Letter from Frank Elderson, Member of the Executive Board of the European Central Bank (ECB), to Richard Raši, Speaker of the National Council of the Slovak Republic, regarding certain amendments to the law on restrictions on cash payments
Date: 2026-02-10
Institutions: European Central Bank
Subjects: money

ECB-PUBLIC 

[COURTESY TRANSLATION] 

Frank Elderson   

Member of the Executive Board 

Mr Richard Raši 

Speaker of the National Council of the Slovak Republic 

National Council of the Slovak Republic 

Námestie Alexandra Dubčeka 1 

812 80 Bratislava 1  

SLOVAKIA 

Frankfurt am Main, 10 February 2026 

Contact person: mikulas.prokop@ecb.europa.eu 

Re: Amendments to the Law on restrictions on cash payments  

Dear Mr Raši, 

It has come to the attention of the European Central Bank (ECB) that on 3 December 2025 the National 

Council of the Slovak Republic adopted a Law on the registration of sales and on amendments to certain 

laws 1 (hereinafter the ‘Law’).   

The Law amends, among others, the Law on restrictions on cash payments 2 by introducing a prohibition of 

(a)  cash  payments  in  excess  of  EUR  5  000  by  or  from  legal  persons  or  natural  persons  who  are 

entrepreneurs;  and  (b)  cash  payments  in  excess  of  EUR  15  000  between  natural  persons  who  are  not 

entrepreneurs.  

On 26 September 2025 the ECB adopted an opinion on an earlier draft version of the Law, which concerned 

the mandatory acceptance of cashless payments by sellers 3. The ECB understands that after the adoption 

of that opinion, in the legislative process at the National Council of the Slovak Republic and following a 

resolution of the Committee of the National Council of the Slovak Republic for Finance and Budget 4, the 

Law was further amended to introduce also the amendments to the Law on restrictions on cash payments 

described above. Therefore, the ECB was not consulted on these amendments to the law on restrictions 

on cash payments.  

1  
2  
3  
4  

Zákon č. 384/2025 Z.z. o evidencii tržieb a o zmene a doplnení niektorých zákonov. 

Zákon č. 394/2012 Z.z. o obmedzení platieb v hotovosti. 
See Opinion CON/2025/30. All ECB opinions are published on EUR-Lex. 

Uznesenie Výboru Národnej rady Slovenskej republiky pre financie a rozpočet z 19. novembra 2025, Číslo: KNR-
VFR-6045/2025-5. 

Address 
European Central Bank  
Sonnemannstrasse 20 
60314 Frankfurt am Main  
Germany 

Postal address 
European Central Bank  
60640 Frankfurt am Main 
Germany 

Tel.: +49 69 1344 0 
E-mail: info@ecb.europa.eu 
www.ecb.europa.eu 

 
 
 
 
 
 
ECB-PUBLIC 

In accordance with Articles 127(4) and 282(5) of the Treaty on the Functioning of the European Union and 

Article 2(1) of Council Decision 98/415/EC5 national authorities are required to consult the ECB on draft 

legislative  provisions  concerning  matters  that  fall  within  its  fields  of  competence,  including  means  of 

payment.  

In addition, Article 80(1) of Regulation (EU) 2024/1624 of the European Parliament and of the Council 6 sets 

a cash payment and acceptance limit of EUR 10 000 for persons trading in goods or providing services. 

Article 80(2) of the same Regulation allows Member States to adopt lower limits following consultation of 

the ECB in accordance with Article 2(1) of Decision 98/415/EC 7.  

While  the  ECB  adopted  an  opinion  on  an  earlier  version  of  the  Law,  this  does  not  release  the  Slovak 

authorities from their duty to reconsult the ECB in accordance with the Treaty and Decision 98/415/EC. As 

noted in the ECB Guide to consultation of the European Central Bank by national authorities regarding draft 

legislative  provisions 8,  the  obligation  to  consult  the  ECB  on  amendments  to  draft  legislative  provisions 

which have already been submitted to the ECB for an opinion applies to substantive amendments which 

affect the essence of the draft legislation. Where substantive new provisions are proposed after the ECB 

opinion  has  been  adopted,  by  analogy  to  the  Court’s  case-law  on  the  requirement  to  reconsult  Union 

institutions on amended draft legislation9, the ECB should be reconsulted in relation to those amendments 

in  exceptional  cases  where  the  draft  legislation  has  undergone  substantial  changes  of  a  non-technical 

nature as compared to the version on which the ECB has previously been consulted. The ECB considers 

that the amendments to the Law on restrictions on cash payments represent substantial changes of a non-

technical nature compared to the version  of the Law  on which the ECB  had  previously been consulted, 

which concerned the separate topic of the mandatory acceptance of cashless payments. 

