IBNS. 

There must be at least two CIT security staff per vehicle.  

D. Transportation of coins 

Companies  holding  a  CIT  cross-border  licence  may  carry  out  daytime  cross-border 
transportation  of  euro  coins  by  road  using  a  vehicle  carrying  only  coins,  provided  that  the 
following conditions are met:  

(a) The cabin of the vehicle must be armoured and the vehicle must bear very clear markings 
indicating,  in  the  official  languages  of  the  Member  State(s)  crossed  and  of  the  Member 
State(s) in which the service is being provided, that it is carrying only coins. 

(b) There must be at least two CIT security staff per vehicle [and these must be unarmed]. 

Consignments which include both coins and banknotes shall be covered by Article 8, 9 or 10 
depending on the type of vehicle used. 

SECTION 3. MISCELLANEOUS 

A. Definitions 

(a) “Cross-border transportation of euro cash by road” means professional  transportation by 
vehicle  of  banknotes  and/or  coins  from  a  participating  Member  State  which  has  granted  a 
cash-in-transit (CIT) cross-border licence, as defined in this [Regulation], for supplying euro 
banknotes and/or coins to, or collecting them from, one or more customers located in one or 
more other participating Member State(s), as well as in the Member State of origin.  

(b)  “Intelligent  banknote  neutralisation  system  (IBNS)”  means  banknote  containers  for  end-
to-end  use  (i.e.  continuous  protection  of  the  banknotes  by  a  cash  degradation  system  from 
secured  area  to  secured  area)  equipped  with  a  mechanism  for  permanently  neutralising  the 
banknotes if any unauthorised attempt is made to open the container. 

(c) “Member State of origin” means the Member State in whose territory the CIT-company is 
established  and  which  forms  the  starting  and  the  return  point  of  the  journey  made  by  the 
vehicle transporting the cash. The CIT-company is considered to be established if it is actually 
pursuing  an  economic  activity,  as  referred  to  in  Article  43  of  the  Treaty,  for  an  indefinite 
period  through  a  stable  infrastructure  from  where  the  business  of  providing  services  is 
actually carried out; 

(d) “CIT cross-border licence” means a licence which has the physical characteristics set out 
in Annex […] to this [Regulation] and which authorises the holder to carry out cross-border 
transportation of euro cash by road between participating Member States in accordance with 
the conditions laid down by this [Regulation]. 

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(e) “Ordinary vehicle” means a vehicle which has a normal appearance and does not bear any 
distinctive signs indicating that it belongs to a cash-in-transit company or that it is used for the 
purposes of transporting cash.  

(f) “CIT security staff” means the employees instructed to drive the vehicle in which the cash 
is being carried or to protect its contents. 

(g) “Member State crossed” means one or several Member State(s) other than the company’s 
Member State of origin which must be crossed by the cash-in-transit vehicle in order to reach 
the Member State(s) in which the service is being provided. 

(h) Language levels “A2” and “B1” mean the levels established by the Council of Europe’s 
Common European Framework of Reference for Languages.  

(i) “Daytime” transport means transport carried out between [6:00] and [22:00].  

(j)  'Point-to-point  transport'  means  a  transport  from  one  secure  location  to  another  secure 
location, without any intermediate stops. 

(k) 'Official language' means the official Community language(s) used by the local authorities 
and the population in the areas where the CIT-transport is taking place. 

B. Penalties 

Where the competent national authorities find that there has been an infringement of one of 
the terms under which the CIT cross-border licence was granted, the granting authority shall 
decide  whether  to  send  a  warning  to  the  company  concerned,  to  suspend  the  licence  for  a 
period  ranging  from  [two  weeks  to  two  months]  or  to  withdraw  the  licence  completely, 
depending on the nature or seriousness of the infringement. The granting authority may also 
prohibit  the  company  concerned  from  applying  for  a  new  licence  for  a  period  of  up  to  [5 
years].  

The  Member  State  crossed  or  where  the  service  is  provided  shall  communicate  any 
infringement of this [Regulation] to the competent national authorities of the Member State of 
origin. The Member State crossed or where the service is provided may suspend the right of 
the company to carry out transportation of euro cash by road on its territory for a maximum 
period of [one month] if the provisions of this [Regulation] relating to the minimum number 
of  CIT  security  staff  per  vehicle  or  relating  to  firearms  have  not  been  respected,  pending  a 
decision by the granting authority of the Member State of origin. 

C. Review 

The  Commission  shall  report  to  the  Council  on  the  implementation  of  this  [Regulation]  by 
[two years after its entry into force] at the latest and, thereafter, once every five years.  

D. Emergency security measures 

(a)  By  way  of  derogation  from  the  standard  rule,  a  Member  State  may  decide  to  introduce 
temporary security measures going beyond those foreseen by the present rules in the event of 
an  urgent  problem  affecting  significantly  the  security  of  CIT  operations.  Those  temporary 
measures shall affect all CIT transports, shall apply for a maximum period of four weeks and 

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shall  be  notified  immediately  to  the  Commission.  The  Commission  shall  ensure  their  swift 
publication.  

(b) The prolongation of the temporary measures provided for in paragraph (a) beyond a period 
of four weeks shall be subject to prior authorisation by the Commission.  

E. Other Community legislation 

This  [Regulation]  shall  be  without  prejudice  to  the  application  of  existing  Community 
legislation,  notably  in  the  fields  of  working  conditions,  health  and  safety  at  work  and 
transport.  

F. Intelligent banknote neutralisation system (IBNS) 

As  long  as  there  is  no  European  specific  standard,  the  IBNS  must  be  homologated  in  one 
participating Member State. It must, furthermore, fulfil the following minimum conditions: 

•  The  IBNS  must  be  equipped  with  a  device  that  is  able  to  constantly  monitor  that  pre-
programmed  instructions  are  respected  and  that  abnormal  events  are  detected.  The  CIT 
security staff must not be able to open the IBNS outside the pre-programmed time periods 
and/or locations. 

•  The IBNS must be capable, if any unauthorised attempt is made to open the container, of 
permanently  neutralising  (i.e.  making  unsuitable  for  cash  transaction  purposes)  at  least 
20 % of the surface area of both sides of 100 % of the banknotes with an indelible, opaque 
ink  or  by  other  means.  If  ink  is  used,  it  must  not  appreciably  degrade  over  time  or  with 
exposure to heat or light. 

G. Council of Europe's common Reference Levels 

User B1: Can understand the main points of clear standard input on familiar matters regularly 
encountered in work, school, leisure, etc. Can deal with most situations likely to arise whilst 
travelling  in  an  area  where  the  language  is  spoken.  Can  produce  simple  connected  text  on 
topics which are familiar or of personal interest. Can describe experiences and events, dreams, 
hopes and ambitions and briefly give reasons and explanations for opinions and plans. 

User A2: Can understand sentences and frequently used expressions related to areas of most 
immediate  relevance  (e.g.  very  basic  personal  and  family  information,  shopping,  local 
geography,  employment).  Can  communicate  in  simple  and  routine  tasks  requiring  a  simple 
and  direct  exchange  of  information  on  familiar  and  routine  matters.  Can  describe  in  simple 
terms  aspects  of  his/her  background,  immediate  environment  and  matters  in  areas  of 
immediate need. 

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