COMMISSION STAFF WORKING DOCUMENT Accompanying the document 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  SWD(2025) 79 final  COMMISSION STAFF WORKING DOCUMENT Accompanying the document 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    {COM(2025) 161 final}  
 
 
Table of Contents 

INTRODUCTION .......................................................................................................................... 2 

1. 
SECTION I -Background to the report ............................................................................ 4 
1.1.  EU budget its role and structure ............................................................................................ 4 
1.2.  Architecture of the EC treasury ............................................................................................ 4 
1.3.  Treasury model 2014-2022 ................................................................................................... 5 
1.4.  Revision of MAR .................................................................................................................. 6 

2. 

SECTION II- Cost Benefit Analysis (Comparative assessment of two different options 
for treasury models) ............................................................................................................ 7 
2.1.  New treasury models – scenarios .......................................................................................... 7 
2.2.  Methodology and evaluation criteria .................................................................................. 10 
2.3.  Assessment of the options against evaluation criteria ......................................................... 10 
Financial impact ................................................................................................. 10 
Technical infrastructure ..................................................................................... 11 
“Fit for purpose” in line with EC treasury architecture ...................................... 12 
2.4.  Conclusions: Choice of the treasury model ........................................................................ 12 

2.3.1. 
2.3.2. 
2.3.3. 

SECTION III-Implementation of the optimised treasury model.................................. 13 
3. 
3.1.  Context ................................................................................................................................ 13 
3.2.  Milestones for implementation of the Optimised treasury model ....................................... 13 
Selection of three banks for cash holding accounts ........................................... 13 
3.2.1. 
3.2.2.  Weekly transfers ................................................................................................ 14 
Four months forecasts of the cash resource requirements .................................. 15 
3.2.3. 
Building trusted relationship with the Members States’ Treasuries ................... 15 
3.2.4. 
3.3.  Outcomes ............................................................................................................................ 16 
Final considerations ............................................................................................................ 19 
3.4. 

 
 
 
 
 
 
INTRODUCTION 

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 the 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. 

In  2020,  against  the  backdrop  of  the  growing  ‘galaxy’  of  financing  instruments  (new 
external assigned revenues, UK contributions, NGEU etc.) and the ensuing complexity of 
the budgetary flows, the Commission undertook internal reflection on simplification of the 
Commission  treasury  architecture  and  optimisation  of  the  treasury  management  model. 
This  effort  culminated  in  2021  during  the  revision  of  MAR  Regulation,  with  the 
Commission proposing that Member States have the option to credit own resources to a 
new central account established by the Commission.  

In  2022,  the  new  provisions  on  the  voluntary  central  account  for  own  resources  were 
adopted.  In  parallel,  the  Commission  was  requested  to  produce  a  report  on  the 
implementation of the said account within 3 years of the entry into force of the Regulation. 

This  report  includes  a  cost-benefit  analysis  of  the  selected  treasury  models  that  the 
Commission evaluated to determine an optimal solution to implement the central account 
model, 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 (NCBs), option outside the scope of the 
new provisions of Art. 9 MAR. 

The  report  lays  out  the  advantages  of  the  chosen  Optimised  Treasury  model  from  the 
perspective of the EC Treasury and Member States. 

the  report  outlines 

implementation  
Finally, 
of the Optimised treasury model highlighting its main achievements in the context of the 
Member States’ expectations, new economic environment, and political challenges.  

the  key  developments  related 

to 

(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. 

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The report consists of three sections: 

Section  I  presents  the  EC  treasury  architecture  and  major  cash  flows  patterns.  It  also 
describes the EC treasury architecture in the period 2014- 2022 and implications of the 
negative interest environment. Furthermore, it outlines the context of the MAR Regulation 
revision in 2021 against the backdrop of the Member States’ concerns.  

Section II contains cost benefit analysis of two new treasury models assessed against the 
chosen criteria. 

Section III outlines the key developments in implementation of the Optimised treasury 
model.  

