Opinion of the European Central Bank of 6 February 2024 on the cash infrastructure network (CON/2024/3)
Date: 2024-02-06
Institutions: European Central Bank
Subjects: legal basis, money

EN 

ECB-PUBLIC 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 6 February 2024 

on the cash infrastructure network 

(CON/2024/3) 

Introduction and legal basis 

On 18 December 2023 the European Central Bank (ECB) received a request from the Magyar Nemzeti 

Bank  (MNB)  for  an  opinion  on  a  draft  MNB  decree  amending  the  MNB  decree  on  the  processing  and 

distribution  of  banknotes  and  on  technical  tasks  relating  to  the  protection  of  banknotes  against 

counterfeiting (hereinafter the ‘draft decree’). 

The ECB’s competence to deliver an opinion is based on Articles 127(4) and 282(5) of the Treaty on the 

Functioning of the European Union and the second indent of Article 2(1) of Council Decision 98/415/EC1, 

as the draft decree relates to means of payment. In accordance with the first sentence of Article 17.5 of the 

Rules of Procedure of the European Central Bank, the Governing Council has adopted this opinion. 

1. 

Purpose of the draft decree 

1.1  The  draft  decree  has  two  main  purposes:  first,  to  lay  down  equivalent  requirements  as  to  the 

minimum required size of the operating cash infrastructure for credit institutions, including Hungarian 

branches of credit institutions registered abroad already operating in Hungary and those entering the 

Hungarian market; and second, to clarify the circumstances under which credit institutions may limit 

the cash services they provide in their branches. 

1.2  Credit institutions are currently obliged to operate an automated teller machine (ATM) network based 

on  territorial  and  turnover-based  criteria  and  must  conduct  an  examination  of  their  ATM  network 

every three years, the results of which must be sent to the MNB. Certain credit institutions are exempt 

from these obligations 2. The draft decree clarifies when credit institutions starting their operations in 

Hungary after the entry into force of the draft decree that will have a market share of less than 1 % 

in respect of issued payment cards with a cash withdrawal function will be exempt from the obligation 

to operate such an ATM network. Additionally, the draft decree requires all credit institutions starting 

their  operations  in  Hungary  after  the  entry  into  force  of  the  draft  decree  to  conduct  an  initial 

examination of their ATM network, based on both territorial and turnover-based criteria. 

1.3  The  draft  decree  also  proposes  to  supplement  the  existing  rules  on  closing  or  restricting  the 

operations of cash desks in branches of credit institutions and establishing new branches without a 

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Council Decision 98/415/EC of 29 June 1998 on the consultation of the European Central Bank by national authorities 
regarding draft legislative provisions (OJ L 189, 3.7.1998, p. 42). 
See Article 9 and Article 10(7) of 1/2023. (I. 17.) MNB rendelet a bankjegyek feldolgozásáról, forgalmazásáról, valamint 
hamisítás elleni védelmével kapcsolatos technikai feladatokról, published in Magyar Közlöny 2023/8. 

 
 
 
 
 
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cash  desk.  Accordingly,  credit  institutions  aiming  to  restrict  the  operation  and  availability  of  their 

branches’ cash desks in a way that is expected to reduce the number of cash transactions of the 

given cash desk by at least 30 % will be obliged to install at least one new ATM in an infrastructure 

hub  within  the  municipality  or  metropolitan  district.  In  addition,  credit  institutions  opening  a  new 

branch without a cash desk will be required to install at least two new ATMs in that branch or in that 

municipality or metropolitan district. 

2. 

General observations 

2.1  Cash payments facilitate the inclusion of the entire population in the economy by allowing citizens to 

settle a wide range of payment transactions in this way, thus ensuring freedom of choice as to method 

of payment for all citizens 3. Additionally, cash is a well-established means of payment providing for 

immediate settlement of debts and direct control over the payer’s spending. It is currently the only 

payment instrument that allows citizens to settle a transaction in central bank money which is also 

settled instantly, while, importantly, ensuring privacy 4. Cash could also play an essential role in the 

event of a disturbance in the payment system 5. The ability to pay in cash also remains particularly 

important for certain groups in society that, for various legitimate reasons, prefer to use cash rather 

than  other  means  of  payment,  or  do  not  have  access  to  bank  services  and  electronic  means  of 

payments. These groups include disabled citizens, immigrants, socially vulnerable citizens, elderly 

people, minors and others with limited or no access to digital payment services 6. 

2.2  While the ECB holds a positive view of further innovation and development in the field of electronic 

payment instruments, it considers that access to cash is necessary to preserve the effectiveness of 

its legal tender status. If citizens do not have easy access to cash, they will not be able to use it as 

a means of payment 7. In this context, on 28 June 2023 the Commission published a proposal for a 

Regulation of the European Parliament and of the Council on the legal tender of euro banknotes and 

coins, which includes an obligation for euro area Member States to ensure sufficient and effective 

access to cash throughout their territory 8. 

2.3  While the official currency in Hungary is the forint, not the euro, the ECB considers it important that 

all Member States, including non-euro area Member States, take appropriate measures to ensure 

that credit institutions and branches operating within their territories provide adequate access to cash 

services, in order to facilitate the continued use of cash9. The ECB therefore welcomes the initiative 

of  the  MNB  to  regulate  the  infrastructure  network  of  credit  institutions  used  to  carry  out  cash 

transactions and facilitate cash flows with the objective of ensuring a minimum level of availability of 

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See  paragraph  2.3  of  Opinion  CON/2023/25  and  paragraph  2.1  of  Opinion  CON/2023/39.  All  ECB  opinions  are 
available on EUR-Lex. 
See  paragraph  2.1  of  Opinion  CON/2023/13,  paragraph  2.3  of  Opinion  CON/2023/25,  paragraph  2.1  of  Opinion 
CON/2023/39, paragraph 2.2.1 of Opinion CON/2023/40 and paragraph 2.1 of Opinion CON/2024/1. 
See paragraph 2.1 of Opinion CON/2023/39, paragraph 2.2.1 of Opinion CON/2023/40 and paragraph 2.1 of Opinion 
CON/2024/1. 
See paragraph 2.1 of Opinion CON/2023/39, paragraph 2.2.1 of Opinion CON/2023/40 and paragraph 2.1 of Opinion 
CON/2024/1. 
See paragraph 2.2 of Opinion CON/2023/25 and paragraph 1.2 of Opinion CON/2023/31. 
COM(2023) 364 final. For the ECB opinion on the proposal, see Opinion CON/2023/31. 

See paragraph 2.2 of Opinion CON/2020/21 and paragraph 3.3 of Opinion CON/2022/40. 

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cash for their customers throughout Hungary. The ECB also welcomes the particular attention given 

to refining the rules for cash desks at the branches of credit institutions as these in-person services 

are  more  inclusive,  contribute  to  a  more  resilient  cash  supply  in  times  of  crisis  and  facilitate  the 

provision  of  services  that  cash  dispensers  cannot  provide,  such  as  the  exchange  of  damaged  or 

mutilated banknotes. 

This opinion will be published on EUR-Lex. 

Done at Frankfurt am Main, 6 February 2024. 

[signed] 

The President of the ECB 

Christine LAGARDE 

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