title: Opinion of the European Central Bank of 12 May 2025 on the resilience of critical entities (CON/2025/11)

text: OPINION OF THE EUROPEAN CENTRAL BANK of 12 May 2025 on the resilience of critical entities (

text: ) Introduction and legal basis

text: On 20 December 2024, Law LXXXIV of 2024 on the resilience of critical entities (hereinafter the ‘Law’) was published in the Hungarian Official Gazette, followed, on 31 December 2024, by an implementing Government decree (hereinafter the ‘decree’). The European Central Bank (ECB) has not been consulted by the Hungarian authorities on the Law or the decree. The ECB has decided to deliver an own initiative opinion on the Law and the decree. 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), third indent, of

text: Council Decision 98/415/EC

text: , as the Law and the decree relate to the Magyar Nemzeti Bank (MNB). In accordance with

text: Article 17.5

text: , first sentence, of the Rules of Procedure of the European Central Bank, the Governing Council has adopted this opinion.

text: 1. Purpose of the Law and the decree

text: 1.1 According to the explanatory memorandum accompanying the Law, the Law’s purpose is: (a) to transpose

text: Directive (EU) 2022/2557

text: of the European Parliament and of the Council (hereinafter the ‘Critical Entities’ Resilience Directive’) into Hungarian law; and (b) to protect life and property in order to (i) ensure the wellbeing of citizens and the continuity of essential services, with a view to developing a national resilience system, and (ii) enhance the resilience of the State, society and the economy. The decree implements the Law based on a delegation under the Law . 1.2 The Critical Entities’ Resilience Directive 1.2.1 The Critical Entities’ Resilience Directive, as a minimum harmonisation directive, does not preclude Member States from adopting provisions of national law with a view to achieving a higher level of resilience of critical entities, provided that such provisions are consistent with Member States’

text: 1 A kritikus szervezetek ellenálló képességéről szóló 2024. évi LXXXIV. törvény, published in Magyar Közlöny 2024/131.

text: 2 A kritikus szervezetek ellenálló képességéről szóló törvény végrehajtásáról szóló 474/2024. (XII. 31.) Korm. rendelet, published in Magyar Közlöny 2024/139.

text: Council Decision 98/415/EC of 29 June 1998

text: 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).

text: Directive (EU) 2022/2557

text: of the European Parliament and of the Council of 14 December 2022 on the resilience of critical entities and repealing

text: Council Directive 2008/114/EC

text: (OJ L 333, 27.12.2022, p. 164, ELI: http://data.europa.eu/eli/dir/2022/2557/oj).

text: 5 Article 40 of the Law. obligations laid down in Union law . The purpose of the Critical Entities’ Resilience Directive is to ensure the provision of essential services in the internal market, enhance the resilience of critical entities, assist them by means of coherent and dedicated support and supervision measures, and improve cross-border cooperation between competent authorities . 1.2.2 The Critical Entities’ Resilience Directive covers ‘public administration entities’, which are defined as entities recognised as such in a Member State in accordance with national law and complying with defined criteria. The judiciary, parliaments and central banks are excluded from the definition of a 8. public administration entity 1.2.3 The Critical Entities’ Resilience Directive outlines obligations for Member States to adopt a strategy for enhancing the resilience of critical entities, carry out a risk assessment, identify critical entities, designate or establish competent authorities and one single point of contact for the purpose of ensuring cooperation between Member States, support critical entities in enhancing their resilience, and consult one another regarding critical entities, whenever appropriate . Additionally, the Directive outlines requirements for critical entities to carry out a risk assessment, take appropriate and proportionate resilience measures, notify competent authorities of incidents significantly disrupting the provision of essential services or having the potential to do so, and the possibility for critical entities to request background checks on certain persons . The Directive also provides for the identification of critical entities of particular European significance and advisory missions to assess the measures certain critical entities of particular European significance have put in place to meet their obligations under the Directive . Furthermore, the Directive establishes a Critical Entities Resilience Group to support the Commission and facilitate cooperation among Member States and the exchange of information . Finally, the Directive establishes the competent authorities’ supervisory and enforcement powers to assess the compliance of critical entities with the obligations laid down in the Directive . 1.3 The MNB under the scope of the Law and the decree 1.3.1 The Law designates the basic tasks of the MNB, with the exception of monetary policy, macroprudential policy and the operation of the central bank information system, as essential services in the financial sector and the financial market infrastructure subsector . Therefore, under the Law, the MNB’s essential services are: (a) the issuance of banknotes and coins; (b) the establishment and management of foreign exchange and gold reserves; (c) the execution of related foreign exchange operations; and (d) the oversight of payment and settlement and securities clearing and settlement systems . On the other hand, the decree specifies that the MNB may be designated

text: 6 Article 3 of the Critical Entities’ Resilience Directive.

text: 7 Recitals 1 and 7 of the Critical Entities’ Resilience Directive.

text: Article 2

text: , point (10), of the Critical Entities’ Resilience Directive.

text: Articles 4

text: to 7 and 9 to 11 of the Critical Entities’ Resilience Directive.

text: Articles 12

text: to 15 of the Critical Entities’ Resilience Directive.

text: 11 Articles 17 and 18 of the Critical Entities’ Resilience Directive.

text: 12 Article 19 of the Critical Entities’ Resilience Directive.

text: 13 Articles 21 and 22 of the Critical Entities’ Resilience Directive.

text: 14 Annex 1 to the Law, line 76. as a critical entity with respect to the following tasks: (a) the establishment and management of foreign exchange and gold reserves; (b) the execution of related foreign exchange operations; (c) the oversight of payment and settlement and securities clearing and settlement systems; and (d) supervision of the financial intermediary system . The designating authority may designate the infrastructures relating to the MNB’s essential services as critical infrastructures . 1.3.2 The Law assigns to the MNB the obligation to: (a) build and improve resilience in the context of essential services and critical infrastructures; (b) conduct risk assessment and risk management; (c) prepare a resilience plan and a resilience matrix; and (d) conduct resilience exercises and stress tests . Additionally, the MNB is to report all incidents falling under the Law to the authorities supervising its compliance with the Law and establish the position of an independent critical entity resilience manager (hereinafter ‘critical entity resilience manager’) . Finally, to meet the applicable resilience requirements, security staff acting on behalf of the MNB are authorised (with some exceptions) to screen, restrict, or prevent, for security purposes, the entry or exit of persons, vehicles and objects within and from the area where a critical infrastructure is located . 1.4 Supervision of the MNB under the Law and the decree 1.4.1 Two authorities supervise the MNB’s compliance with the Law and the decree: (a) the National Directorate General for Disaster Management of the Ministry of the Interior as the general designating and control authority ; and (b) the Minister responsible for the regulation of the money, capital and insurance markets as the first-level specialist authority (ágazati szakhatóság) in relation to the MNB’s critical activities . 1.4.2 The general designating authority regularly monitors and assesses the resilience status of sectors, subsectors, essential services, potential critical entities and critical infrastructures . It decides on the designation of critical entities and infrastructures and carries out a procedure to maintain or withdraw the designation at the latest every four years . In the context of that procedure, it examines compliance with horizontal criteria by the MNB or the infrastructure subject to the procedure and, in certain cases, with sectoral criteria with the involvement of the first-level specialist authority . It also classifies critical entities into three levels of resilience based on the impact of the service they provide and of an incident, the number of users of their service, the geographical coverage of the service provided, and the nature of the sector, subsector and essential service concerned . Finally, it

text: 21 Belügyminisztérium Országos Katasztrófavédelmi Főigazgatóság. Articles 2(1) and 19(1) of the decree; Article 2(1) of Government decree 234/2011. (XI. 10.) on the implementation of Law CXXVIII of 2011 on disaster management and amending certain related laws.

text: 22 Pénz-, tőke- és biztosítási piac szabályozásáért felelős miniszter. Annex 1, Table 21, lines 12 and 25, to Government decree 531/2017. (XII. 29.) designating certain specialised authorities to act on imperative grounds of public interest. designates critical infrastructures and determines their level of resilience with the involvement of the first-level specialist authority . 1.4.3 The control authority carries out regular, periodic and ex-post complex official inspections 28. (hereinafter the ‘complex control’) with the involvement of the first-level specialist authority It monitors, as part of the complex control: (a) the MNB’s compliance with the provisions of the Law and related legislation; (b) the MNB’s compliance with the final decision of the designating authority; (c) the adequacy of and compliance with the measures taken by the MNB to maintain and improve the resilience of the MNB and its critical infrastructures; (d) the adequacy of the MNB’s resilience plan and the regularity and adequacy of the MNB’s risk assessment and resilience matrix; (e) the adequacy of the activities of the MNB’s management in terms of resilience; (f) the adequacy of the activities of the critical entity resilience manager; (g) the adequacy of the MNB’s resilience exercise; (h) the adequacy of the cooperation between the MNB and members of the relevant supply chain and suppliers; and (i) the MNB’s compliance with the requirements relating to the suitability of the critical entity resilience manager . 1.4.4 The first-level specialist authority, in addition to issuing a sector-specific opinion in the relevant designation procedures, is also involved in determining the content of the resilience plan and resilience matrix, and in the regular periodic inspections of the control authority. Under certain conditions, it may carry out a sectoral resilience inspection independently, examining a number of compliance obligations . 1.4.5 If the MNB or the critical entity resilience manager fail to comply with their legal obligations, the supervising authorities will impose a time limit for the MNB to remedy the failure and may also impose an administrative fine on the MNB . The amount of the administrative fine depends on the individual infringement and ranges from HUF 500 000 to HUF 15 000 000. In the case of several infringements, the fines for each infringement are totalled, subject to a maximum total fine of HUF 100 000 000 .

