COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT accompanying document to the Proposal for a Regulation (EU) of the European Parliament and of the Council No xx/yy on the professional cross border transportation of euro cash by road between euro-area Member States   and the   Proposal for a Council Regulation (EU) No zz/yy concerning the extension of the scope of Regulation (EU) of the European Parliament and of the Council No xx/yy concerning the professional cross border transportation of euro cash by road between euro-area Member States   {COM(2010)377 final} {SEC(2010) 877final}
Date: 2010-07-14
Institutions: European Commission
Subjects: EU Member State, EU action, European currency, common transport policy, cross-border transport, paper money

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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 European Parliament and of the Council No 
xx/yy on the professional cross-border transportation of euro cash by road 
between euro-area Member States 

and the 

Proposal for a Council Regulation (EU) No zz/yy concerning the extension of the 
scope of Regulation (EU) of the European Parliament and of the Council No xx/yy 
concerning the professional cross-border transportation of euro cash by road 
between euro-area Member States 

{COM(2010)377 final} 
{SEC(2010) 877final} 

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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 types and Restrictions of the scope of the 
common rules ............................................................................................................... 9 

6.2.5.  Potential impact on the security 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. 

8. 

Comparison of options and summary of impacts (second-round assessment)........... 16 

Monitoring and evaluation ......................................................................................... 20 

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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 CO2 
and other emissions. An attempt at quantifying 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 travel 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 transport 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 examined in the report. It should be emphasised that this is 
a simplified and theoretical exercise, which nevertheless could provide some indication 
of the magnitude of these savings. 

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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 distance 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 aggregated into total savings pr. day and pr. 
year.  This  shows  that  cross-border  CIT  transports  can  save  around  2.8  million  km  pr 
year  in  the  long-term.  This  corresponds  to  0.8  percent,  respectively,  out  of  the  total 
kilometres that CIT-vehicles travel per year.  

In  terms  of  associated  savings  in  fuel  and  CO2  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 CO2 emissions are some 850 tonnes. 

Facilitating cross-border cash transports are thus likely to produce some environmental 
benefits,  but  of  a  limited  magnitude  relative  to  the  total  number  of  kilometres,  fuel 
consumed and CO2 and other emissions. As mentioned at the beginning of Section 6, the 
savings depend also on the extent to which the potential market can be realised. 

6.2.3.  Potential social impact 

If  regulatory  obstacles  to  the  professional  cash  transport  by  road  are  successfully 
removed, leading to a significant increase in cross-border transports and a more efficient 
cash cycle, this would strengthen the competitiveness of the sector as a whole. This is in 
the long-term interest of the workers in the sector 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  CIT-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 therefore be foreseen as part of common cross-
border  rules  (which  is  not  required  in  all  euro-area  countries),  which  should  inter  alia 
cover  cross-border  CIT-legislation  and  procedures,  applicable  national  legislation  and 
rules covering CIT. 

As  explained  in  the  problem  definition  above,  a  significant  increase  in  cross-border 
transports  may,  however,  also  have  negative  social  effects  in  the  host  countries.  This 
concerns notably a possible effect on wage levels and/or employment in the CIT-sector 
in  a  given  host  country,  if  there  are  significant  differences  in  salaries  compared  to 
neighbouring  countries.  It  may  therefore  be  justified  to  mitigate  the  potential  social 
impact in the host country by ensuring a minimum protection of the workers in line with 
the  principles  of  existing  EU  legislation.  Directive  96/71/EC  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  Directive,  Member  States  shall  ensure  that 
workers  posted  to  a  host  country  are  guaranteed  a  number  of  terms  and  conditions  of 
employment, provided these are laid down by law or by collective agreements that have 
been  declared  universally  applicable1.  These  include  minimum  rates  of  pay,  including 
overtime rates, as well as paid annual holidays, maximum work periods and minimum 

1 

For the full text, see Article 3(1) of Directive 96/71/EC. 

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rest  periods,  health,  safety  and  hygiene  at  work,  protective  measures  for  pregnant 
women etc.  

In  view  of  the  specific  character  of  CIT  transport  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-term  nature  of  the  potential  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  hours  that  CIT-staff  spends  in  the  host 
country(ies).  Moreover,  the  different  contractual  situations  in  the  CIT-sector  may 
require a case-by-case assessment of whether 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  contract  with  the  bank  of  that  retailer.  In  the 
latter case, the Directive may not be applicable. 