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1.  SECTION I -BACKGROUND TO THE REPORT 

1.1.  EU budget its role and structure 

The  EU  budget  plays  a  crucial  role  in  delivering  on  EU  priorities  and  addressing  the 
political, social, and economic challenges the EU faces. It is largely financed through Own 
Resources,  which  comprise  Member  States’  contributions  based  on  their  gross  national 
income, value-added tax-based resources, customs duties and non-recycled plastic. 

Over the last two decades, the EU’s public finances have been bolstered by the introduction 
of new off-budget  financing  mechanisms in  response to  various political and economic 
developments. Consequently, the array of financing instruments has become increasingly 
complex. 

Under Article 317 TFEU (2) the Commission is responsible for implementing the budget 
in accordance with the Financial Regulation and within the limits of the appropriations, 
adhering to the principles of sound financial management. 

The  current  EU  long-term  budget  2021-2027  has  been  established  for  €2.07  trillion  in 
current  prices  including  €807  billion  under  the  extraordinary  recovery  instrument  Next 
Generation EU financed through borrowing operations.  

In 2024, during the budget implementation process, the EC Treasury made approximately 
2.800.000 payments to third parties. 

To manage its treasury operations effectively the Commission has established elaborate 
systems for cash flows (receipts and payments), the opening and running of bank accounts, 
cash forecasting and liquidity management.  

1.2.  Architecture of the EC treasury 

The  key  characteristics  of  the  Commission  treasury  architecture  are  determined  by  the 
provisions of Art. 9(1) MAR Regulation granting Member States the possibility to credit 
own resources twice per month 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 requested contribution in cash. 

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

The third option, introduced in 2022, is a central account opened by the Commission for 
crediting Own Resources in the public financial institution of its choice. It has not yet been 
applied and will be discussed further on in this paper.  

(2)  Treaty on the Functioning of the European Union, consolidated version: OJ C 202, 7.6.20 

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Member States implement variations of these models, such as: 

•  Maintaining EUR accounts at the central bank, 
•  Holding EUR accounts at both the national treasury and the central bank, 
•  Using national non-EUR currency accounts at the central bank, with external 

currency conversions, 

•  Operating both national currency and EUR accounts at the central bank or 

treasury, where currency conversions occur centrally, 
•  Relying on a single EUR account at the national treasury. 

The complexity of the Commission treasury system also arises from the need of keeping 
the available funds in Own Resources (OR) accounts to comply with the provisions of the 
MAR  Regulation  on  not  drawing  funds  in  excess  of  payment  needs  (Art. 14(1))  and 
ensuring a fair distribution of weighted balances among the Member States to respect the 
budgetary key principle (Art. 14(4)).  

The major cash flows are mostly related to the execution of payments in EUR and non-
EUR currencies, to third party beneficiaries and to Member State public authorities. 99,8% 
of payments, representing 24,9% of the total value, are executed through accounts held by 
the Commission with commercial banks. The remaining 0.2% of payments, representing 
75.1% of the total value, are executed directly from OR accounts held in national treasuries 
or via central banks.  

Apart from the transfers needed to meet payment requirements, a considerable number of 
treasury  movements  are  triggered  by  the  rebalancing  exercise,  conversion  of  non-euro 
currencies, and receipt of off-budget revenues. 

Despite  this  complexity,  the  Commission  has  consistently  ensured  effective  treasury 
management  in  compliance  with  the  existing  regulatory  framework,  continuously 
delivering on its key objectives: 

Timely and secured execution of payments,  

• 
•  High degree of reliability and automation of operations,  
• 
•  None of the accounts opened in accordance with the Financial Regulation is in debit 

Sound cash and financial management, 

1.3.  Treasury model 2014-2022 

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

One of the key principles of sound financial management of the EC treasury is to preserve 
the EU financial assets. Pursuant to Art. 9(1) of the MAR Regulation the own resources 
contributions credited in national treasuries and central banks are kept free of any charge 
or  interest.  Where  negative  interest  is  applied  to  those  accounts,  the  Member  State 

Page 5/19 

 
 
 
concerned shall credit the account with an amount corresponding to the negative interest 
applied.  

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 compliance 
with Art. 14(1) of MAR Regulation all payment accounts held in commercial banks were 
replenished daily from the OR accounts based on the number 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. 