text: 2. General observations

text: 2.1 The ECB supports the aim of the Critical Entities’ Resilience Directive to ensure that services that are essential for the maintenance of vital societal functions or economic activities within the scope of Article 114 of the Treaty are provided in an unobstructed manner in the internal market. The ECB also supports the objective of the Critical Entities’ Resilience Directive to help achieve a high level of resilience of critical entities in order to ensure the provision of essential services within the Union and to improve the functioning of the internal market .

text: 2.2 The ECB understands that, by including the MNB within their scope, the Law and the decree go beyond the Critical Entities’ Resilience Directive, which excludes central banks from the definition of a ‘public administration entity’ . 2.3 Under the Law and the decree, the scope of the tasks in the exercise of which the MNB can be designated as a critical entity differ. The ECB understands that in the event of a conflict between the Law and the decree, the provisions of the Law take precedence . Nevertheless, the ECB suggests that the scope of the MNB’s tasks under the Law and the decree should be aligned to ensure legal certainty.

text: 3. Impact of the Law and the decree on the independence of the MNB

text: 3.1 Article 130 of the Treaty provides that, when exercising the powers and carrying out the tasks and duties conferred upon them by the Treaties and the Statute of the European System of Central Banks and of the European Central Bank (hereinafter the ‘Statute of the ESCB’), neither a national central bank (NCB), which includes the MNB, nor any member of its decision-making bodies are to seek or take instructions from Union institutions, bodies, offices or agencies, from any government of a Member State or from any other body. The Union institutions, bodies, offices or agencies and the governments of the Member States undertake to respect this principle and not to seek to influence the members of the decision-making bodies of the NCBs in the performance of their tasks . 3.2 Article 130 of the Treaty also applies to Member States with a derogation, such as Hungary, in respect of which the Council has not yet decided that they fulfil the necessary conditions for the adoption of the euro . Consistent with these Treaty requirements, Hungarian law enshrines the independence of the MNB, and its concomitant primary objective to maintain price stability . 3.3 Central bank independence is served by providing the NCBs with the necessary means and instruments to conduct an efficient monetary policy and to achieve their primary objective of price stability independently of any other authority, reflecting the generally held view that the objective of price stability is best served by a fully independent institution . The recognition that central banks have such independence does not, however, have the consequence of exempting them from every rule of law or of shielding them from any kind of legislation . This also applies to national legislative measures capable of applying to NCBs in the European System of Central Banks (ESCB) , such as the Law and the decree.

text: 36 Article 130 of the Treaty is mirrored in Article 7 of the Statute of the ESCB.

text: 37 Article 130 of the Treaty is not referred to in

text: Article 139(2)

text: thereof, which lists exhaustively the Treaty provisions that do not apply to Member States with a derogation.

text: 38 See Articles 1(2) and 3(1) of the Law on the MNB. Pursuant to Article 139(2) of the Treaty, in conjunction with Article 42.2 of the Statute of the ESCB, the central banks of Member States with a derogation, which includes the MNB, retain their powers in the field of monetary policy according to national law.

text: 39 See the ECB’s Convergence Report, 2024, paragraph 2.2.3, available on the ECB’s website at www.ecb.europa.eu.

text: 40 See the judgment of the Court of Justice of 10 July 2003, Commission v European Central Bank,

text: , ECLI:EU:C:2003:395, paragraphs 134 to 136.

text: 41 See paragraph 2.2 of Opinion

text: , paragraph 2.2 of Opinion

text: and paragraph 2.2 of Opinion

text: . All ECB opinions are published on EUR-Lex. 3.4 The ECB refers to the stance it has taken in the context of assessing national legislation on the resilience of critical infrastructures. The ECB has welcomed the exemption of critical infrastructures and payment systems operated, supervised or overseen by ESCB central banks from draft national laws' scope of application, as that should help to ensure that national legislation on the protection of critical infrastructures does not encroach on the ESCB’s competences, consistent with the principle of the primacy of Union law and central bank independence under Article 130 of the Treaty . 3.5 The ECB also refers to the stance it has taken in the context of national emergency planning in the case of Member States whose currency is the euro. The ECB has highlighted that, in the area of monetary policy and ESCB-related tasks, Member States whose currency is the euro may not unilaterally adopt measures as it is for the decision-making bodies of the ECB alone to take the measures necessary to ensure the performance of the tasks entrusted to the ESCB by the Treaty and the Statute of the ESCB , including contingency planning in respect of the continued performance of these tasks . 3.6 Therefore, Member States which have not adopted the euro may not adopt unilateral measures that interfere with the independence of the NCBs as it is for the NCB’s decision-making bodies to ensure the performance of the tasks entrusted to the ESCB under the Treaty and the Statute of the ESCB. Contingency planning, together with building, improving and managing the resilience of an NCB, are integral parts of the performance of an NCB’s ESCB-related tasks. Since the MNB’s resilience is inextricably linked with the performance of its tasks, it is for the MNB’s decision-making bodies to take decisions concerning its resilience. 3.7 Contrary to the above, the ECB understands that, in their current form, the Law and the decree impose a number of obligations on the MNB and place it under the supervision of governmental bodies with substantial powers. For instance, the MNB is required to build and improve its resilience based on obligations such as the preparation of a resilience plan and a resilience matrix with predetermined content and form requirements and the establishment of a position of an independent critical entity resilience manager with the provision of adequate technical, human and financial resources for their activities. The supervising governmental bodies’ powers include, for example, powers to designate a specific MNB infrastructure as a critical infrastructure, to approve or reject the MNB’s resilience plan and resilience matrix, and to mandate the MNB to conduct resilience exercises and stress tests. The MNB is also subject to inspections during which the supervising governmental bodies monitor all the MNB’s actions and lack of action related to its resilience. Finally, if the MNB or the critical entity resilience manager fail to comply with their legal obligations, the supervising governmental bodies will impose a time limit for the MNB to remedy the failure and may impose an administrative fine on the MNB. These obligations and supervisory powers significantly influence the MNB’s preparedness and fundamentally restrict the autonomy of the MNB’s decision-making bodies to make decisions that concern the MNB’s resilience. 3.8 Therefore, the Law and the decree, in their current form, amount to enabling the government to give instructions to the MNB and thus interfere with the MNB’s independence under Article 130 of the

text: 42 See paragraph 2.3.1 of Opinion

text: and paragraph 3.2.1 of Opinion

text: 44 See paragraph 2.1 of Opinion

text: and paragraph 2.1 of Opinion

text: . Treaty. Against this background, the ECB recommends that the Hungarian legislator exempt the MNB from any provision that could amount to enabling the government to give such instructions to the MNB in light of the need to preserve its independence. This opinion will be published on EUR-Lex. Done at Frankfurt am Main, 12 May 2025. [signed] The President of the ECB Christine LAGARDE


text: Az államháztartásról szóló 2011. évi CXCV. törvény, published in Magyar Közlöny 2011/164.

text: A Magyar Nemzeti Bankról szóló 2013. évi CXXXIX. törvény, published in Magyar Közlöny 2013/158.

text: Council Decision 98/415/EC of 29 June 1998

text: 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).

text: Article 9(3) of the Law on the MNB. 6 Article 12(1) of the Law on the MNB. For a detailed description of the role of the Monetary Council and the Executive Board of the MNB, see paragraphs 1.5 and 1.6 of Opinion

text: . All ECB opinions are published on EUR- Lex.

text: See section 5.1. of the Guide to consultation of the European Central Bank by national authorities regarding draft legislative provisions (April 2025). 13 See paragraph 2 of Opinion

text: Decision ECB/2014/8 of the European Central Bank of 20 February 2014 on the prohibition of monetary financing and the remuneration of government deposits by national central banks (OJ L 159, 28.5.2014, p. 54, ELI: ELI: http://data.europa.eu/eli/dec/2014/303/oj). 15 See also paragraph 2.3 of Opinion

publisher: Europeiska centralbanken

sprak: en

title: Opinion of the European Central Bank of 27 May 2025 on the composition of the decision-making bodies of the Magyar Nemzeti Bank, the treasury accounts managed by the Magyar Nemzeti Bank and the permitted activities of foundations established by the Magyar Nemzeti Bank (CON/2025/12)

serie: con

text: OPINION OF THE EUROPEAN CENTRAL BANK of 27 May 2025 on the composition of the decision-making bodies of the Magyar Nemzeti Bank, the treasury accounts managed by the Magyar Nemzeti Bank and the permitted activities of foundations established by the Magyar Nemzeti Bank (

text: ) Introduction and legal basis

type: rubrik

text: On 14 May 2025 the European Central Bank (ECB) was informed by the Hungarian Ministry of the National Economy of draft amendments to (1) the Law on public finance (hereinafter the ‘Law on public finance’); and (2) the Law on the Magyar Nemzeti Bank (MNB) (hereinafter the ‘Law on the MNB’), hereinafter together referred to as the ‘draft amendments’. 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), third indent, of

text: Council Decision 98/415/EC

text: , as the draft amendments relate to the MNB. In accordance with

text: Article 17.5

text: , first sentence, of the Rules of Procedure of the European Central Bank, the Governing Council has adopted this opinion.

