Opinion of the European Central Bank of 26 September 2025 on the mandatory acceptance of cashless payments by sellers (CON/2025/30)
Date: 2025-09-26
Institutions: European Central Bank
Subjects: money, payment system

ECB-PUBLIC 

OPINION OF THE EUROPEAN CENTRAL BANK 

Of 26 September 2025 

on the mandatory acceptance of cashless payments by sellers 

(CON/2025/30) 

Introduction and legal basis 

On 21 August 2025 the European Central Bank (ECB) received a request from the Minister for Finance of 

the Slovak Republic for an opinion on a draft law on the registration of sales (hereinafter the ‘draft law’). 

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), second indent, of Council Decision 98/415/EC1, as the 
draft  law  relates  to  means  of  payment.  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 law  

1.1  The draft law recodifies the legislation on online and virtual cash registers and proposes a new type 

of  cash  register  known  as  a  software  online  cash  register  (hereinafter,  together,  ‘e-cash  register’ 

(eKasa)),  which  must  be  used  by  sellers2  to  register  revenue  when  selling  goods  or  providing 

services.  The  overall  purpose  of  the  draft  law  is  to  reflect  new  trends  in  the  registration  of  sales 

revenues, and to support the fight against tax evasion3. 

1.2  The  draft  law  introduces,  inter  alia,  an  obligation  for  sellers  to  enable  buyers  to  make  cashless 

payments for goods and services for any sale exceeding EUR 1 in value as of 1 March 20264. This 

obligation  is  considered  to  be  fulfilled  when  the  seller  accepts  as  cashless  payment  the  use  of  a 

‘payment instrument’, which is defined as any personalised device and/or set of procedures agreed 

between the payment service user and the payment service provider, and used in order to initiate a 

payment order, including but not limited to a payment card, internet banking or any other electronic 

banking payment application5.  

1.3  The draft law provides that when a cashless payment is made using a payment instrument that allows 

scanning  of  a  payment  order  in  the  form  of  a  QR  code,  the  Financial  Directorate  of  the  Slovak 

Republic  (hereinafter  the  ‘Financial  Directorate’)  will  provide  the  technical  means  necessary  to 

enable the e-cash register to obtain confirmation of such cashless payment. If, when making such a 

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Council Decision 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). 
Section  2,  point  (a), of  the  draft  law  defines ‘seller’ as a  natural  or  legal person  authorised  to  conduct  business or 
perform other self-employed activities, and who receives revenue for the sale of goods or the provision of services, 
regardless of where they have their permanent residence or registered office. 
See the submission report and general part of the explanatory memorandum. 
Section 15 and Section 19(5) of the draft law. 

Section 2(19) of Law No. 492/2009 Coll. on payment services and amending certain laws (Zákon č. 492/2009 Z. z. zo 
4. novembra 2009 o platobných službách a o zmene a doplnení niektorých zákonov). 

 
 
 
 
 
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cashless  payment,  confirmation  of  its  execution  is  not  provided,  the  e-cash  register  will  print  a 

document  confirming  this  fact.  The  draft  law  requires  the  Financial  Directorate  to  determine  and 

publish on its website the technical details of the technical means that will enable the e-cash register 

to  obtain  confirmation  of  the  cashless  payment  and  the  particulars  of  the  non-confirmation  of  a 

payment.  The  technical  means  for  cashless  payments  may  also  be  provided  by  third  parties 

independently from the Financial Directorate 6. 

1.4  Sellers are exempted from the obligation to enable buyers to make a cashless payment if: (a) they 

are exempted from the mandatory use of an e-cash register 7; (b) they have permission to postpone 

sending  data  to  the  e-cash  register 8;  or  (c)  at  the  time  of  payment  for  the  sale  of  goods  or  the 

provision of a service there is (i) no internet connection available at the point of sale, or (ii) a failure 

of  the  technical  means  provided  by  the  Financial  Directorate  or  by  a  third  party  to  confirm  the 

processing of a cashless payment 9. 