Furthermore,  to  comply  with  Art.  14(4)  of  MAR  Regulation,  the  EC  Treasury  used  to 
perform  twice  per  month,  after  the  execution  of  European  Agricultural  Guarantee  fund 
(EAGF) payments and around the middle of the month, the alignment exercise consisting 
in rebalancing the overall assets, as far as possible, in proportion to each Member State 
contribution to the budget.  

All  these  operations  generated  a  considerable  number  of  daily  inflows  into  National 
Treasuries and outflows from other Member States. The consequence of those transfers 
was a high number of transactions within the complex Treasury architecture resulting in 
an insufficient predictability and limited transparency of cash flows for Member States.  

Moreover, the lack of a bigger cash buffer was also impacting the Commission’s ability to 
execute urgent payments due to regulatory limitations of payment instructions execution 
by Member States. Pursuant to Article 15 of MAR Regulation, the transfers from and to 
OR accounts should be done within three days’ notice. In case of an urgent payment that 
needed to be executed within one day, and exceeded the existing operational balance, the 
EC Treasury struggled to meet the deadline. 

1.4.  Revision of MAR 

The  traditional  treasury  model  applied  until  2022  has  undoubtedly  proven  its  value  in 
effective management of the EU funds. However, the growing number of various financing 
resources (new external assigned revenues, UK contributions, NGEU etc.), coupled with 
challenging negative interest conditions, rendered the existing model increasingly complex 
and thus required significant operational efforts on part of the Commission to manage it 
effectively.  

Moreover, as described in Section 1.3, this model was generating a considerable number 
of daily cash flows on OR accounts kept in the national treasuries. It also required some of 
the national treasuries to hold a larger cash surplus buffer to meet the Commission’s cash 
requirements.  In  this  context,  several  Member  States  voiced  their  concerns  about 
insufficient predictability of cash movements and considered improvements in this area as 
a priority.   

Therefore, the Commission proposed to include in the MAR Regulation the possibility to 
credit own resources to a new central account opened for this purpose by the Commission.  

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This proposal aimed to achieve: 

•  Clear predictability and transparency of cash movements for Member States (i.e. cash 

movements = call for funds), 
Shorter payment delays and alignment with standard treasury practices, 

• 
•  Ability to operate with lower overall treasury balance leading to decreased needs for 

calling advanced twelfths.  

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. 

Member States’ participation in the centralised model would be done on voluntary basis. 
Moreover, Member States requested that the Commission prepares a 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 MAR Regulation and in line with its counterparty risk 
policy, the Commission considered only public financial institutions as valid alternatives 
for holding this account. 

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 currencies. 
Opting in for this centralised account would be voluntary for Member States. 

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Figure 1. Central account in ECB. 

The model's implementation calls for a gradual elimination of the current dual system—
namely, the OR accounts held by treasuries or central banks—at the Member State level.  
This would mean replacing the current practice—where national treasuries make resources 
available in accounting terms—with a system in which each participating Member State 
contributes its own resources via bank transfers on specified dates, in line with Art. 6(3) 
MAR. Under this model amounts in EUR would be pooled in one central account set up 
by  the  Commission  in  the  ECB  and  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. Based on 
that funding, the Commission would instruct its banking partners to execute the payments 
to its beneficiaries.  

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 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 could mostly impact Member States which make 
funds available in accounting terms first, as instead of mobilizing the cash gradually over 
time, funds would need to be transferred immediately. 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. 

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

  National Central Banks 

This  solution  does  not  make  recourse  to  the  new  provisions  of  Article  9(1)(c)  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.  

It notably envisages reengineering existing processes by:  

• 

• 
• 
• 

channelling part of Own Resources and other revenues to non-Own Resources cash 
holding accounts in the selected national central banks,  
enhancing cash needs forecasting,  
reinforcing cash management component in the rebalancing exercise, 
simplification of the existing complex treasury architecture. 

Figure 2. Optimised treasury model with central cash holding accounts.  

This  model  activates  weekly  transfers  on  designated  days  from  OR  accounts  to  cash 
holding  accounts,  tailored  to  meet  Commission  payment  requirements.  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.  