type: stycke

text: 1. Purpose of the draft amendments

text: 1.1 According to the explanatory memorandum accompanying the draft amendments, the primary objective of the draft amendments is to enable the MNB to perform its basic central bank and statutory tasks as efficiently as possible. As a part of this objective, it is considered necessary to reduce the activities of the MNB that fall outside [the scope of] its statutory tasks. 1.2 Composition of the MNB’s decision-making bodies 1.2.1 Under the Law on the MNB, the bodies of the MNB are the Monetary Council, the Financial Stability Council, the Executive Board and the Supervisory Board. The Monetary Council is the MNB’s supreme decision-making body, and the scope of its competence includes, inter alia, strategic decisions concerning the MNB’s tasks relating to monetary policy, banknotes and coins, official foreign exchange and gold reserves, foreign exchange operations and the collection and publication of statistical information . The Law on the MNB currently provides that the Monetary Council is to have at least five and at most nine members, comprising the Governor and the Deputy Governors of the MNB and other members elected by the National Assembly for six years. The combined number

text: of the Governor and Deputy Governors of the MNB must be less than the number of Monetary Council members elected by the National Assembly. Moreover, the number of Monetary Council members elected by the National Assembly must be less than twice the combined number of the Governor and Deputy Governors of the MNB . 1.2.2 The Executive Board of the MNB is responsible for implementing the decisions of the Monetary Council and of the Financial Stability Council, as well as for managing the operations of the MNB . The members of the Executive Board are the Governor and Deputy Governors of the MNB . The Law on the MNB currently provides that the MNB is to have at least two and at most three Deputy Governors . 1.2.3 According to the draft amendments, the MNB will have at least two and at most four Deputy Governors, and the number of members of its Monetary Council will be at least five and at most eleven. The explanatory memorandum clarifies that the increase of the maximum number of members of the Monetary Council is due to the possibility to appoint a fourth Deputy Governor, i.e. to ensure that the number of Monetary Council members elected by the National Assembly continues to exceed the combined number of the Governor and Deputy Governors of the MNB, thereby maintaining the ratio set out in the Law on the MNB as it currently stands. 1.3 Treasury accounts managed by the MNB 1.3.1 The Law on public finance currently provides that the Hungarian State Treasury disposes of a Hungarian forint (HUF) account at the MNB called the single HUF treasury account, and the Treasury may hold single foreign currency treasury accounts . The MNB is to pay interest to the central budget on the current balance of (1) the single HUF treasury account at the market interest rate but not exceeding the central bank base rate; and (2) the single foreign currency treasury accounts at the market interest rate, with due regard to the prohibition of monetary financing when determining such rate . 1.3.2 The draft amendments entitle the Hungarian State Treasury to hold other foreign currency accounts and custody accounts at the MNB; the latter are to be used for the separate management of funds in connection with the statutory custodial activities of the Treasury. In accordance with the draft amendments, the MNB is to pay interest to the central budget also on the current balance of the other foreign currency treasury accounts at the market interest rate, with due regard to the prohibition of monetary financing when determining such rate. 1.4 Permitted activities of the foundations established by the MNB The Law on the MNB currently provides that in line with its tasks and primary objective, the MNB may establish a business association in which it has a majority holding or may establish a

text: foundation . The draft amendments add that the MNB may not establish asset-management foundations, and the foundations established by the MNB must not carry out investment, asset management activities or other financial transactions as an economic activity. This provision is not to apply to foundations established before the entry into force of the draft amendments.

text: 2. Duty to consult the ECB on the draft amendments

text: 2.1 The Hungarian Ministry of the National Economy has informed the ECB about the draft amendments ‘for full transparency’ and asked the ECB to provide comments on them, should it wish to. The draft amendments were submitted to the Hungarian National Assembly by its Committee on Economics. 2.2 Under Articles 127(4) and 282(5) of the Treaty and

text: Article 2(1) of Decision 98/415/EC

text: , the authorities of Member States must consult the ECB on any draft legislative provision that falls within its fields of competence. 2.3 Under

text: Article 3(1) of Decision 98/415/EC

text: , the authorities may set the ECB a time limit for the submission of its opinion, which may not be less than one month from the date on which the President of the ECB receives notification to this effect.

text: Article 3(2) of Decision 98/415/EC

text: allows for the reduction of the time limit in cases of extreme urgency, the reasons for which must be stated. Furthermore, in accordance with

text: Article 4 of Decision 98/415/EC

text: , the ECB should be consulted at an appropriate stage, which enables the authority initiating the draft legislative provision to take the ECB’s opinion into account before it decides on the substance. This implies that national procedures should ensure that the consultation takes place at a point in the legislative process which affords the ECB sufficient time to examine the draft legislative provisions and to adopt its opinion . 2.4 The ECB reiterates that the draft amendments fall within the ECB’s fields of competence under

text: Article 2(1)

text: , third indent, of Decision

text: , as they concern a national central bank (NCB) in the European System of Central Banks, in this case, the MNB. Since the draft amendments were proposed by a parliamentary committee, the ECB invites the Hungarian National Assembly to take note of the obligation to consult the ECB on the draft amendments .

text: 3. Observations on the draft amendments

text: 3.1 The ECB takes note of the increase in the number of Deputy Governors of the MNB and, consequently, the number of members of the Monetary Council of the MNB under the draft amendments. 3.2 The ECB welcomes that the draft amendments provide that the interest paid by the MNB to the central budget on the current balance of the other foreign currency treasury accounts cannot exceed market rates, and that when setting the interest rate for these accounts the MNB will have due regard to the prohibition of monetary financing. The ECB refers in this respect to Decision ECB/2014/8 of

text: the European Central Bank , which sets out the criteria applied by the ECB regarding the remuneration of government deposits by NCBs for the purposes of monitoring compliance with the monetary financing prohibition laid down in Article 123(1) of the Treaty . Regarding the reference to custody accounts held with the MNB for the separate management of funds in connection with the statutory custodial activities of the Treasury, the ECB understands that the funds credited to these accounts are not remunerated. 3.3 Taking particular account of the scope, number and size of the foundations established by the MNB over time, the ECB welcomes that the draft amendments restrict the permitted activities of foundations established by the MNB.

text: This opinion will be published on EUR-Lex.

text: Done at Frankfurt am Main, 27 May 2025.

text: [signed]

text: The President of the ECB

text: Christine LAGARDE

type: vagledning

utgivare: ecb


text: Council Decision 98/415/EC of 29 June 1998

text: on the consultation of the European Central Bank by national authorities regarding draft legislative provisions (OJ L 189, 3.7.1998, p. 42, ELI: https://eur-lex.europa.eu/eli/dec/1998/415/oj). 2 Loi du 5 août 1978 de réformes économiques et budgétaires/Wet van 5 augustus 1978 houdende economische en budgettaire hervormingen, telle que modifiée/zoals nader gewijzigd, Moniteur Belge/Belgisch Staatsblad, 17/8/1978, p. 9106. 3

text: Article 39

text: , second paragraph, of the Wijninckx law. The Wijninckx cap amounts to EUR 46 882.74 per year at index 138.01. The indexed amount is EUR 99 499.24 gross per year (since 1 February 2025 at index 2.1223), or EUR 8 291.60 gross per month. 4 Article

text: ° of the Wijninckx law. 5 Articles X+3 and X+4 of the draft law.

text: This examination is without prejudice to the Member States’ competences under Article 153(4) of the Treaty. 7 See paragraph 6 of Opinion

text: and paragraph 4.2 of Opinion

text: . All ECB opinions are published on EUR-Lex. 8 See the ECB’s Convergence Report, 2024, paragraph 2.2.3 (sub-section entitled ‘Autonomy in staff matters’), available on the ECB’s website at www.ecb.europa.eu. See also paragraph 4.3 of Opinion

text: , paragraph 2.4 of Opinion

text: , paragraph 2.3 of Opinion

text: and paragraph 3.2 of Opinion

text: . 9 See the ECB’s Convergence Report, 2024, paragraph 2.2.3 (sub-section entitled ‘Autonomy in staff matters’). See also paragraph 4.4 of Opinion

text: , paragraph 2.3 of Opinion

text: and paragraph 3.3 of Opinion 10 See paragraph 2.1.3 of Opinion

text: and paragraph 3.2.2 of Opinion

text: See paragraph 2.1.3 of Opinion

text: , paragraph 3.2.2 of Opinion

text: and paragraph 2.5 of Opinion 12 See the ECB’s Convergence Report, 2024, paragraph 2.2.3 (sub-section entitled ‘Personal independence’). See also paragraph 3.5 of Opinion

text: , paragraph 3.2.9 of Opinion

text: , paragraph 4.3 of Opinion

text: , paragraph 3.5.2 of Opinion

text: and paragraph 3.3.1 of Opinion

text: . 13 See paragraph 3.2.10 of Opinion

text: , paragraph 4.6 of Opinion

text: , paragraph 2.6 of Opinion

text: and paragraph 2.9 of Opinion

text: . 14 See Article 44 of the Wijninckx law.

