Opinion of the European Central Bank of 14 August 2025 on implementing measures concerning access to cash (CON/2025/22)
Date: 2025-08-14
Institutions: European Central Bank
Subjects: legal basis, money

ECB-PUBLIC 

EN 

OPINION OF THE EUROPEAN CENTRAL BANK 

of 14 August 2025  

on implementing measures concerning access to cash 

(CON/2025/22)  

Introduction and legal basis 

On 16 July 2025, the European Central Bank (ECB) received a request from the Irish Minister for Finance 

(hereinafter the ‘Minister’) for an opinion on a draft Finance (Provision of Access to Cash Infrastructure) 

(Section 5) Order 2025 (hereinafter the ‘first draft law’) and a draft Finance (Provision of Access to Cash 

Infrastructure) (Section 10) Order 2025 (hereinafter the ‘second draft law’, and together with the first draft 

law, the ‘draft laws’).  

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  Article  2(1),  first, second  and third indents, of Council Decision 
98/415/EC1, as the draft laws relate to currency matters, means of payment and the Central Bank of Ireland 
(CBI). In accordance with Article 17.5, first sentence, of the Rules of Procedure of the European Central 
Bank, the Governing Council has adopted this opinion. 

1. 

Purpose of the draft laws 

1.1  The overall purpose of the draft laws is to implement certain aspects of the Finance (Provision of 

Access to Cash Infrastructure) Act 2025 (hereinafter the ‘2025 Act’) 2.  

1.2  The first draft law implements the provision of the 2025 Act3 that requires the Minister, in consultation 
with  the  CBI,  to  specify  criteria  to  ensure  sufficient  and  effective  access  to  cash  infrastructure  in 
respect of each of the eight NUTS 3 regions in Ireland4 (hereinafter the ‘access to cash criteria’). The 
access  to  cash  criteria  must  specify:  (a)  the  minimum  percentage  of  the  population  of  the  region 

concerned  that  ought  to  be  within  a  radius  of  not  less  than  5  kilometres  and  not  more  than  10 

kilometres of an automated teller machine (ATM); (b) the minimum number of ATMs that ought to be 

available  per  100  000  people  in  the  region  concerned;  and  (c)  the  minimum  percentage  of  the 

population of the region concerned that ought to be within a radius of not less than 5 kilometres and 

not more than 10 kilometres of a cash service point. In setting the access to cash criteria the Minister 

must  take  into  account:  (a)  the  need  to  ensure  the  continued  provision  of  sufficient  and  effective 

access to cash for individuals and SMEs, and (b) in the case of the first draft law, the level of access 

1  

2  

3  
4  

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, ELI: http://data.europa.eu/eli/dec/1998/415/oj). 
The  Finance  (Provision  of  Access  to  Cash  Infrastructure)  Act  2025  was  adopted  by  the  Oireachtas  (Irish  National 
Parliament) on 20 May 2025.  
See section 5 of the 2025 Act.  
The NUTS 3 regions are those regions which have been established for statistical purposes, as set out in Annex I to 
Regulation (EC) No 1059/2003 of the European Parliament and of the Council of 26 May 2003 on the establishment 
of  a  common  classification  of  territorial  units  for  statistics  (NUTS)  (OJ  L  154,  21.6.2003,  p.  1,  ELI: 
http://data.europa.eu/eli/reg/2003/1059/oj ). The eight NUTS 3 regions in Ireland are: Border, West, Mid-West, South-
East, South-West, Dublin, Mid-East, Midlands. 

 
 
 
 
 
 
ECB-PUBLIC 

to the cash infrastructure available to individuals and SMEs as at 31 December 2022, adjusting for 
the exit of two banks from the Irish market: Ulster Bank Ireland DAC and KBC Bank Ireland plc 5. On 
that basis, the first draft law proposes, in respect of each NUTS 3 region in Ireland, the access to 

cash criteria of: (a) a specified percentage of the population that must be within a radius of no more 

than 10 kilometres of an ATM, ranging from 96 % to 100 %; (b) a minimum number of ATMs per 100 

000 people, ranging from 73 to 94; and (c) a specified percentage of the population that must be 
within a radius of no more than 10 kilometres of a cash service point, specified at 100 % or 99 %6. 
As outlined in the consultation letter from the Minister, the access to cash criteria in the first draft law 

are indicative and will be finalised following consultation with the CBI.   

1.3  The second draft law implements the provision of the 2025 Act that concerns the designated entities 
responsible  for  maintaining  access  to  cash  levels  in  Ireland 7.  Designated  entities  are  credit 
institutions that meet certain conditions as outlined in the 2025 Act. These conditions are met where, 

for two consecutive quarters, a credit institution holds (a) a percentage share of current accounts in 

Ireland, and (b) a percentage share of household deposits in Ireland. The 2025 Act empowers the 

Minister, following consultation of the  CBI, to set the  percentage shares for current accounts and 

household  deposits,  respectively.  The  respective  percentage  shares  must  be  set  between  the 

following ranges: (a) at least 5 % and not greater than 15 % of the total number of current accounts 

of credit institutions in Ireland; and (b) a share of at least 5 % and not greater than 15 % of the total 

value  of  household  deposits  of  credit  institutions  in  Ireland.  On  that  basis,  the  second  draft  law 

provisionally proposes the percentage share of current accounts at 10 %, and the percentage share 

of  household  deposits  at  10 %,  as  this  is  the  mid-point  between  the  minimum  and  the  maximum 

range. The second draft law and the respective percentage shares will also be finalised following 

consultation with the CBI.  