While the ECB adopted an opinion in 2012 when the Law on restrictions on cash payments was adopted10, 

and while said Law on restrictions on cash payments included the same limits as those re-introduced by 

the Law at the time of adoption, this does not release the Slovak authorities from their duty to consult the 

ECB in accordance with the Treaty and Decision 98/415/EC, in particular given the substantial development 

in the jurisprudence on the restrictions on cash payments following the decision of the Court of Justice of 

the European Union in 2021 in the Hessischer Rundfunk case11. In this respect, the ECB would like to draw 

5  

6  

7  

8  

9  

10  
11  

Council  Decision  98/415/EC  of  29  June  1998  on  the  consultation  of  the  European  Central  Bank  by  national 
authorities 
ELI: 
http://data.europa.eu/eli/dec/1998/415/oj). 

provisions 

legislative 

regarding 

3.7.1998, 

draft 

189, 

(OJ 

42, 

p. 

L 

Regulation (EU) 2024/1624 of the European Parliament and of the Council of 31 May 2024 on the prevention of the 
use of the financial system for the purposes of money laundering or terrorist financing (OJ L 2024/1624, 19.6.2024, 
ELI: http://data.europa.eu/eli/reg/2024/1624/oj).  
Article 80(2) of Regulation (EU) 2024/1624: ‘“Member States may adopt lower limits following consultation of the 
European Central Bank in accordance with Article 2(1) of Council Decision 98/415/EC. Those lower limits shall be 
notified to the Commission within 3 months of the measure being introduced at national level.’” 
See European Central Bank, Guide to consultation of the European Central Bank by national authorities regarding 
draft legislative provisions (April 2025), p. 12, available at www.ecb.europa.eu.  
See Judgment of the Court of Justice of 15 July 1970, Chemiefarma v Commission, C-41/69, ECLI:EU:C:1970:71, 
paragraph  3;  judgment  of  the  Court  of  4  February  1982,  Buyl  and  Others  v  Commission,  C-817/79, 
ECLI:EU:C:1982:36, paragraph 1; judgment of the Court of Justice of 10 June 1997, Parliament v Council, C-392/95, 
ECLI:EU:C:1997:289, paragraph 15; judgment of the Court of Justice of 11 November 1997, Eurotunnel and Others 
v SeaFrance, C-408/95, ECLI:EU:C:1997:532, paragraph 46; judgment of the Court of 25 September 2003, Océ van 
der Grinten, C-58/01, ECLI:EU:C:2003:495, paragraphs 100 and 102. 
See Opinion CON/2012/83. 
See judgment of the Court (Grand Chamber) of 26 January 2021, Hessischer Rundfunk, C-422/19 and C-423/19, 
ECLI:EU:C:2021:63. 

2 

 
 
ECB-PUBLIC 

the  attention  of  the  Slovak  authorities  to  certain  opinions  adopted  by  the  ECB  since  2021  concerning 

general cash limitations and cash payments 12, including, in particular, an opinion adopted by the ECB in 

2023  in  response  to  a  consultation  by  the  Chairman  of  the  Financial  and  Budgetary  Committee  of  the 

National Council of the Slovak Republic on a draft law amending the Law on restrictions on cash payments, 

in particular on increasing the applicable cash payment limits at that time13.  

The ECB would appreciate that the National Council gives due consideration to the above observations by 

honouring its obligation to consult the ECB in the future on draft national legislation falling within the ECB’s 

fields of competence where appropriate. 

Yours sincerely, 

[signed] 

Cc: 

Mr P Kažimír, Governor, Národná banka Slovenska 

Mr L Kamenický, Ministerstvo financií Slovenskej republiky 

Mr  V  Dombrovskis,  Commissioner  for  Economy  and  Productivity;  Implementation  and 

Simplification, European Commission 

Mr A De Gregorio Merino, Director-General Legal Service, European Commission  

Encl. 

Guide to consultation of the ECB by national authorities regarding draft legislative provisions 

12  

13  

See, for example, Opinions CON/2022/9 (Spain), CON/2023/33 (Belgium), CON/2023/40 (Belgium), CON/2024/2 
(Denmark) and CON/2024/39 (Netherlands).  

See Opinion CON/2023/13.  

3