title: Opinion of the European Central Bank of 10 June 2025 on the pensions of the Nationale Bank van België/Banque Nationale de Belgique (CON/2025/13)

text: OPINION OF THE EUROPEAN CENTRAL BANK of 10 June 2025 on the pensions of the Nationale Bank van België/Banque Nationale de Belgique (

text: ) Introduction and legal basis

text: On 14 May 2025, the European Central Bank (ECB) received a request from the Belgian Deputy Prime Minister and Minister of Finances and Pensions for an opinion on a draft law for temporary public pension sustainability measures (hereinafter the ‘draft law’). The draft law amends the rules applicable to the pension of certain members of the board of directors and staff of the Nationale Bank van België/Banque Nationale de Belgique (NBB). 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), third indent, of

text: Council Decision 98/415/EC

text: , as the draft law relates to the NBB. In accordance with

text: Article 17.5

text: 1. Purpose of the draft law

text: 1.1 The law of 5 August 1978 on economic and budgetary reforms (hereinafter the ‘Wijninckx law’) provides for a maximum amount for pensions in the public sector (hereinafter the ‘Wijninckx cap’). The Wijninckx cap applies to the pensions of staff members and members of the management bodies of, inter alia, public institutions of credit (organismes publics de crédit / openbare kredietinstellingen) such as the NBB, even though the NBB is organised as a public limited company, independent from the government. 1.2 The draft law adapts the rules applicable to the Wijninckx cap. In particular, the draft law would suspend the annual adjustment of the Wijninckx cap on the basis of the Belgian consumer price index from 1 July 2025 until 31 December 2029 . According to the explanatory memorandum accompanying the draft law, the draft law aligns with the 2025-2029 federal coalition agreement, which notably limits the indexation of the State pension for civil servants and persons with mixed public and private careers when the Wijninckx cap is exceeded. As noted in the consultation request accompanying the draft law, the

text: measures in the draft law primarily aim to reduce pension costs as part of broader fiscal measures addressing the fiscal sustainability risks faced by Belgium.

text: 2. Observations

text: 2.1 As the draft law applies to and directly affects the NBB’s board members and some of its staff, the draft law should primarily be examined from the perspective of central bank independence requirements . 2.2 Financial independence 2.2.1 Article 130 of the Treaty and Article 7 of the Statute of the European System of Central Banks and of the European Central Bank (hereinafter the ‘Statute of the ESCB’) require that third parties may not influence, directly or indirectly, a national central bank (NCB) in the performance of its tasks or as regards its ability to fulfil its mandate both operationally in terms of manpower, and in terms of appropriate financial resources . In this regard, Member States may not impair an NCB’s ability to employ and retain the qualified staff necessary for the NCB to perform independently the tasks conferred on it by the Treaty and the Statute of the ESCB. An NCB may not be put into a position where it has limited control or no control over its staff, or where the government of a Member State can influence its policy on staff matters. Amendments that lead to reductions in remuneration for members of an NCB’s decision-making body and its staff members should not interfere with that NCB’s powers to administer its own financial resources, including the funds resulting from any reduction in salaries that it pays. Autonomy in staff matters extends to issues relating to staff pensions . 2.2.2 To protect autonomy in staff matters, the ECB has consistently recommended in its previous opinions and in its convergence reports that any amendment to legislation on remuneration for members of an NCB’s decision-making bodies and its staff members should be decided in close and effective cooperation with the NCB, taking due account of its views, to ensure the ongoing ability of the NCB to independently carry out its tasks . 2.2.3 Situations where the government of a Member State exempts the NCB of that Member State from the scope of the legislation involved, while at the same time inviting the NCB to consider whether the underlying reasons for the legislative provisions can be achieved without prejudicing the performance of the NCB’s tasks under the Treaty, the Statute of the ESCB and national legislation , or where the relevant national legislative provisions provide that the public service pension plan is only applicable to the NCB with its consent, constitute examples of effective cooperation between a Member State government and an NCB. These approaches would allow the NBB to take into account the particularities of its own legal framework and special legal regime as well as any other relevant considerations – in

text: particular, obligations arising under the Treaty – in deciding upon the form and extent of its consent or objection to the application of the plan to NBB staff . 2.3 Personal independence of the members of the NBB’s decision-making bodies 2.3.1 Article 130 of the Treaty and Article 7 of the Statute of the ESCB prohibit national governments from seeking to influence the members of an NCB’s decision-making bodies in the performance of their tasks. The ECB understands that the Wijninckx cap applies generally to all public servants in Belgium who come within its scope, including the Governor of the NBB and the members of the NBB’s board of directors. In view of this, the draft law does not seek to influence the NBB’s decision-making bodies either directly or indirectly in the performance of their tasks. 2.3.2 However, to comply with the Treaty requirements with regard to the personal independence of members of an NCB’s decision-making bodies and to exclude any kind of influence on the members of an NCB’s decision-making bodies in the performance of their tasks, adjustments to the remuneration, including the pensions, of the Governor and other members of an NCB’s decision-making bodies who are involved in the performance of ESCB-related tasks may not affect the terms under which the current members of an NCB’s decision-making bodies have been appointed. Therefore, such adjustments may only apply to future appointments . The requirements in respect of the principle of financial independence discussed in paragraphs 2.2.1 to 2.2.3 must also be taken into account . 2.4 Compliance with the prohibition of monetary financing The ECB understands that any savings resulting from the suspension of the yearly adjustment of the Wijninckx cap on the basis of the Belgian consumer price index would be returned to the NBB, as the employer . The ECB understands that the draft law would not therefore trigger any financing by the NBB of the Belgian State that could raise concerns from the prohibition of monetary financing under Article 123 of the Treaty. This opinion will be published on EUR-Lex.

text: Done at Frankfurt am Main, 10 June 2025.

text: [signed]

text: The President of the ECB

text: Christine LAGARDE


title: Opinion of the European Central Bank of 25 June 2025 on access to cash and a constitutional right to payment in cash (CON/2025/14)

text: OPINION OF THE EUROPEAN CENTRAL BANK of 25 June 2025 on access to cash and a constitutional right to payment in cash (

text: ) Introduction and legal basis

text: On 13 June 2025 the ECB received a request from the Magyar Nemzeti Bank (MNB) for an opinion on a draft MNB decree on the detailed rules on the criteria for the installation of ATMs and on the burden and cost sharing of payment service providers (PSPs) (hereinafter the ‘draft MNB decree on ATMs’). On 24 March 2025 a Government decree on the emergency maintenance of automated teller machines (ATMs) (hereinafter the ‘first Government decree on ATMs’) was published in the Hungarian Official Gazette . On 14 April 2025 the fifteenth amendment to the Fundamental Law of Hungary (hereinafter the ‘amendment to the Fundamental Law’) was published in the Hungarian Official Gazette . On 12 May 2025 the Law on the installation of ATMs (hereinafter the ‘Law on ATMs’) was published in the Hungarian Official Gazette . On 29 May 2025 a decree of the Ministry of the National Economy on certain issues related to the accelerated deployment of ATMs starting in 2025 (hereinafter the ‘Ministerial decree on ATMs’) was published in the Hungarian Official Gazette . On 5 June 2025 a Government decree amending Government decrees related to the use of cash (hereinafter the ‘Government decree on cash’) and a Government decree on the emergency maintenance of ATMs (hereinafter the ‘second Government decree on ATMs’) were published in the Hungarian Official Gazette . The second Government decree on ATMs repealed the first Government decree on ATMs . On 20 June 2025 the Law amending certain laws in relation to the use of cash (hereinafter the ‘Law on cash’) was published in the Hungarian Official Gazette . The European Central Bank (ECB) has not been consulted by the Hungarian authorities on the amendment to the Fundamental Law, the Law on ATMs, the Law on cash, the first Government decree on ATMs, the Government decree on cash, the second Government decree on ATMs or the Ministerial decree on ATMs. The ECB has decided to deliver an own initiative opinion on the amendment to the Fundamental Law, the Law on ATMs, the Law on cash, the Government decree on cash, the second Government decree on ATMs

text: 1 Az automata bankjegykiadó gépek működésének veszélyhelyzeti fenntartásáról szóló 49/2025. (III. 24.) Korm. rendelet, Magyar Közlöny 2025/33 (III. 24.).

text: 2 Magyarország Alaptörvényének tizenötödik módosítása, Magyar Közlöny 2025/41 (IV. 14.).

text: 3 Az automata bankjegykiadó gépek telepítéséről szóló 2025. évi XVIII. törvény, Magyar Közlöny 2025/55 (V. 12.).

text: 4 Az automata bankjegykiadó gépek 2025-ben kezdődő, gyorsított telepítésével kapcsolatos egyes kérdésekről szóló 16/2025. (V. 29.) NGM rendelet, Magyar Közlöny 2025/63 (V. 29.).

