REPORT FROM THE COMMISSION TO THE COUNCIL on the cost benefit analysis of the use of the central account referred to in Article 9(1)(c) of the Council Regulation (EU, Euratom) No 609/2014 of 26 May 2014.
Date: 2025-04-10
Institutions: Directorate-General for Budget, European Commission
Subjects: EU Member State, EU budget, GNP contribution, Member States' contribution, VAT resource, budget policy, central bank, cost-benefit analysis, financial control

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 10.4.2025  COM(2025) 161 final  REPORT FROM THE COMMISSION TO THE COUNCIL on the cost benefit analysis of the use of the central account referred to in Article 9(1)(c) of the Council Regulation (EU, Euratom) No 609/2014 of 26 May 2014.   {SWD(2025) 79 final}  
 
 
1.  SECTION I – BACKGROUND TO THE REPORT  

This report is issued in accordance with Art. 9 of the Council Regulation (EU, Euratom) 
No 609/2014 of 26 May 2014 (1), hereafter MAR Regulation. The main objective of this 
document  is  to  present  a  cost-benefit  analysis  to  the  Council  regarding  the  potential 
implementation of a central account as defined in Art 9(1)(c) of MAR Regulation. This 
central account would be opened by the Commission in the public financial institution of 
its choice for the collection of own resources. 

This  report  includes  a  cost-benefit  analysis  of  the  selected  treasury  models  that  the 
Commission evaluated, namely:  

- 

central account model held in the European Central Bank (ECB) in compliance 
with the new Art. 9(1)(c).  

-  Optimised Treasury model, which involves three central cash holding accounts 
held in the chosen national central banks, option outside the scope of the new 
provisions of Art. 9 MAR.  

1.1.  Architecture of the European Commission (EC) treasury 

The  key  characteristics  of  the  Commission  treasury  architecture  are  determined  by  the 
provisions of Art. 9(1) MAR Regulation.  

Up until 2022,  the MAR Regulation allowed Member States to credit own resources (OR) 
to two different types of accounts opened in the name of the Commission: 

•  Type  1:  national  treasuries.  In  this  case,  Member  States  make  own  resources 
contributions  available  to  the  Commission  first  in  accounting  terms  and  gradually, 
upon reception of transfer instructions from the Commission in cash. 

•  Type  2:  national  central  banks.  In  this  case,  Member  States  make  available  the 

totality of the requested contribution in cash. 

The accounts of type 1 and 2 are kept in national currencies.  

Council  Regulation  (EU,  Euratom)  2022/615  of  5  April  2022  amending  the  MAR 
Regulation, introduced a third type of account which allows for the use of a new central 
account for crediting own resources, opened by the Commission in the public financial 
institution of its choice.  

In the period from 2014 to 2022, the EC treasury operations were primary influenced by 
two key factors: 

– 

formalistic implementation of Art. 14(1) of MAR Regulation, 

(1)  Council Regulation (EU, Euratom) No 609/2014 of 26 May 2014 on the methods and procedure for 
making available the traditional, VAT and GNI-based own resources and on the measures to meet cash 
requirements  (Recast)  OJ  L  168,  7.6.2014,  p.  39,  amended  by  Council  Regulation  (EU,  Euratom) 
2022/615 of 5 April 2022 OJ L 115 p. 51. 

 
 
 
– 

the ECB decision to introduce its negative interest rate policy (NIRP) starting from 
11 June 2014.  

In  view  of  safeguarding  the  EU  assets,  the  Commission  took  necessary  measures  to 
minimise  the  impact  of  negative  interests.  To  this  end,  between  2014  and  2022,  the 
Commission  endeavoured  to  keep  the  funds,  as  far  as  possible,  within  the  national 
treasuries and central banks where they were free of any charge or interests. In parallel, in 
compliance with Art. 14(1) of MAR Regulation, all payment accounts held in commercial 
banks were replenished daily from the own resources accounts on the basis of the amount 
of payments to be executed from each of them, The cash buffers held in those banks were 
kept at the minimum level to avoid excessive overnight balances and thus lower the impact 
of negative interests while ensuring business continuity of payment transactions. 

All  these  operations  generated  a  considerable  number  of  daily  inflows  into  national 
treasuries  and outflows from other Member States. Moreover, the lack of a bigger cash 
buffer was also impacting the Commission’s ability to execute urgent payments.  