It should be noted that this centralisation of cash flows is achieved outside the scope of the 
new provisions of Art. 9 MAR Regulation. Therefore, the central cash holding accounts 
kept in the chosen central banks are not OR  accounts. Consequently, they can generate 
interests  in  the  positive  interests’  environment  that  would  be  returned  to  the  budget, 
whereas in the reverse economic conditions, they may be subject to negative interests that 
are not covered by Member States.  

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2.2.  Methodology and evaluation criteria 

Given the importance that effective treasury management plays in the implementation of 
EU policies, the Commission  established criteria to  make  a qualitative and quantitative 
assessment of the two chosen central treasury options. The criteria have been calibrated 
specifically  to  address  the  Member  States'  concerns  regarding  any  potential  additional 
costs that the new models might entail, as voiced during the process of adopting the revised 
MAR Regulation. In the selected option, the overall costs for the EC Treasury should be 
equal  to or lower than  those in the  current setup, while also  generating additional 
benefits of simplification of cash flows and enhanced operational efficiency.  

The chosen criteria consist of: 

a)  Financial impact that 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.  

For  Option  2,  the  Commission  examined  the  conditions  offered  by  a  selection  of  five 
National  Central  Banks  in  the  Eurozone.  The  ECB  Guidance  2019/671(3)  limited  the 
remuneration of all non-monetary policy deposits at the level of 0.04 % of the GDP of its 
Member State. In 2024 the ECB guidelines were amended (4) Given the conditions in 2022, 
the  Commission  focused  its  analysis  on  the  NCBs  of  the  four  biggest  economies  

(3)  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.  

(4)  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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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 (cost of operational and system set-up for establishing account(s) and 

costs incurred from day-to-day transfer operations) 

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,  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.  Therefore,  Option 2  turns  out  to be  
a  more  cost-effective  solution  as  it  does  not  involve  any  additional  costs  for  the 
Commission or Member States. 

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 
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 prior request has been made to the ECB. (5) 

Option 2 had no adverse technical impact on the Commission’s accounting system. The 
existing  technical  solution  is  well-established,  efficient,  and  seamlessly  accommodates  

(5)  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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the inclusion of the Central Account Model without any modifications. The chosen NCBs 
maintain a commercial layer that enables automated communication with the EC Treasury 
via  Swift  services.  Payment  messages  are  generated  directly  from  the  Commission’s 
Accounting  system.  Consequently,  this  option  would  not  necessitate  additional  testing  
or development by the Commission. 

In conclusion, given the challenges in establishing new layers of connectivity, Option 2 
turned out to be much less resource and cost demanding comparing to Option 1.  

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  proposed  opening 
specific accounts in the respective central banks. This scenario foresees one EUR account 
for all EUR contributions and one account for each non-EUR currencies (7 accounts). As 
there would be only 8 accounts to manage in total versus currently 27 OR accounts it would 
entail  less  bank-to-bank  transfers  hence  less  potential  manual  reconciliations  of  bank 
transfers. 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 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.  

Moreover, this model could even enhance efficiency of operations.  As the Member States’ 
treasuries do not use the SWIFT connectivity 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. It would in turn lead to less manual bank statements 
and increased automation. 

In  conclusion,  both  options  would  generate  operational  efficiencies  in  the  account 
management  by  the  EC  treasury.  However,  for  Option  1  the  analysis  reveals  that 
establishing non-euro sub-accounts in the ECB would be challenging. Hence this solution 
would not advance a real simplification of cash flows.  

2.4.  Conclusions: Choice of the treasury model 

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

The  Commission  believes  that  significant  benefits  under  Option  1  would  only  be 
achievable if many Member States participate, ensuring that the majority of OR are pooled 
in the centralised account. 

A differentiating factor is cost, which is significantly lower for Option 2 compared to the 
fees the ECB may charge for establishing a new account model and providing operational 
services under Option 1. The impossibility of opening non-euro accounts at the ECB is an 
obstacle to achieving a simplification of cash flows. 