text: 5 Kormányrendeletek készpénzhasználattal összefüggő módosításáról szóló 128/2025. (VI. 5.) Korm. rendelet az automata bankjegykiadó gépek működésének veszélyhelyzeti fenntartásáról szóló 129/2025. (VI. 5.) Korm. rendelet, Magyar Közlöny 2025/67 (VI. 5.).

text: 6 Article 4 of the second Government decree on ATMs.

text: 7 Egyes törvényeknek a készpénzhasználattal összefüggő módosításáról szóló 2025. évi LXII. törvény, Magyar Közlöny 2025/74 (VI. 20.). and the Ministerial decree on ATMs. This opinion is also the ECB’s response to the MNB’s consultation request on the draft MNB decree on ATMs. 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 and third indents, of

text: Council Decision 98/415/EC

text: , as the amendment to the Fundamental Law, the Law on ATMs, the Law on cash, the Government decree on cash, the second Government decree on ATMs, the Ministerial decree on ATMs and the draft MNB decree on ATMs relate to means of payment and/or the MNB. In accordance with

text: Article 17.5

text: , first sentence, of the Rules of Procedure of the European Central Bank, the Governing Council has adopted this opinion.

text: 1. Purpose of the amendment to the Fundamental Law, the Law on cash, the Government decree on cash, the Law on ATMs, the second Government decree on ATMs, the Ministerial decree on ATMs and the draft MNB decree on ATMs

text: 1.1 The amendment to the Fundamental Law 1.1.1 The amendment to the Fundamental Law establishes the right to payment in cash as a fundamental right under Hungarian law. According to the explanatory memorandum accompanying the amendment, cash is legal tender that is physically independent from digital systems, banks and other third parties. Only the maintenance of cash circulation can ensure that the functioning of the economy does not become completely vulnerable to electronic financial systems, which may be vulnerable for technical reasons or due to the market. It is therefore necessary to enshrine at constitutional level the principle that the possibility to pay in cash is a fundamental right. The enshrinement of this right at constitutional level also guarantees that the possibility of paying in cash remains available to all, thus avoiding the possibility of financial exclusion. 1.1.2 The right to payment in cash supplements the right to own and inherit property, which is contained in the chapter listing the fundamental rights of citizens . Under the current provision, everyone has the right to own and inherit property, as well as to make payments in cash, and owning property is connected to social responsibility. 1.1.3 The Fundamental Law provides that fundamental rights can be limited to the extent strictly necessary for the purpose of enforcing another fundamental right or protecting a constitutional value, in proportion to the aim pursued and with due regard for the essential content of the fundamental right . 1.1.4 The Fundamental Law provides that the official currency of Hungary is the forint , and under Hungarian law banknotes and coins issued by the MNB in the official currency of Hungary are the legal tender of Hungary .

text: Council Decision 98/415/EC of 29 June 1998

text: on the consultation of the European Central Bank by national authorities regarding draft legislative provisions (OJ L 189, 3.7.1998, p. 42, ELI: https://eurlex.europa.eu/eli/dec/1998/415/oj).

text: 9 Article XIII (1) in Chapter ‘Freedom and responsibility’ (‘Szabadság és felelősség’) of the Fundamental Law of Hungary.

text: 10 Article I (3) of the Fundamental Law of Hungary.

text: 11 Article K of the Fundamental Law of Hungary. 1.2 The Law on cash 1.2.1 According to the explanatory memorandum accompanying the Law on cash, the purpose of the Law is to ensure that citizens have, in their private relations, the possibility to pay in cash, in addition to digital payment options, for the purchase of goods and services. 1.2.2 In particular, the Law on cash provides that undertakings must ensure the possibility for consumers to pay the price of goods in cash, with the exception of cross-border online sales and online service contracts. The Law on cash also provides that consumers must have the possibility to pay in cash for specified commercial and service activities, except for online service contracts for the crossborder provision of services. The Law on cash also provides that where the price in the case of a transfer of ownership of land is paid by means of a lawyer's or a notary’s deposit, the price provided for in the contract may be paid in cash. 1.3 The Government decree on cash 1.3.1 The Government decree on cash aims to make the use of cash more widely available to citizens, in accordance with the amendment to the Fundamental Law . 1.3.2 In particular, the Government decree on cash provides that claimants of certain housing subsidies in small municipalities and applicants for a loan scheme for housing may pay, in cash, the purchase price for buying a dwelling or the purchase price difference for exchanging a dwelling. Credit institutions involved in the provision of these subsidies and loans remain obliged to transfer their payment to the account indicated by the sellers of the dwellings . 1.4 The Law on ATMs 1.4.1 The Law on ATMs aims to promote the safe supply of cash to the public, with particular attention to the needs of people living in rural areas and areas with lower population density. In this respect, the Law on ATMs seeks to guarantee the operation of the ATM network at the municipal level . 1.4.2 Under the Law on ATMs, PSPs providing payment account management services and issuing payment instruments for consumers must provide cash withdrawal services for account holders who are consumers in any municipality. This service may be provided by means of ATMs, and PSPs may agree to jointly install and operate an ATM. The local government of the municipality concerned must

text: 13 Amending the Law on Consumer Protection, a fogyasztóvédelemről szóló 1997. évi CLV. törvény, Magyar Közlöny 1997/119 (XII. 23.).

text: 14 Amending the Law on Commerce and the Law on the general rules on commencing and pursuing service activities, a kereskedelemről szóló 2005. évi CLXIV. törvény, Magyar Közlöny 2005/168 (XII. 25.), a szolgáltatási tevékenység megkezdésének és folytatásának általános szabályairól szóló 2009. évi LXXVI. törvény, Magyar Közlöny 2009/94 (VII. 8.).

text: 15 Amending the Law on certain provisions and transitional rules in connection with the Law on the trade of agricultural and forestry land, a mező- és erdőgazdasági földek forgalmáról szóló 2013. évi CXXII. törvénnyel összefüggő egyes rendelkezésekről és átmeneti szabályokról szóló 2013. évi CCXII. törvény, Magyar Közlöny 2013/207 (XII. 12.).

text: 16 Preamble to the Government decree on cash.

text: 17 Articles 1 and 2 of the Government decree on cash, amending Government decrees on housing subsidies in small municipalities and on a preferential loan scheme for housing for families, a kistelepüléseken nyújtható otthonteremtési támogatásokról szóló 302/2023. (VII. 11.) Korm. rendelet, a családok otthonteremtését támogató kedvezményes CSOK Plusz hitelprogramról szóló 518/2023. (XI. 30.) Korm. rendelet.

text: 18 Preamble to the Law on ATMs. provide a suitable location free of charge for cash withdrawal services and cooperate with the PSPs in shaping the appropriate conditions. The PSP must provide cash withdrawal services even if the municipality is unable to provide the appropriate conditions . 1.4.3 Under the Law on ATMs, credit institutions that operate ATMs must not suspend the operation of ATMs that were already in operation at the date of entry into force of the Law on ATMs, and bank branches must not discontinue their cash withdrawal services for payment accounts . 1.4.4 The MNB is given sanctioning powers in its supervisory function to enforce the Law on ATMs. The level of possible fines ranges from HUF 2 million to HUF 200 million. Fines for breach of the obligation to provide cash withdrawal services constitute direct revenues of the central budget . 1.5 The second Government decree on ATMs 1.5.1 The second Government decree on ATMs stipulates that ensuring access to cash is a priority in rural areas, and it is therefore essential that the operation of ATMs that were already in operation at the date of entry into force of the Law on ATMs is not discontinued . 1.5.2 The second Government decree on ATMs derogates from the Law on ATMs during the current state of emergency declared due to the armed conflict and humanitarian catastrophe in Ukraine by allowing credit institutions to suspend the operation of an ATM, in justified cases. A justified case may be based, for instance, on the average cash withdrawal turnover in the given municipality or district and the termination of the lease over the premises on which the ATM is located . 1.6 The Ministerial decree on ATMs 1.6.1 The Ministerial decree on ATMs sets the deadline for PSPs to install ATMs in municipalities with over 500 inhabitants according to the 2022 census data of the Hungarian Central Statistical Office. For municipalities with a population of more than 1000, the deadline is 31 December 2025, and for municipalities with a population of more than 500, the deadline is 31 December 2026 . 1.6.2 The Ministerial decree on ATMs also sets out the criteria for the location in which the local government of the municipality concerned must provide for the installation of ATMs. The location has to be, amongst other criteria, easily accessible and barrier-free, adequately illuminated, with good transport connections, preferably close to places where people do their daily business, and where the access route is not restricted. If such a location cannot be provided on the territory of the municipality, the local government must examine other locations in cooperation with the PSP . 1.7 The draft MNB decree on ATMs

text: 22 Preamble to the second Government decree on ATMs.

text: 24 Article 1 of the Ministerial decree on ATMs.

text: 25 Article 2 of the Ministerial decree on ATMs. 1.7.1 The draft MNB decree on ATMs, taking into account the provisions of the Ministerial decree on ATMs, sets out the detailed criteria for determining the PSPs required to install and operate ATMs per municipality and detailed rules on the equal sharing of the burden and costs of PSPs. The draft MNB decree on ATMs also creates groups of municipalities affected by the obligation to install ATMs and determines the PSPs obliged to install ATMs there . 1.7.2 PSPs that choose to jointly fulfil their obligation to install and operate an ATM in the municipalities concerned must designate the PSP which is obliged to notify and provide data to the MNB. PSPs may also agree amongst themselves to switch municipalities and may take over from each other the obligation to install an ATM . 1.7.3 If the scope of PSPs changes after the entry into force of the draft MNB decree on ATMs, the MNB must carry out a new examination based on the relevant criteria and, on the basis of the results of this examination, the MNB must again determine the list of PSPs obliged to install and operate an ATM .