In order to create legal certainty for the concerned operators and in order not to impose 
an unnecessary administrative burden on the operators, which could in practice have the 
effect of seriously impeding the possibility of carrying out such cross-border transports, 
the following specific provisions should therefore apply to cross-border cash transports: 

•  It  should  be  clarified  that  the  minimum  protection  of  workers  foreseen  by  the 
Directive  should  apply  to  all  cross-border  cash  transports  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,  according  to  the  statutory 
minimum wage). In order to avoid complicated 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 specific 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  include  all  the  terms  and 
conditions of employment covered by the Directive (i.e. also holidays, maximum work 
periods and minimum rest periods etc).  

Due  to  the  specific  characteristics  of  the  CIT-sector,  it  is  also  necessary  to  foresee  a 
derogation from the general rules in the transport 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  Section  6.2.4),  no  limit  to  the 
number of cash pick-ups/deliveries are foreseen 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  apply  (provided  it  is  higher  than  the  actual 
salary paid to the worker under his labour contract). 'Home' means home country actual 

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salary according to the labour contract and 'Host' means host country minimum rates. It 
should be pointed out that the minimum rates of pay in the 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 into account for the calculation of minimum 
rates of pay depends on the situation in each Member State and remains to be clarified. 
The existence of universally 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' would ensure that the minimum rates of pay 
according  to  the  universally  applicable  relevant  collective  agreements  cannot  be 
undercut  in  Belgium,  the  Netherlands,  Luxembourg,  France,  Italy,  Austria,  Spain  and 
Portugal, which according to the abovementioned analysis all have such agreements. 

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Table 3. Applicable salary if minimum rates of host country applies (statutory minimum 
wage or minimum rates according to universally 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 agreements (UACA) or, failing that, statutory minimum wages 
(SMW). 

To 

BE 

 DE 

NL 

LU 

FR 

IT 

AT 

SI 

SK 

ES 

PT 

From 

BE 
(2365 €) 

(2153-

2408  €)

(UACA) 

(1386-

(1879-

(1297-

(1015-

(1460  €)

(589  €) 

(296  €) 

(917-

(943  €)

2067  €)

2560  €)

1560  €)

1798  €)

961 

€)

(UACA) 

(UACA) 

(UACA) 

(UACA) 

(UACA) 

(SMW) 

(SMW) 

(UACA) 

(UACA) 

Home 
(2365 €)  

Home 
(2365 €)  

Depends  

Home 
(2365 €) 

DE (*) 
(1315-2261 €) 

Depends 

Home 
(2135€ / 
2261€) 

Host 

Home 

Home 

NL 
(1902 €) 

LU 
(2572 €) 

FR 
(2268 €) 

IT 
(2083 €) 

AT 
(2077 €) 

SI  
(1083 €) 

SK 
(750 €) 

ES 
(1754 €) 

PT 
(1189 €) 

Host 
(2153 to 
2408 €) 

Home 
(1902 €) 

Normally 
Host 

Home 
(1902 €) 

Home 
(2572 
€) 

Home 
(2572 €)  

Home 
(2572 €) 

Home 
(2572 €) 

Depends 

Home 
(2268 €) 

Depends 

Home 
(2268 €) 

Home 
(2268 €) 

Home 
(2083 €)  

Home 
(2083 €)  

Home 
(2083 €)  

Home 
(2077 €) 

Home 
(2077 €) 

Home 
(2077 €) 

Home 
(2077 €) 

Depends 

Host 
(1460 €) 

Host 
(1460 €) 

Home 
(1754 €) 

Home 
(1754 €)  

Home 
(1189) 

* Collective agreements in Germany are concluded at the level of each Land. For salaries 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 applicable collective agreements), Eurostat (for statutory minimum wages), 
ESTA, 2010 (for BE, ES, FR, LU, NL, AT, PT, SI and 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 monthly salary according to collective agreements 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 other euro-area countries are not included in the table. 

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Based on the information in the table, such a clarified 'minimum protection rule' would 
in practice ensure that CIT-workers that carry out cross-border cash transports over the 
borders from the Netherlands would be entitled to the minimum rates of pay in Belgium 
according  to  its  universally  applicable  collective  agreements  in  the  CIT-sector.  For 
possible cross-border transports from Germany to Belgium, it would mean that workers 
under  collective  agreements  from  Rheinland-Pfalz/Saarland  would  be  guaranteed  the 
Belgian  minimum  rates,  whereas  for  workers  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 not 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  include  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  collective  agreements.  The  definition  of  the 
concept of minimum rates of pay is in principle a matter for the Member States, i.e. in 
this context the host Member State. 