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Moreover, the technical infrastructure for the cash flows management in the ECB is not 
“fit for purpose”.  

Therefore,  based  on  the  above  analysis  of  the  two  scenarios,  the  chosen  solution  is 
Option 2 - Optimised  treasury model. This option  developed over the  past  two years 
capitalises  on  existing,  well-established  processes  while  bringing  forward  incremental 
changes  to  further  optimise  the  Commission's  treasury  management  and  effectively 
respond to Member States expectations. 

It is a cost-effective solution, compliant with the principle of sound financial management, 
allowing for efficient asset management with the possibility for additional returns if market 
conditions allow. 

3.  SECTION III-IMPLEMENTATION OF THE OPTIMISED TREASURY MODEL 

3.1.  Context 

The internal assessment of various scenarios for a more efficient treasury model coincided 
with  external  factors  that  reinforced  the  EU  Commission’s  determination  to  pursue  its 
project of the centralized treasury model. 

In  autumn  2022,  the  market  conditions  for  deposits  changed  following  the  Decision 
2022/1521 of ECB of 12 September 2022 on temporary adjustments to the remuneration 
of certain non-monetary policy deposits held with national central banks and the European 
Central Bank (6). The remuneration of deposits in NCBs became positive for the first time 
since 2014. 

Furthermore, the political situation of war in Ukraine demanded increased financial effort 
on EU part and swift disbursement of funds in response to ensuing civilian and military 
crisis. For EC treasury it implied the necessity to create a cash buffer that would make the 
EU funds instantly available to execute urgent payments.  

In  addition,  the  creation  of  a  cash  buffer  became  even  more  important  for  business 
continuity  reasons  in  the  event  of  a  potential  system’s  disruption  in  the  climate  of 
heightened geopolitical tensions and increased risk of systemic cyberattacks. 

3.2.  Milestones for implementation of the Optimised treasury model  

3.2.1.  Selection of three banks for cash holding accounts  

In September 2022, the Commission decided to proceed with the selection of central banks 
for the centralization of flows. As explained in Section 2.3.1, in terms of the remuneration 
all considered banks were in line with the ECB’s guidelines. In view of a selecting cash 
holding  accounts,  there  was  therefore  no  incentive  in  spreading  the  cash  flows  across 

(6)  Decision  (EU)  2022/1521  of  the  European  Central  Bank  of  12  September  2022  on  temporary 
adjustments to the remuneration of certain non-monetary policy deposits held with national central banks 
and the European Central Bank (ECB/2022/30), OJ L 2361, 13.09.2022. 

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multiple NCBs. Consequently, the Commission decided to pursue with two banks with the 
best operational conditions and additionally retain one more geographically closest bank 
for the business continuity reasons.  

The following conditions were considered in the bank selection process:  

• 
• 
• 
• 

established treasury cash flows,  
technical compatibility, 
cash deposit capacity,  
business continuity. 

Given  the  above-mentioned  criteria,  the  Commission  has  decided  to  entrust  the 
management of cash holding accounts to: Deutsche Bundesbank, Banque de France and 
National Bank of Belgium, whose business and technical profiles best correspond to the 
critical requirements for the EC Treasury. 

Deutsche  Bundesbank  is  the  central  bank  of  the  biggest  contributor  to  EU  budget.  It 
implies processing large part of EU  funds  and handling high  amount of  cash  flows, on 
average 934 transactions for an amount of EUR 139 billion per year. Its broad connectivity 
with EC banking partners around Europe historically facilitated channelling most transfers 
from Member States’ national banks through it. Moreover, considerable amount of the EC 
external  revenues  (ETS,  NGEU  top-ups)  is  routed  through  the  flows  established  with 
Deutsche Bundesbank.  

Banque de France as the central bank of the second biggest contributor to EU budget, is 
involved in processing large part of EU funds and significant amount of cash flows. They 
amount to approximatively 436 transactions on average for an amount of EUR 25 billion 
per  year.  Banque  de  France  has  been  historically  used  for  conversions  of  non-euro 
currencies.  Furthermore,  over  many  years,  the  European  Development  Fund  has  been 
routed through it. Since 2020, to diversify the risk exposure, the UK contributions have 
also started to being channelled to EU budget through Banque de France.  