text: 2. General observations

text: 2.1 The ECB notes that, during the last months, the Hungarian authorities have adopted a new amendment to the Fundamental Law, as well as a large number of laws and decrees, all related to cash acceptance and access to cash. A nationwide cash supply network requires a complex infrastructure. Due to this, the stakeholders involved need appropriate preparation time to adapt regulatory changes to mitigate potential network side effects and avoid any potential overlap with rules currently in force. 2.2 The ECB understands that once the state of emergency declared due to the armed conflict and humanitarian catastrophe in Ukraine is terminated, the Law on ATMs will be restored to its full effect, as a consequence of which credit institutions may no longer suspend the operation of ATMs, even in justified cases. 2.3 The ECB understands that electronic payment instruments are increasingly used as a method of payment in Hungary, while the use of cash is declining. According to the MNB, electronic payment alternatives are now available in virtually all situations in Hungary and the use of electronic payments has grown significantly in recent years . Despite the significant increase in the use of electronic payments, cash remains widely used in Hungary, and according to the MNB there are significant regional and demographical differences in cash usage customs within the country . In 2023, 66 % of stores in Hungary were cash-intensive, meaning that the majority of stores saw more cash purchases than electronic purchases . This indicates that cash is still the most commonly used means of payment in Hungary.

text: 26 Preamble, Articles

text: and

text: and Annex 1 of the draft MNB decree on ATMs.

text: 29 Payment Systems Report 2024, Magyar Nemzeti Bank, p. 7.

text: 30 Payment Systems Report 2024, Magyar Nemzeti Bank, pp. 14 and 19.

text: 31 Payment Systems Report 2024, Magyar Nemzeti Bank, p. 47. 2.4 Although electronic payment instruments are used increasingly in a number of Member States, cash continues to play an important role in society and is still widely used throughout the entire population . Cash is a well-established and secure means of payment providing for immediate settlement of debts and direct control over the payer’s spending. It is currently the only payment instrument that allows citizens to settle a transaction in central bank money which is also settled instantly, while, importantly, ensuring privacy . Cash payments facilitate the inclusion of the entire population in the economy by allowing it to settle any kind of financial transaction in this way, thus ensuring freedom of choice as to the method of payment for all citizens . The ECB agrees with the view expressed in the explanatory memorandum accompanying the amendment to the Fundamental Law that the maintenance of cash circulation can ensure that the functioning of the economy does not become completely dependent on electronic financial systems. Furthermore, the ability to pay in cash remains particularly important for certain groups in society that, for various legitimate reasons, prefer to use cash rather than other means of payment, or who do not have access to bank services and electronic means of payments. These groups include disabled citizens, immigrants, socially vulnerable citizens, elderly people, minors and others with limited or no access to digital payment services . 2.5 While the ECB holds a positive view of further innovation and development in the field of electronic payment instruments, the ECB also welcomes the core objectives of the Law on ATMs and the second Government decree on ATMs to facilitate the continued use of cash in Hungarian society by an adequate level of access to cash services throughout Hungary, including in rural areas and areas with a lower population density. The availability and accessibility of cash and its fallback function in case of disruptions contribute to trust in the financial system and enhance resilience, which is important for the smooth functioning of monetary policy . In this context, the ECB notes that that an adequate level of access to cash services should guarantee reasonable and proportionate cash service networks to avoid that citizens have problems accessing their money in cash. The ECB also notes that the MNB has a mandate to define the Hungarian legal framework on access to cash . Based on this mandate, the MNB issued a decree in 2023 (hereinafter the ‘MNB decree on banknotes’) that sets out rules concerning the size and the territorial coverage of the Hungarian ATM network. The Hungarian nationwide access to cash infrastructure currently works in accordance with the MNB decree on banknotes. The ECB has previously welcomed the MNB’s initiative to regulate

text: 32 See, for example, paragraph 1.7 of Opinion

text: 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: https://eur-lex.europa.eu/eli/C/2023/1355/oj), paragraph 2.1 of Opinion

text: , paragraph 2.1 of Opinion

text: , paragraph 2.1 of Opinion

text: and paragraph 2.5 of Opinion

text: . The ECB has stated its neutrality regarding different means of payment, which means that it does not favour one instrument over another. See paragraph 2.1 of Opinion

text: . All ECB opinions are published on EUR-Lex.

text: 33 See paragraph 2.1 of Opinion

text: , paragraph 2.1 of Opinion

text: , paragraph 2.1 of Opinion

text: , paragraph 2.1 of Opinion

text: and paragraph 2.1 of Opinion

text: 34 See paragraph 2.1 of Opinion

text: , paragraph 2.1 of Opinion

text: , paragraph 2.1 of Opinion

text: and paragraph 2.1 of Opinion

text: 35 See, for example, paragraph 2.1 of Opinion

text: , paragraph 2.1 of Opinion

text: , paragraph 2.1 of Opinion

text: , paragraph 2.1 of Opinion

text: and paragraph 2.1 of Opinion

text: 36 See paragraph 2.2 of Opinion

text: , paragraph 2.2 of Opinion

text: , paragraph 2.2 of Opinion

text: and paragraph 2.5 of Opinion

text: 37 See

text: Article 23

text: /A of the Law on the MNB.

text: 38 A bankjegyek feldolgozásáról, forgalmazásáról, valamint hamisítás elleni védelmével kapcsolatos technikai feladatokról szóló 1/2023. (I. 17.) MNB rendelet, Magyar Közlöny 2023/8 (I. 17.). the infrastructure network of credit institutions used to carry out cash transactions and facilitate cash flows with the objective of ensuring a minimum level of availability of cash for their customers throughout Hungary . The ECB notes that the Law on ATMs might conflict with the requirements of the MNB decree on banknotes, entailing the risk of unintended side effects such as increased costs for credit institutions and PSPs being obliged to install an ATM in a municipality where they potentially do not have any customers. 2.6 While the official currency in Hungary is the forint, not the euro, the ECB considers it important that all Member States, including non-euro area Member States, take appropriate measures to ensure that credit institutions and branches operating within their territories provide adequate access to cash services through ATMs or branch cashiers. This is crucial to facilitate the continued use of cash . 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 . 2.7 In addition, the ECB wishes to note that a minimum level of in-person cash withdrawal services – whether through ATMs or branch cashiers – may be needed at credit institutions, especially for those groups in society that do not have access to electronic means of payment. Such in-person cash withdrawal services would also enable access to cash in situations where ATM networks are temporarily unavailable. Moreover, customers should have sufficient and effective access to cash deposit services at credit institutions. This would support the acceptance of cash by payees (e.g. merchants and public sector entities) by ensuring that they can conveniently convert cash into commercial bank money and manage their liquidity efficiently, for instance to pay their suppliers and employees . 2.8 The ECB welcomes the financial sanctions that may be imposed on credit institutions under the Law on ATMs, which should facilitate the enforcement of their requirements under the Law on ATMs .

text: 3. Constitutional law on the right to payment in cash

text: 3.1 The ECB understands that the right to payment in cash under the Fundamental Law refers to payments executed in the legal tender of Hungary. If and when the euro is introduced as Hungary’s legal tender, the amendment to the Fundamental Law, in the light of its objective and content, would establish legal rules governing the status of legal tender of euro banknotes, which is an area of exclusive competence of the Union under Article 133 of the Treaty for Member States whose currency is the euro. 3.2 The concept of ‘legal tender’ as a means of payment denominated in a currency unit has been considered by the Court of Justice of the European Union. In particular, the Court of Justice has

text: 39 See paragraph 2.3 of Opinion

text: 40 See paragraph 2.3 of Opinion

text: , paragraph 2.3 of Opinion

text: , paragraph 2.4 of Opinion

text: and paragraph 3.2 of Opinion

text: 41 See paragraph 1.2 of Opinion

text: , paragraph 2.2 of Opinion

text: and paragraphs 2.3 and 2.7 of Opinion

text: 42 See paragraph 2.4 of Opinion

text: 43 See paragraph 2.5 of Opinion

text: 44 See paragraph 3.2.3 of Opinion

text: and paragraph 3.2.3 of Opinion

text: . clarified that the concept of ‘legal tender’ signifies that this specific means of payment cannot generally be refused in settlement of a debt denominated in the same currency unit, at its full face value, with the effect of discharging the debt. In clarifying the concept of ‘legal tender’ under Union law, the Court of Justice took into consideration

text: Commission Recommendation 2010/191/EU

text: , which provides useful guidance for the interpretation of the relevant provisions of Union law. Point 1 of Recommendation