2. 

Observations  

2.1  The ECB was consulted on a draft version of the 2025 Act and adopted an opinion thereon 8. 

2.2  The ECB considers it important that all 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. Sufficient and effective access to cash is 
necessary to preserve the effectiveness of the legal tender status of cash. If citizens do not have 
easy access to cash, they will not be able to use it as a means of payment and store of value 10. The 
ECB  welcomes  the  establishment  of  the  access  to  cash  criteria  in  the  first  draft  law,  to  ensure  a 

5   
6  

7  
8  
9  

10  

Section 5(1) of the 2025 Act.  
The 2025 Act defines ‘cash service’ as any service by which cash may be deposited and withdrawn by individuals and 
SMEs, to or from an account, and in-person assistance is available in connection with that service; and ‘cash service 
point’ as a location at which cash services are provided by or on behalf of a designated entity.  
Section 10 of the 2025 Act.  
See Opinion CON/2024/22. All ECB opinions are published on EUR-Lex. 
See  paragraph  2.2  of  Opinion  CON/2020/21,  paragraph  3.3  of  Opinion  CON/2022/40,  paragraph  2.3  of  Opinion 
CON/2024/3, paragraph 2.3 of Opinion CON/2024/8, paragraph 2.3 of Opinion CON/2024/19, paragraph 2.2 of Opinion 
CON/2024/26, paragraph 3.2 of Opinion CON/2025/8, paragraph 2.5 of Opinion CON/2025/14 and paragraph 3.1 of 
Opinion CON/2025/17. 
See paragraph 2.2 of Opinion CON/2023/25, paragraph 1.2 of Opinion CON/2023/31 of the European Central Bank 
of 13 October 2023 on a proposal for a regulation on the legal tender of euro banknotes and coins (OJ C, C/2023/1355, 
1.12.2023,  ELI: http://data.europa.eu/eli/C/2023/1355/oj ), paragraph 2.2  of  Opinion  CON/2024/3, paragraph 2.3 of 
Opinion CON/2024/19, paragraph 2.1 of Opinion CON/2024/26, paragraph 3.2 of Opinion CON/2025/8, paragraph 2.6 
of Opinion CON/2025/14 and paragraph 3.1 of Opinion CON/2025/17. See also Principle 6 of ELTEG III in the Final 
report  of  the  Euro  Legal  Tender  Expert  Group  (ELTEG)  of  6  July  2022,  available  on  the  Commission’s  website  at 
www.ec.europa.eu . 

2 

 
 
 
ECB-PUBLIC 

minimum  availability  of  ATMs  and  cash  service  points  that  credit  institutions  have  to  maintain  in 

Ireland in accordance with the 2025 Act. The ECB notes that the 2025 Act provides for situations 
that may trigger a review of these values 11. Moreover, the ECB notes that, in addition to ensuring the 
adequacy of access to cash through the access to cash criteria set in the first draft law, the 2025 Act 
also includes the possibility to remedy local deficiencies for individuals and SMEs 12. 

2.3  The access to cash criteria and the conditions for identification of designated entities in the draft laws 
are indicative. The ECB understands that the CBI is conducting related data collection exercises and 
that these values are therefore subject to consultation with the CBI and consideration by the Minister 
of the data collected.  

2.4  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 13  (hereinafter  the  ‘proposed 
regulation  on  the  legal  tender  of  euro  cash’),  which  includes  an  obligation  for  Member  States  to 

ensure sufficient and effective access to cash throughout their territory. The proposed regulation on 

the  legal  tender  of  euro  cash  provides  that,  following  its  adoption,  the  Commission  will  adopt 

implementing acts on a set of common indicators of general application in the euro area, which would 

allow  Member  States  to  effectively  monitor  and  assess  the  acceptance  of  payments  in  cash  and 

access to cash throughout their territory, in all their different regions, including urban and non-urban 
areas. The ECB will be consulted by the Commission on the preparation of such implementing acts 14.   
Once the implementing acts on the common indicators are adopted by the Commission, the access 

to cash criteria set out in the first draft law would need to be reviewed and, if necessary, adjusted 

accordingly. 

This opinion will be published on EUR-Lex.  

Done at Frankfurt am Main, 14 August 2025. 

[signed] 

The President of the ECB 

Christine LAGARDE 

11  
12  
13  
14  

Section 5(3) and (6) of the 2025 Act.  
Section 7 of the 2025 Act. See paragraph 2.6 of Opinion CON/2024/22.  
COM(2023) 364 final. 
Recitals 8, 9 and 12, and Article 9(2) and (5) of the proposed regulation on the legal tender of euro cash. 

3