The geographic proximity of National Bank of Belgium ensures business continuity for 
the EC treasury in the event of any IT/SWIFT system disruptions, which supported the 
decision  to  select  this  bank  for  holding  a  cash-holding  account.  Furthermore,  the  bank 
handles  high  amount  of  cashflows  with  commercial  banks  executing  payments  and 
receiving receipts other than Member States’ contributions (approx. 213 transactions on 
average for an amount of EUR 49 billion per year). 

Since  October  2022  the  Commission  has  started  depositing  non  OR  receipts  (UK 
contribution, NGEU top-ups, ETS) in the central cash holding accounts to fund the paying 
accounts in the commercial banks.  

3.2.2.  Weekly transfers  

To reduce the frequency of cash movements, the Commission has implemented a system 
of weekly  transfers from  OR  accounts to cash holding accounts, based on the payment 
needs  for  that  week.  These  transfers  are  scheduled  on  fixed  days  and  adhere  to  the 
principle of the budgetary key of each Member State. This system has replaced the daily 
transfer model previously used by the Commission. 

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Figure 3. New optimized model of weekly funding. 

The  alignment  of  cash  balances  focuses  on  minimizing  transfer  outflows  and  reducing  
the  number  of  inflows  into  the  OR  accounts.  Funds  are  called  from  Member  States’ 
treasuries based on other revenue sources (non-Own Resources) held in the cash holding 
accounts.  

3.2.3.  Four months forecasts of the cash resource requirements  

Since mid-2022, the Commission has been transmitting monthly forecasts of cash resource 
requirements  for  the  upcoming  four  months  to  Member  States  electronically  via  the 
CIRCABC  platform.  Hence,  it  successfully  fulfilled  its  regulatory  obligations  set  in 
Art. 9(2)(a)  of  the  amended  MAR  Regulation.  These  forecasts  are  produced  based  on 
statutory contributions of Own Resources and Other Revenues and monthly estimates of 
structural spendings coupled with historical trends. 

The improvements in forecasting capability have significantly enhanced the predictability 
of the amounts and timing of cash transfers on OR accounts for Member States. 

3.2.4.  Building trusted relationship with the Members States’ Treasuries  

In  parallel  to  these  activities,  the  Commission  decided  to  initiate  a  pilot  project  with  a 
single Member State. The primary objectives were: 

•  Test  feasibility  and  effectiveness  of  the  new  Optimised  Treasury  model  for  cash 

management, 

•  Establish a reliable framework for forecasting and managing cash transfers, 
•  Gather detailed feedback to carry on with broader implementation of the model with 

all Member States, 

•  Assess the model’s impact on operational efficiency.  

In the context of bilateral consultations, the Treasury of Spain expressed its willingness to 
participate in this project with the EC Treasury.  

Consequently, the Commission established an open communication channel with the ES 
Treasury.  Over  a  period  of  nine  months,  the  Commission  was  exploring  the  possibility  

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of producing monthly forecasts of the cash requirements based on historical outflows and 
inflows and the projections for the structural funds spendings. Moreover, the Commission 
carried  out  tests  of  the  weekly  forecasts  of  movements  on  OR  accounts  and  applied 
adequate adjustments based on Member States feedback.  

Close cooperation and regular communication with the pilot Member State yielded positive 
results.  

The positive results and feedback from Spanish treasury paved the way for establishing 
close  cooperation  with  some  other  Member  States.  Until  the  date  of  this  report,  the 
Commission has engaged in an open dialogue with the National Treasuries of Germany, 
Belgium, France, and Italy.  

Open  communication  enabled  a  smooth  transition  to  the  Optimised  treasury  model, 
allowing  the  Commission  to  address  Member  States'  concerns  promptly  and  ensure 
transparency in cash management changes. The positive feedback from Member States’ 
treasuries highlighted the high level of trust and strong cooperation. 

3.3.  Outcomes  

The Optimised treasury model delivered positive outcomes for both Member States and 
the EC treasury operations. 