text: states that, where a payment obligation exists, the legal tender of euro banknotes and coins should imply (a) mandatory acceptance of those banknotes and coins; (b) their acceptance at full face value; and (c) their power to discharge from payment obligations. According to the Court of Justice, this shows that the concept of ‘legal tender’ encompasses, inter alia, an obligation in principle to accept banknotes and coins denominated in euro for payment purposes . 3.3 The Court of Justice has clarified that the concept of ‘legal tender’ is a concept of Union law that must be given an autonomous and uniform interpretation throughout the Union . Insofar as it allows the Union legislature to lay down the measures necessary for the use of the euro as the single currency, the Court of Justice clarified that Article 133 of the Treaty empowers the Union legislature alone to specify the legal rules governing the status of legal tender accorded to banknotes and coins denominated in euro, insofar as that is necessary for the use of the euro as the single currency. Furthermore, the Union legislature’s exclusive competence precludes any competence on the part of the Member States in the matter, unless they have been empowered by the Union to do so or for the implementation of Union acts . In this respect, the ECB notes that 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 (hereinafter the ‘proposed regulation on the legal tender of euro cash’), which will establish rules on the legal tender of euro banknotes and coins in binding Union secondary law . The explanatory memorandum accompanying the proposed regulation on the legal tender of euro cash states that discussions within the Euro Legal Tender Expert Group (ELTEG) confirmed the existence of uncertainty and important differences regarding the practical application of the concept of legal tender across the euro area . These differences would justify establishing rules on the legal tender of euro cash in a regulation adopted under Article 133 of the Treaty. 3.4 Taking account of the foregoing, the ECB invites the Hungarian authorities, if and when the euro is adopted in Hungary, to guarantee that the right to make payments in cash will be amended to merely refer to the relevant provisions of Union law .

text: 45 Commission Recommendation of 22 March 2010 on the scope and effects of legal tender of euro banknotes and coins (OJ L 83, 30.3.2010, p. 70, ELI: https://eur-lex.europa.eu/eli/reco/2010/191/oj).

text: 46 See judgment of the Court of Justice of 26 January 2021, Hessischer Rundfunk,

text: and

text: , ECLI:EU:C:2021:63, paragraphs 46 to 49.

text: 47 See judgment of the Court of Justice of 26 January 2021, Hessischer Rundfunk,

text: and

text: , ECLI:EU:C:2021:63, paragraph 45.

text: 48 See judgment of the Court of Justice of 26 January 2021, Hessischer Rundfunk,

text: and

text: , ECLI:EU:C:2021:63, paragraphs 50 to 52.

text: 49 COM(2023) 364 final. For the ECB opinion on the proposal, see Opinion

text: 50 See section 3, page 4 of the explanatory memorandum accompanying the proposed regulation on the legal tender of euro cash and the final report of the Euro Legal Tender Expert Group (ELTEG) of 6 July 2022, available on the Commission’s website at https://commission.europa.eu/index_en. See also Opinion

text: 51 See paragraph 3.3.3 of Opinion

text: and paragraph 3.2.6 of Opinion

text: . This opinion will be published on EUR-Lex. Done at Frankfurt am Main, 25 June 2025. [signed] The President of the ECB Christine LAGARDE


text: COM(2025) 301 final.

text: COM(2025) 372 final.

sprak: sv

title: Europeiska centralbankens yttrande av den 2 juli 2025 om ett förslag till rådets förordning om ändring av förordning (EG) nr 974/98 vad gäller införandet av euron i Bulgarien och ett förslag till rådets förordning om ändring av förordning (EG) nr 2866/98 vad gäller omräkningskursen till euron för Bulgarien (CON/2025/15)

text: Inledning och rättslig grund

text: Den 5 juni 2025 mottog Europeiska centralbanken (ECB) en begäran från Europeiska unionens råd om ett yttrande över ett förslag till rådets förordning om ändring av förordning

text: (EG) nr 974/98

text: vad gäller införandet av euron i Bulgarien. Den 1 juli 2025 mottog ECB en begäran från Europeiska unionens råd om ett yttrande över ett förslag till rådets förordning om ändring av förordning

text: (EG) nr 2866/98

text: vad beträffar omräkningskursen till euron för Bulgarien.

text: ECB:s behörighet att avge ett yttrande grundar sig på

text: artikel 140.3 i fördraget om Europeiska unionens funktionssätt

text: . I enlighet med

text: artikel 17.5

text: första meningen i arbetsordningen för Europeiska centralbanken har detta yttrande antagits av ECB-rådet.

text: Observationer

text: 1. De föreslagna förordningarna kommer, efter upphävandet av Bulgariens undantag i enlighet med förfarandet i artikel 140.2 i fördraget, att möjliggöra införandet av euron som Bulgariens valuta.

text: 2. ECB välkomnar de föreslagna förordningarna.

text: Utfärdat i Frankfurt am Main den 2 juli 2025.

text: Christine Lagarde

text: ECB:s ordförande

text: (EG) nr 974/98

text: (EG) nr 2866/98

text: Europeiska unionens officiella tidning

text: III Förberedande akter

text: EUROPEISKA CENTRALBANKEN

text: Europeiska centralbanken


text: A kötelező tartalékráta mértékéről szóló 52/2023. (XI. 20.) MNB rendelet, Magyar Közlöny 2023/164 (XI. 20.). 2 A kötelező jegybanki tartalék kapcsán alkalmazandó kamatmértékekről szóló 49/2023. (X. 24.) MNB rendelet, Magyar Közlöny 2023/150 (X. 24.). 3

text: Council Decision 98/415/EC of 29 June 1998

text: 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). 4

text: Article 1

text: (b) of MNB decree 52/2023. (XI. 20.) on the required reserve ratio. The liabilities concerned are all liabilities included in a credit institution’s reserve base, except: (1) deposits and loans taken, the original maturity of which exceeds two years according to the MNB decree on data provision in force; (2) debt securities, provided that the maturity of the securities at the time of the issuance exceeds two years; and (3) repos. 5 All ECB opinions are published on EUR-Lex.

text: See, for example, paragraph 2.6 of Opinion

text: , paragraph 2 of Opinion

text: , paragraph 2.2 of Opinion

text: and paragraph 2.1 of Opinion

text: . 7 Article 282(4) of the Treaty and Article 42.2 of the Statute of the European System of Central Banks and of the European Central Bank.

title: Opinion of the European Central Bank of 14 July 2025 on the required reserve ratio of the Magyar Nemzeti Bank (CON/2025/16)

text: OPINION OF THE EUROPEAN CENTRAL BANK of 14 July 2025 on the required reserve ratio of the Magyar Nemzeti Bank (

text: ) Introduction and legal basis

text: On 16 June 2025 the European Central Bank (ECB) received a request from the Magyar Nemzeti Bank (MNB) for an opinion on a draft MNB decree amending the MNB decree on the required reserve ratio and the MNB decree on the interest rates related to required reserves (hereinafter the ‘draft MNB decree’). 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

text: Article 2(2) of Council Decision 98/415/EC

text: , as the draft decree relates to instruments of monetary policy of a Member State that has not adopted the euro. In accordance with

text: Article 17.5

text: , first sentence, of the Rules of Procedure of the European Central Bank, the Governing Council has adopted this opinion.

text: 1. Purpose of the draft MNB decree

text: 1.1 Currently, the required reserve ratio decided by the MNB is a uniform 10 % for certain liabilities . The option to choose among different reserve ratios was removed in 2023, in relation to which the ECB adopted Opinion

text: . 1.2 The draft MNB decree aims to decrease the required reserve ratio from the current 10 % to 8 %. According to the explanatory memorandum accompanying the draft MNB decree, this planned amendment has two purposes. First, the average interbank liquidity decreased from 2024 to 2025, and the reduction of the required reserve ratio aims to contribute to counterbalancing this effect. Second, the MNB aims to maintain credit institutions’ lending capacities and preserve the role of reserve requirements in steering short-term interest rates to ensure effective monetary policy transmission. 1.3 For background, the explanatory memorandum accompanying the draft MNB decree explains that a technical amendment to the MNB decree on the interest rates related to required reserves is also

text: needed to clarify that the extent of unremunerated reserves remains unchanged in the percentage of the liabilities subject to reserve requirements. Thus, the MNB will continue not to pay any interest on up to 2,5 % of the liabilities subject to reserve requirements.

text: 2. General observations

text: 2.1 As previously noted by the ECB , Member States whose currency is not the euro retain their powers in the field of monetary policy according to national law . On the introduction of the euro, Hungary’s monetary policy would be the single monetary policy for the euro and would need at that time to be consistent with the Eurosystem’s operational framework. Credit institutions should therefore be familiar with the requirements that will apply to them once the single monetary policy is implemented in Hungary.

text: This opinion will be published on EUR-Lex following its adoption and in any case no later than six months following its adoption.

text: Done at Frankfurt am Main, 14 July 2025.

text: [signed]

text: The President of the ECB

text: Christine LAGARDE


text: Available on the website of the Croatian Parliament at www.sabor.hr.

text: See the discussion in the Finance and State Budget Committee of the Croatian Parliament, available on the website of the Croatian Parliament at www.sabor.hr.

text: 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).

text: See paragraph 2.4 of Opinion

text: , paragraph 2.1 of Opinion

text: and paragraph 3.2 of Opinion

text: . All ECB opinions are published on EUR-Lex.