The table below attempts to provide an indication 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  may  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 borders 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 

Seniority 24 months 

Risk premiums 

25 374 21 912 14 421 20 000 27 062 22 830 24 928 12 854  9 000  13 000

-

400

476

2 016 2 800 1 068

0 

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  average,  since  collective  agreements  are  concluded  at  the  level  of  the 
Länder. 

As can be seen from the table, other wage elements constitute between 0 % and 14 % of 
the base salary ineightof the ten countries in the table, whereas in Spain and France they 

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represent around a third of the total salary. Other wage elements 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.  UNI-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  higher  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 workers, which intends to ensure a minimum protection 
for workers. 

A  clarified  rule  on  applicable  minimum  rates  of  pay  in  the  host  country,  as  outlined 
above,  could  thus,  with  some  possible  reservations  regarding  other  wage  elements,  be 
considered  as  an  effective  'minimum  protection  rule'  in  order  to  mitigate  potential 
negative  social  effects  in  the  host  countries  of  an  increase  in  cross-border  cash 
transports. 

6.2.4. 

Specific options: Non-harmonised rules on the carrying of weapons, National 
derogations  from  authorised  transport  types  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 carrying of arms and possibilities of national 
derogations  from  authorised  transport  types.  The  envisaged  common  rules  annexed  to 
the  White  Paper  and  subsequently  elaborated  in  the  expert  group  with  representatives 
from  Member  States'  administrations  foresee  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 and in the host Member State(s) as regards the 
carrying of weapons and the maximum permitted calibre. 

B.  Cross-border  cash  transport  may  be  carried  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 transport 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'  administrations  and  other  stakeholders  have 
shown  that  these  exceptions  are  seen  as  necessary  in  order  to  ensure  a  high  level  of 
security and that they are a necessary precondition 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 collected via a questionnaire to Member States2. 

2 

Questionnaire of 17.7.2009, ref Ares(2009)177142. 

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The national weapons legislation may raise serious obstacles to cross-border transports 
in two cases: a) if the carrying 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 abovementioned 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 replies 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  neighbours,  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  collective  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 particular calibre is prohibited may furthermore make use of 
the possibility foreseen by the envisaged common rules of locking the weapons into a 
strong-box in the vehicle. Once locked, the content 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 vehicle leaves the country in question. 

Although  the  different  national  rules  in  the  field  of  weapons  are  likely  to  reduce  the 
potential  cross-border  market  to  some  degree,  it  can  be  concluded  that  they  do  not 
create  major  problems  for  cross-border  transports.  Although  some  transport  options 
would be excluded, transport would still be possible under other options. Furthermore, 
the envisaged common rules also foresee concrete measures to reduce the impact of the 
different  national  rules  through  rules  on  mutual  approval  of  equivalent  weapons 
training, on facilitation of applications 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  authorise  comparable  transport 
modalities for domestic transports) it is difficult 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  might  in  some  cases  concern  transports  in 
unarmoured vehicles (equipped with IBNS), whereas it seems likely that transports with 
fully-armoured  vehicles  will  be  possible  in  practically  all  cases3.  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 reduce the potential cross-border 
market to some degree. 

The  maintaining  of  national  weapons  legislation  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  States.  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. 

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cases  solutions  that  enable  cross-border  transports  (strong-box,  standardised  transport 
options, recognition of equivalent weapons training, etc.).  

The potential impact of common rules may moreover be reduced if there are restrictions 
foreseen for the scope and definition of cross-border transports. The envisaged common 
rules annexed to the White Paper and subsequently 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  perceived  security  threats  or  avoid 
undue circumvention of national rules: 

C. Cross-border transportation of euro cash shall be carried out during daytime (defined 
as 06.00–22.00) and the CIT-vehicle shall depart from and return to its Member State of 
origin in the same day (an exception is, however, 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 rules 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  considered  as  cross-border  (whereas  for  point-to-
point  transports  it  is  enough  that  the  transport  takes  place  between  two  different 
participating Member States). 

The  restriction  foreseen  under  the  specific  option  C  is  not  expected  to  have  any 
significant impact on the extent of cross-border cash transportation, since it is common 
practice in the sector that the cash transports 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  will  not  be  possible  for  CIT-
vehicles to spend the night under non-secure conditions in another country. 