1.5  The  draft  law  envisages  that  a  second  breach  of  a  seller’s  obligation  to  enable  buyers  to  make 

cashless payments will be subject to a fine ranging from EUR 500 to 15 000 10. Any further breach 

would be subject to a fine ranging from EUR 1 000 to 30 00011.  

2. 

Observations  

2.1  The ECB views further innovation and development in the field of electronic payment instruments 

and  their  further  spread  in  society  positively12  and  recalls  the  Eurosystem’s  support  for  the  full 

deployment of instant payments 13. Therefore, the ECB welcomes the draft law in terms of its goal to 

contribute to the development of instant payments in Slovakia. At the same time, given the lack of 

technical details on the concrete implementation of the draft law, the ECB is unable to opine on the 

feasibility  of  the  intended  solution  for  instant  payments.  The  ECB  recommends  that  the  specific 

details of the technical solution for cashless payments that is to be facilitated by the e-cash register, 

including  any  need  for  the  establishment  of  accounts  with  payment  providers  and  related  fee 

structures, is made known to the sellers well in advance of the entry into force of the draft law, obliging 

them to accept cashless payments.  

2.2  The ECB understands that the intention of the Slovakian Ministry of Finance is to oblige sellers to 

accept at least one means of cashless payment, and that the choice of acceptable means of cashless 

payment will lie solely with the seller 14. However, the text of the draft law is unclear in this respect 

and may also lend itself to the interpretation that the buyer is entitled to use any payment instrument 

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Section 15(3) of the draft law. 
Sections 3(2) and 15(1) of the draft law. 
Section 4 and Section 15(1) of the draft law. 
Section 15(1) of the draft law. 
Sections 16, point (v), and 17(1), point (h), of the draft law. 
Sections 16, point (v), and 17(2), point (a), of the draft law. 
See paragraph 2.2 of Opinion CON/2020/21; paragraph 2.3 of Opinion CON/2021/18 and paragraph 2.1 of Opinion 
CON/2021/38. 
See Opinion CON/2023/4 of the European Central Bank of 1 February 2023 on a proposal for a regulation amending 
Regulations (EU) No 260/2012 and (EU) 2021/1230 as regards instant credit transfers in euro (OJ C 106, 22.3.2023, 
p. 2); see also the ECB, ‘The Eurosystem’s retail payments strategy – priorities for 2024 and beyond’, available on the 
ECB’s website at www.ecb.europa.eu. 

This intention appears in the analysis of the impact on the business environment prepared by the Slovakian Ministry 
of Finance. 

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of  its  choice.  Such  an  interpretation  would,  however,  be  tantamount  to  the  introduction  of  a 

requirement for the mandatory acceptance of all payment instruments and could, in the case of non-

instant  payments,  involuntarily  expose  sellers  to  credit  and  settlement  risks.  Therefore,  the  ECB 

recommends that the draft law should be amended to expressly clarify that sellers discharge their 

obligation to enable buyers to make cashless payments by accepting at least one means of cashless 

payment of each individual seller’s choice. 

2.3  The ECB understands that the draft law introduces an obligation for sellers to enable buyers to make 

cashless payments, but does not limit the ability of buyers to continue paying for goods and services 

in cash. In this regard, the ECB stresses that sellers are generally obliged to accept cash as a means 

of payment for goods and services, as euro banknotes and coins have legal tender status, and their 

continuing acceptance plays an important role in society15. 

This opinion will be published on EUR-Lex.  

Done at Frankfurt am Main, 26 September 2025. 

[signed] 

The President of the ECB 

Christine LAGARDE 

15  

See  paragraph  2.4  of  Opinion  CON/2017/8,  paragraph  2.1  of  Opinion  CON/2019/41,  paragraph  9.2.1  of  Opinion 
CON/2020/13,  paragraph  2.3  of  Opinion  CON/2020/21,  paragraph  7.2.1  of  Opinion  CON/2021/9,  paragraph  2.1  of 
Opinion CON/2021/18, paragraph 2.1 of Opinion CON/2023/7 and paragraph 2.2 of Opinion CON/2025/21. All ECB 
opinions are published on EUR-Lex. 

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