Therefore, in view of reducing complexity of the cash flows and addressing Member States 
concerns,  the  Commission  proposed  in  2021  to  include  in  the  MAR  Regulation  the 
possibility to credit own resources to a new central account opened for this purpose by 
the Commission (Article 9(1)(c) of the MAR Regulation).  

In parallel to the central account proposal, the Commission tabled a provision to provide 
Member  States  with  forecasts  of  the  cash  resources  requirements  for  the  following 
4 months to  further increase the predictability  of cash movements (Article 9(2a) of the 
MAR Regulation). 

In accordance with Article 9(1) of the MAR Regulation, Member States’ participation in 
the  centralised  model  is  to  be  done  on  voluntary  basis.  Moreover,  the  Commission  is 
required  to  produce  cost  benefit  analysis  of  the  use  of  the  central  account  prior  to  its 
implementation.  

2.  SECTION  II-  COST  BENEFIT  ANALYSIS  (COMPARATIVE  ASSESSMENT  OF 

TWO DIFFERENT OPTIONS FOR TREASURY MODELS) 

This  exercise  aims  to  compare  two  models  for  the  European  Commission's  treasury 
management  within  the  framework  of  the  current  Multiannual  Financial  Framework 
(MFF) 2021-2027, considering the existing legal environment.  

2.1.  New treasury models – scenarios 

For the purpose of conducting a cost-benefit analysis on the use of the central account in 
accordance with the provisions of the MAR Regulation and in line with its counterparty 
risk  policy,  the  Commission  considered  only  public  financial  institutions  as  valid 
alternatives for holding this account. 

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Two types of public institutions were contemplated:  

•  European Central Bank (ECB) because it already acts as the cash manager of the 
NGEU liquidity resources and executes the RRF payments to the beneficiary Member 
States. 

•  National Central Banks (NCBs) as they are vital actors in the existing EC treasury 

architecture and cash management model. 

Based on this assumption the Commission proposed two different options for the central 
account management. 

Option 1: Central account in the European Central Bank (ECB)  

Based on the provisions of the newly introduced Art. 9(1)(c) MAR Regulation, the model 
consists  in  establishing  one  central  account  in  the  ECB  for  own  resources  and  other 
revenues paid in EUR and sub-accounts for own resources in each non-EUR currency.  

The implementation of this model envisages a gradual phasing out of the existing systems 
at Member State level. It would imply that making available resources in accounting terms 
first, as  currently  practiced by  the national  treasuries, would be replaced  by  the system 
where all participating Member States would provide their own resources by bank transfers 
on specific days. Amounts in EUR would be pooled in one central account set up by the 
Commission in the ECB. Non-EUR currencies contributions would be first channelled to 
the relevant sub-accounts established for this purpose with a Treasury or National Central 
Bank. The EUR central account would be mainly used to fund daily the bank accounts of 
the Commission from which it executes its payments in EUR. Moreover, the EUR central 
account could be used to execute direct payments to Member States, mainly to accounts 
held at national central banks.  

It should be noted that, pursuant to Art. 9(1) MAR Regulation this central account would 
need to be free of interest. In case of positive renumeration the interest would be distributed 
to Member States participating in this setup in proportion to their budgetary key. Funds 
pooled  in  the  account  would  be  also  safeguarded  from  potential  negative  interests  that 
would need to be covered by the Member State(s) concerned. 

The choice of the central account option would mostly impact Member States which make 
funds available to the Commission first in accounting terms and gradually, upon reception 
of  transfer  instructions  from  the  Commission  in  cash  (own  resources  accounts  kept  in 
Treasuries). In this case, Member States would need to transfer funds immediately instead 
of mobilizing the cash gradually over time. For Member States opting so far to maintain 
the own resources account in their national central bank, the switch to ECB option would 
have none to very limited impact.  

It should be noted that the ECB has not been formally requested and hence has not given 
its consent to provide extra services. 

Option  2:  Optimised  treasury  model  with  central  cash  holding  accounts in  chosen 

National Central Banks 

This model does not make recourse to the new provisions of Article 9(1)(c) of the MAR 
Regulation establishing a new central account. Conversely, it builds on existing treasury 
architecture and already well-established cash flows with the national central banks.  