The restriction foreseen under the specific option D is a result of the consultations with 
Member  States'  administrations  and  is  intended  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  should  however  not  be  overestimated  in  the 
sense that, in practice, CIT Companies would not invest time and resources to comply 
with the new cross-border rules for just a few 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  attacks  furthermore  vary  significantly  across 
countries. It is crucial that common rules for cross-border cash transport provide a high 
level of security for both the staff and the general public.  

The  envisaged  common  rules  have  therefore  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'  administrations  (Finance  Ministries,  Ministries  of 
Interior and Justice, Central Banks and police authorities). 

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In  order  to  ensure  a  high  level  of  security,  the  envisaged  common  rules  foresee  high 
standards in the relevant fields, such as licensing requirements, the repute and integrity 
of CIT-staff including managers 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 communication 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 armouring 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  rules  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 types4 modelled on 
the existing transport types in Member States, with different rules on minimum level of 
staffing, bullet-proof vests, uniforms etc. However, if a Member 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  transport  types  for  domestic  CIT-
transports). 

Finally, shorter transports overall due to increased 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 common 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  interesting  for  other  EU 
Member States that the envisaged common rules cover their territory and possibly their 
currency as well.  

Such a possibility could be particularly relevant for countries that are close to adopting 
the euro in order to adapt in advance to rules 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. 

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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  differences  in  salaries  are  very  substantial  it  could  also 
give  CIT-companies  in  the  (low-cost)  country  such  an  advantage  that  it  could  have  a 
substantial negative social impact 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,  compared  with  the  actual  salaries  in  the 
neighbouring euro area countries. Salaries may vary according to, for instance, years of 
experience,  qualifications  and  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 
Member State 

area 

Actual monthly salary 

Poland 

472 € 

Czech Republic 

605 € 

Hungary 

513 € 

Actual monthly salary in bordering 
euro-area country, or in the case of 
Germany, the bordering Bundesland
(bordering non-euro area country in 
parenthesis) 
Mecklenburg-Vorpommern & 
Brandenburg 1315 € (PL) 

Sachsen 1289 € (PL, CZ) 

Bayerna2121-2195 € (CZ) 

Austria 2077 € (CZ, HU) 

Exchange rates used (1 € =): 
4,2 PLN, 25,5 CZK, 273 HUF. 

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 are 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-euro  area  countries  are  very  substantial.  Salaries  are 
over 60 % lower in Poland than in the neighbouring 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  Sachsen  and  over  70 % 
lower than in the bordering Land of Bayern. Compared to Austria, salaries in the Czech 
Republic are around 70 % lower, whereas salaries 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 company would thus be obliged to pay at least 
the Austrian minimum rates of pay to CIT-workers that are posted there. As regards the 
German  Länder  referred  to  above,  there  is  however  currently  not  any  universally 

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applicable (within the meaning of Directive 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 common rules, for their 
territory and possibly their currency, could have a more significant impact in Germany 
in  the  absence  of  universally  applicable  collective  agreements  there.  The  legal 
possibility  to  declare  collective  agreements  as  universally  applicable  does,  however, 
exist5, but it is a matter of German national competence 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 would at least apply during 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 objective 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  have  argued  that  there  is  a  need  also  for 
delivery  and  repatriation  of  other  EU  and  EEA  currencies,  which  should  not  be 
prevented. This would not contribute to achieving 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  rules  might,  however,  also  complicate  the 
adoption process for comparatively little added value.  

It does therefore not seem necessary to generally 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  exclude  the  large  majority  of 
transports  in  terms  of  kilometres  driven,  hours  worked  and  cash  points  serviced 
(although not in terms of value of euro transported). The potential 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 area 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. 

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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 their action or production. 

As regards the CIT-companies, the information 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 thus choose to apply for a CIT cross-border 
licence. 

The administrative costs for these CIT-companies 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-transport 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  verifies  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 contact point to which CIT-staff of other Member States 
my  submit  an  application  for  a  weapons  licence  and  inform  each  other  about  the 
contact details of this 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 and on IBNS that have been homologated 
by them. 

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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 specific options in order 
to  take  into  account  security-related  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 next page on the basis of the same criteria as 
in the first-round assessment (Section 5): 

•  Effectiveness: The extent to which options achieve the objectives of the proposal; 

•  Efficiency:  The  extent  to  which  objectives  can  be  achieved  for  a  given  level  of 
resources/at  least  cost,  notably  administrative  costs  for  all  parties  involved  (cost-
effectiveness); 

•  Coherence:  The  extent  to  which  options  are  coherent  with  the  overarching 

objectives of EU policy. 