text: See paragraph 2.2 of Opinion

text: , paragraph 1.2 of Opinion

text: 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 2.3 of Opinion

text: , paragraph 2.3 of Opinion

text: , paragraph 2.4 of Opinion

text: , and paragraph 2.1 of Opinion

text: . 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 .

text: See paragraph 2.2 of Opinion

text: , paragraph 1.2 of Opinion

text: , paragraph 2.2 of Opinion

text: and paragraphs 2.3 and 2.7 of Opinion

text: . See also Principle 6 of ELTEG III in the Final report of the Euro Legal Tender Expert Group (ELTEG) of 6 July 2022.

text: COM(2023) 364 final.

text: See paragraph 2.2 of Opinion

text: and paragraph 3.3 of Opinion

text: See paragraph 2.7 of Opinion

title: Opinion of the European Central Bank of 14 July 2025 on the elimination of certain fees related to payment accounts and cash withdrawals (CON/2025/17)

text: OPINION OF THE EUROPEAN CENTRAL BANK of 14 July 2025 on the elimination of certain fees related to payment accounts and cash withdrawals (

text: ) Introduction and legal basis

text: On 15 May 2025 the Government of the Republic of Croatia sent to the Croatian Parliament for parliamentary procedure a draft law amending the Law on comparability of fees related to payment accounts, payment account switching and access to basic accounts (hereinafter the ‘draft law’). The European Central Bank (ECB) has not been consulted by the Croatian authorities on the draft law . The ECB has decided to deliver an own initiative opinion on 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 and fifth indents, of

text: Council Decision 98/415/EC

text: , as the draft law relates to means of payment and payment and settlement systems. In accordance with

text: Article 17.5

text: 1. Purpose of the draft law

text: 1.1 The draft law prohibits certain fees that may currently be charged by credit institutions in respect of the opening, managing and closing of accounts, using online or mobile banking, depositing and withdrawing cash at counters and automated teller machines (ATMs), receiving cash payments in euro from Croatia or abroad, issuing and using debit cards and paying with cards at points of sale. According to the draft law, these services can be provided free of charge in one of two ways: (1) by opening a basic account or (2) by contracting with a bank for the provision of a package of free services for the account to which citizens receive their salary, pension, scholarship or other regular income. 1.2 Fees on basic accounts 1.2.1 The draft law provides that a credit institution may not charge a consumer who holds a basic account and who belongs to a vulnerable group a fee in respect of the following services: (1) opening, maintaining and closing a basic account; (2) internet or mobile banking services at the choice of the credit institution; (3) the deposit of cash into a basic account at a counter or ATM, with the exception

text: of the processing of coins; (4) the withdrawal of cash from a basic account at a counter or ATM of the credit institution holding the basic account; (5) the inflow of national and cross-border payment transactions in euro; (6) the regular issuance of a debit card and its use; and (7) the execution of payments by debit card at physical points of sale. 1.2.2 A credit institution is obliged to enable a consumer belonging to a vulnerable group, on a monthly basis and free of charge, to perform ten national and/or cross-border credit transfers (including instant credit transfers and standing orders) and/or direct debits in euro from the basic account for which the credit institution otherwise charges the consumer a fee according to its usual pricing policy. The number of free payment transactions excludes credit transfers that are not made in branches of the credit institution or via internet or mobile banking. Fees charged by a credit institution to a consumer belonging to a vulnerable group for the execution of payment transactions that exceed this number must be reasonable. For services that the credit institution provides to the consumer in addition to the basic account, and which are not specified in the draft law, the credit institution may charge the consumer a fee if it otherwise charges it according to its usual pricing policy for a payment account that is not a basic account, in an amount that for an individual service cannot be higher than the fee it normally charges for each individual service. If a credit institution refuses to execute an authorised payment transaction because there are insufficient funds in the consumer’s basic account, the credit institution may not charge the consumer a fee for that transaction or for refusing to execute the transaction. 1.2.3 An overdraft is not allowed on a basic account. If the consumer’s basic account is brought into a negative balance for any reason, the credit institution may not charge the consumer interest on the negative balance. 1.2.4 The draft law provides that a credit institution that, according to the audited annual financial statements for the previous year, has total assets of more than EUR 1.99 billion is obliged to offer consumers a basic account, while other credit institutions can offer a basic account at their discretion. 1.3 Free service package 1.3.1 The draft law introduces a new option in the form of a ‘free service package’, under which, in general, the services described in paragraph 1.2.1 would have to be provided free of charge. This option is possible for existing current accounts to which regular income is received and will be triggered at the consumer’s request. Under this option, the credit institution will, at the client’s request, arrange an overdraft whose effective interest rate must not be higher than for other payment accounts. 1.3.2 Credit institutions are required to enable clients who already have an open current account to use the free service package without changing the International Bank Account Number (IBAN). 1.3.3 These provisions on free package services apply to credit institutions which offer payment account services to consumers in Croatia. 1.4 Establishment of a national ATM network 1.4.1 Regarding withdrawal of cash, a credit institution is obliged to enable a consumer to withdraw cash from the payment account containing the free service package, or to enable a consumer belonging

text: to a vulnerable group to withdraw cash from a basic account, twice a month, free of charge, at an ATM of any other credit institution in Croatia that is not the credit institution in which the consumer has the payment or basic account. As noted in the explanatory memorandum accompanying the draft law, this provision is part of an initiative to establish a national ATM network in Croatia that would allow citizens to withdraw money from ATMs of any bank without charge. This initiative is a response to citizens’ needs for better availability of cash services, cost reduction and the strengthening of financial inclusion, especially in areas where access to ATMs is difficult. In this regard, it is planned that the Croatian Government, Hrvatska narodna banka (HNB) and the credit institutions will sign a memorandum defining a framework for cooperation with the aim of establishing a single, interoperable ATM network throughout Croatia, which should be fully functional no later than 1 January 2027. The national ATM network will be considered established if, as of 1 January 2027, credit institutions ensure that consumers can withdraw cash from ATMs free of charge. Once the national ATM network is established, the fees that credit institutions currently charge consumers for withdrawing cash with debit cards from the ATMs of other credit institutions will be abolished and all ATMs in the national ATM network will be considered credit institutions’ own ATMs. The draft law provides that if the national ATM network is not established by 1 January 2027, credit institutions will have to enable consumers, as of 1 January 2027, to withdraw cash from a payment account containing a package of free services twice a month, free of charge, using an ATM of any other credit institution in Croatia that is not the credit institution at which the consumer has a payment account containing a package of free services.

text: 2 General observation

text: This opinion is limited to specific observations concerning the impact of the draft law on free of charge withdrawals of cash from ATMs. This opinion does not address issues that fall outside the ECB’s fields of competence, including, in particular, issues concerning consumer protection or competition issues outside the ECB’s fields of competence.

text: 3 Free of charge withdrawals of cash from ATMs

text: 3.1 The ECB welcomes the provisions of the draft law ensuring the withdrawal of cash free of charge from ATMs, which help to preserve the effectiveness of the legal tender status of euro banknotes. The ECB considers it important that all Member States put in place appropriate measures to ensure that credit institutions and branches operating within their territories provide adequate access to cash 4 5 services . This is crucial to facilitate the continued use of cash . Sufficient and effective access to

text: 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 . 3.2 The ECB welcomes the initiative to establish a national ATM network in Croatia, which would facilitate sufficient and effective access to cash throughout Croatia. Upon the establishment of a national ATM network all residents in Croatia will be able to withdraw cash free of charge from ATMs in a convenient manner. To achieve the objective of facilitating sufficient and effective access to cash throughout Croatia, it would be important for the national ATM network to maintain an adequate number of ATMs and ensure their appropriate geographical spread. The ECB also welcomes the prohibition on credit institutions charging for ATM cash withdrawals from basic accounts and accounts for which the ‘free services package’ has been opted into, alongside the provision enabling consumers who choose to opt into the ‘free services package’ to withdraw cash twice a month, free of charge, from an ATM of any other credit institution in Croatia, which are first steps towards the establishment of a national ATM network. 3.3 In this context, it is recalled that 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 (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 territories. 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 territories, in all their different regions, including urban and non-urban areas. It is envisaged that the ECB will be consulted by the Commission on the preparation of such implementing acts . Following adoption by the Commission of the implementing acts on the common indicators, Member States would need to monitor the level of access to cash throughout their territories based on the common indicators. If in the light of their assessment access to cash is deemed insufficient and/or ineffective, Member States would be obliged to take remedial measures. In this context, national legislation concerning access to cash would need to be reviewed and, if necessary, adjusted accordingly . 3.4 From the monetary policy perspective, the ECB also welcomes the measures in the draft law aimed at requiring Croatian credit institutions to provide a national ATM network. In its pursuance of price stability, the ECB must be able to rely on an appropriate transmission of its monetary policy towards the wider economy. Given the key role of credit institutions in the transmission of monetary policy, they should ideally offer access to currency in the form of cash throughout the territory so as to be accessible to all economic actors, including those who do not use digital banking services. At the

text: same time, the costs of implementation of the new obligations for credit institutions would need to be adequately accounted for in the draft law . This opinion will be published on EUR-Lex. Done at Frankfurt am Main, 14 July 2025. [signed]

text: The President of the ECB

text: Christine LAGARDE