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This model activates weekly transfers on designated days from  own resources  accounts 
(OR  accounts)  to  cash  holding  accounts.  The  cash  flows  from  OR  accounts  kept  in 
treasuries are channelled in compliance with the budgetary key only in one direction (from 
OR accounts towards cash holding accounts). Consequently, it should reduce considerably 
the overall number of cashflows on OR accounts kept in treasuries. The weekly transfers 
of own resources  would be coupled with  enhanced and  more precise forecasting  of  the 
funding needs performed on a weekly basis.  

2.2.  Methodology and evaluation criteria 

Recognizing  the  importance  of  effective  treasury  management  for  EU  policies,  the 
Commission developed qualitative and quantitative criteria to assess two central treasury 
options. These criteria specifically address Member States’ concerns about potential extra 
costs  under  the  revised  MAR  Regulation.  The  chosen  option  ensures  that  costs  remain 
equal to or lower than the current setup, while offering simpler cash flows and enhanced 
operational efficiency. 

The chosen criteria consist of: 

a)  Financial impact, it comprises the following components: 

•  Remuneration on cash deposits (estimation of generated positive and/or 

• 

negative interests) 
Service fee (cost of establishing account(s) and ongoing expenses incurred 
from day-to-day operations) 

b)  Technical infrastructure  

It examines the connectivity potential of the selected Options with existing technical 
set-up for the EC Treasury. 

c)  “Fit for purpose” in line with EC treasury architecture 

It explores compatibility of the selected Options  with EC Treasury characteristics 
(euro and non-euro contributions, multiple payments to beneficiaries), reduction of 
administrative burden, and synergies with existing cash flows patterns.  

2.3.  Assessment of the options against evaluation criteria 

2.3.1.  Financial impact  

The Commission has evaluated the potential financial impact of the two treasury models. 

For Option 1, the Commission used as a benchmark the conditions for the NGEU accounts 
held  with  the  ECB  for  the  purpose  of  implementation  of  the  European  Recovery 
Instrument.  

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For  Option  2,  the  Commission  examined  the  conditions  offered  by  a  selection  of  five 
National Central Banks (NCB) in the Eurozone. The ECB Guidance 2019/671(2) limited 
the remuneration of all non-monetary policy deposits. In 2024 the ECB guidelines were 
amended (3). Given the conditions in 2022, the Commission focused its analysis on the 
NCBs of the four biggest economies of the eurozone, namely Germany, France, Italy, and 
Spain. Moreover, given its geographical proximity essential for the EC Treasury’s business 
continuity, the Commission also considered the National Bank of Belgium. 

The two analysis elements taken into consideration were: 

-  Remuneration on cash deposits:  

The  analysis  showed  that  the  NCBs’  rates  were  all  aligned  with  the  ECB 
conditions. As a result, remuneration conditions offered in the two options were 
so similar that this factor would not influence the decision. 

-  Service fee:  

As the EC already holds accounts with NCBs, they would not charge additional 
fees for account maintenance. Furthermore, some NCBs would transfer funds 
for free, while others would charge a reduced transaction fee or charge a fix 
amount  for  unlimited  transactions.  In  contrast,  the  ECB  approach  could 
involve an initial set-up fee, and recurring fees for account management and 
payment-related services. 

In conclusion: 

o 

 Both  options  showed  similar  conditions  for  the  remuneration  on  cash 
deposits. However, Option 1 may entail higher initial setup and operational 
costs due to the creation of a new account model at the ECB. 

o  Option 2 proved more cost-effective, as existing relationships with NCBs 
meant  no  additional  account  maintenance  fees  or  significant  operational 
costs. 

2.3.2.  Technical infrastructure  

Option 1 The European Central Bank (ECB) has built a high-performance and specialized 
technical  infrastructure  that  is  tailored  to  the  monetary  framework  and  regulatory 
environment  of  the  Eurozone.  This  design  aligns  closely  with  the  specific  monetary 
policies, financial systems, and legal statutes of its member states, relying on tools like the 
TARGET2 payment system to enable large-scale cross-border euro transactions between 
members  of  the  European  System  of  Central  Banks  and  facilitate  wholesale  market 
transactions with large financial institutions. The primary focus of this architecture is to 
maintain financial stability and support effective transmission of the euro-area monetary 

(2)  Guideline (EU) 2019/671 of the European Central Bank of 9 April 2019 on domestic asset and liability 

management operations by the national central banks (recast), OJ L 113/11, 29.4.2019.  