•  Proportionality:  Community  action  should  not  go  beyond  what  is  necessary  to 

achieve the objectives set. 

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The table first compares the retained broad option 3 with the base-line option 1, without 
taking  into  account  possible  derogations and restrictions 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 options compared to a full application of the broad option 3 is 
then summarised. The broad option 3 including the effect of the four specific options is 
thereafter compared with the baseline and finally the effects of each of the sub-options 
are compared with the broad option 3. 

Table 6. Comparison of the retained broad option with the baseline 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 
objectives 

reaching 

Coherence 
with overarching EU 
objectives 

Proportionality 

1. No change 

3. Common cross-
border rules (full 
application) 

A. Derogation for 
national weapons 
legislation 

B. Transport type 
opt-out possibility 

C. One-day and 
day-time transport 

D. Majority of 
stops abroad 

3. Common cross-
rules 
border 
(with 
specific 
options A-D) 

Sub-options: 

a) Extension of the 
to  MS 
scope 
the  euro 
outside 
area 

0 

++ 

0 

++ 

0 

++ 

0 

++ 

Reduction 

Reduction 

Reduction 

Neutral 

Reduction 

Reduction 

Reduction 

Neutral 

Neutral 

Neutral 

Neutral 

Neutral 

Reduction 

Reduction 

Reduction 

Neutral 

+(+) 

+(+) 

+(+) 

++ 

Some 
improvement 

Some 
improvement 

Improvement 

Neutral 

b) 
the 
Extend 
scope to other cash 

Neutral 

Some 
improvement 

Improvement 

Neutral 

c)  Restricting  the 
scope  to  point-to-
point transports 

Reduction 

Reduction 

Reduction 

Neutral 

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The analysis has shown that the introduction of common EU rules applicable to cross-
border  transports  as  outlined  in  the  present  impact  assessment  (Option  3)  would  be 
effective in reaching the stated objective of facilitating the free circulation of euro cash 
within the euro area by removing obstacles to the professional transport 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-border transports will to some extent be 
reduced by necessary exceptions and derogations from and restrictions 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, this 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 meet the criterion of proportionality. The 
EU rules would remove national regulatory obstacles to cross-border transport of euro 
cash, while the national regulation of purely domestic transports would remain in force. 

The  facilitation  of  cross-border  cash  transports  is  also  likely  to  produce  some 
environmental  benefits,  due  to  shorter  transports  overall,  although  these  benefits  are 
expected to be of a relatively limited magnitude.  

On  the  basis  of  extensive  consultations  with  stakeholders  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  legislation  and  possibilities  for  Member  States  of 
opting  out  from  specific  transport  types  if  they  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 neighbouring countries. In view of the specific 
nature  of  CIT  transport  services,  notably  the  frequent  and  short-term  nature  of  the 
potential work periods abroad, a clarification 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 extension of the scope of the common rules to EU 
Member States outside the euro area that are close to adopting the euro would to some 
degree contribute to the free circulation of euro cash within the euro area by allowing 
countries that are close to adopting the euro to adapt in advance 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  overarching  EU  objectives  such  as  realising  the 
potential of the single market and creating a more competitive and connected economy. 
Extending  the  scope  to  other  cash  does  not  contribute  to  the  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 

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rules for relatively little added value. Restricting 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-area  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 efficient way relative 
to  the  other  broad  policy  options,  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.  It  is  furthermore  recommended  that  Option  3  is  completed  with 
sub-option a), i.e. the extension of the  common rules to the territory of other EU 
Member States that are about to introduce the euro. 

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8. 

MONITORING AND EVALUATION 

In  order  to  monitor  the  implementation  of  common  cross-border  rules  and  possibly 
propose measures to improve the 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  would  help  the  Commission  in  assessing  the 
effectiveness  of  the  new  rules.  The  Committee  should  also  consult  the  relevant 
stakeholders,  including  the  social  partners,  and  take  their  views  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  consultations  of  the  stakeholders  in  the 
sector, including the social partners. Based on the result of the review, the Commission 
could  make  a  proposal  to  revise  the  Regulation.  The  review  should  thereafter  be 
repeated every five years. 

For  this  purpose,  specific  indicators  should  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 indication of possible indicators: 

Specific objectives 

Indicators 

Facilitate the free circulation of the euro 
between euro-area Member States 

Number of CIT cross-border licenses 
granted/withdrawn 

Number of cross-border cash transports 

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 significant 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  respected,  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. 

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