•  More predictability. 

The enhanced regular forecasting, combined with weekly transfers executed on fixed dates, 
has increased the level of predictability and visibility of cash management activities for 
Member States. 

This  model  has  led  to  a  significant  reduction  in  the  number  and  amounts  of  outgoing 
transfers from OR accounts. 

The number of outgoing transfers in the OR accounts decreased on average by  60 % 
between 2022 (previous model) and 2024 (Optimised Treasury model). 

Figure 4. Number of outgoing transfers in OR accounts.  

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In terms of volumes, the average reduction amounted to 48% in 2024 comparing to the 
previous model in 2022.  

Figure 5. Volumes of outgoing transfers in OR accounts.  

(Billion EUR) 2022-2024

s
n
o

i
l
l
i

B

40,00

35,00

30,00

25,00

20,00

15,00

10,00

5,00

0,00

Jan

Feb Mar Apr May

Jun

Jul

Aug

Sep Oct Nov Dec

2022

2024

The alignment of the Member States' contributions with the cash outflows implemented in 
the  Optimised  Treasury  model,  have  reduced  the  inflows  to  OR  accounts  held  in 
treasuries by 80% from 2022 to 2024 (figure 8).  

Figure 6. Number of cash inflows in OR accounts held in Treasuries.  

•  Efficiency gains 

There are also considerable operational efficiencies. As the Member States’ treasuries do 
not use the SWIFT connectivity, their bank statements are sent via other means and require 
a  manual  processing.  Thanks  to  the  centralization  of  flows  into  three  cash  holding 
accounts,  bank-to-bank  transfers  between  OR  accounts  in  treasuries  and  central  banks’ 
accounts have been reduced.   

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In 2024 the manually processed statements dropped by 23% compared to 2022. 

Figure 7. Number of manual statements.   

Reduction in the number of manual bank statements has led to a decrease of the need for 
manual  reconciliation  of  the bank transfers.  The  manual  operations  dropped  by  23% 
over the period 2022-2024.  

Figure 8. Manual reconciliation of bank transfers. 

•  Higher returns 

Furthermore,  the  favourable  market  conditions  have  allowed  for  the  new  Optimised 
treasury model  to  generate substantial  positive interests that will be  returned to  the EU 
budget. The turning point could be observed in the month of September of 2022 when the 
ECB  deposit  facility  rate  became  positive.  In  the  following  months,  the  first  positive 
interest was paid by the central banks based on their specific conditions. As of May 2023 
all banks concerned agreed on ESTR ON minus 20 basis points as recommended as ceiling 
by the Governing Council of the ECB in February 2023. This rate reached its highest level 
(with ESTR of around 3,9% ) from 20/09/2023 until 12/06/2024. The rate has decreased 
since then, while being still largely positive (around 2,7% at 07/02/2025).  

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3.4.  Final considerations  

In  compliance  with  the  requirements  of  Art.  9  MAR  Regulation  the  Commission  has 
conducted analysis of different treasury models that could effectively respond to political 
and economic challenges while safeguarding the principle of sound financial management.  

The  Optimised  treasury  model  is  the  most  cost-effective  solution  that  streamlined  the 
disbursement of funds and brought internal efficiencies.  It has significantly rationalised 
cashflows on OR accounts held in treasuries. The simplification and automation of treasury 
operations has led to a more robust and effective cash management system. 

In  parallel,  it  effectively  responds  to  Member  States  expectations  in  terms  of  enhanced 
predictability and transparency of cash movements  in  Member States’ treasuries.  It has 
also proven effective in addressing political challenges. 

Furthermore,  the  favourable  market  conditions  have  allowed  for  the  new  Optimised 
treasury model  to  generate substantial  positive interests that will be  returned to  the EU 
budget.   

Given the specificities of the Commission and the Member States treasury management, 
the Commission recommends maintaining Optimised treasury model, solution outside the 
scope of the new provisions of Art. 9 MAR, as an overall the most viable and efficient 
option.  

The  Optimised  treasury  model  remains  the  most  suitable  approach  given  the  current 
structure and operational framework of the EU budget. 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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