(3)  Decision (EU) 2024/1209 of the European Central Bank of 16 April 2024 on the remuneration of non-
monetary  policy  deposits  held  with  national  central  banks  and  the  European  Central  Bank 
(ECB/2024/11) OJ L 2024/1209 3.5.2024. 

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policy.  The  ECB’s  infrastructure  is  not  designed  to  handle  directly  individual 
multicurrency  cash  payments  of  market  actors  or  institutions  such  as  the  European 
Commission. The layers of functionality needed to provide directly such payment services 
—such  as  dynamic  multi-currency  interoperability  and  integration  with  external 
commercial platforms—are not in place and would need to be further analysed and built 
entailing costs noting that no such prior request has been made to the ECB. (4) 

Option 2 had no adverse technical impact on the Commission’s accounting system. The 
existing technical solution is well-established, efficient, and seamlessly accommodates the 
inclusion of the Central Account model without any modifications. The chosen national 
central banks maintain a commercial layer that enables automated communication with the 
EC Treasury via Swift services. Consequently, this option would not necessitate additional 
development by the Commission. 

In conclusion: 

o  Option 1 faced technical challenges because the ECB’s infrastructure is not 
designed  to  handle  directly  individual  multicurrency  cash  payments  
of market actors or institutions such as the European Commission.  

o  Option  2  posed  no  technical  disruptions,  as  NCBs  use  well-integrated 

systems aligned with the Commission's current infrastructure. 

2.3.3.  “Fit for purpose” in line with EC treasury architecture  

For Option 1 the analysis revealed that establishing non-euro sub-accounts within the ECB 
would  be  challenging.  To  address  the  non-euro  dimension,  the  ECB  suggested  a 
differentiated approach depending on the nature of the accounts. This scenario foresees 
one EUR account for all EUR contributions and one account for each non-EUR currencies 
used (7 accounts). However, this approach would offer only limited simplification of cash 
flows, particularly due to the voluntary nature of Member States' participation. 

Option 2, featuring central cash holding accounts in the selected national central banks. 
builds on the existing EC treasury architecture. It preserves a well-established model of 
cash flows and non-euro conversions of own resources while creating synergies for euro-
denominated other resources. Therefore, it has no adverse impact for the EC Treasury or 
Member States in terms of additional administrative or operational burden.  

The centralization of flows into just a few cash holding accounts would reduce bank-to-
bank transfers between OR accounts in treasuries and central banks’ accounts. 

In conclusion: 

o  Option  1  had  limitations  due  to  the  requirement  of  separate  accounts  to 

accommodate non-euro transactions efficiently.  

(4)  The crucial role that the ECB has played since 2020 as fiscal and paying agent for the EU debt issuance 
and management programme builds on the ECB’s infrastructure and capacities in the implementation of 
monetary policy. 

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o  Option 2 was more coherent with established processes, offering synergies 
without  adding  administrative  burdens  on  the  EC  Treasury  or  Member 
States. 

2.4.  Conclusions: Choice of the treasury model 

Both options offer efficiency gains and operational enhancements for the internal processes 
related to the cash flows and account management.  

However,  Option  2  stands  out  as  the  preferable  choice  as  it  builds  on  the  established 
treasury  framework,  which  minimizes  transition  costs  and  operational  disruptions.  This 
optimization  aligns  with  sound  financial  management,  ensuring  effective  asset 
management aligned with EU policy objectives. 

Moreover, Option 2 meets Member State’s expectations by enhancing the predictability 
and transparency of cash movements in national treasuries. Over  the past two years the 
Commission  has  implemented  Option  2  as  a  strategic  enhancement  to  its  treasury 
management,  addressing Member States’ concerns while strengthening the EU's financial 
infrastructure.  

The Commission recommends  maintaining the Option  2 as  a cost-effective solution  for 
cash  management  system.  Given  the  current  EU  budget  structure  and  operational 
framework, this remains the most suitable approach. Depending on future budgetary and 
economic  developments,  further  refinements  and  assessments  may  be  carried  out  if 
necessary, including in the context of the next Multiannual Financial Framework. 

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