Restrictions on the use of cash
Although cash remains legal tender, its use is becoming increasingly restricted. As of January 1, 2026, a ban on cash payments of EUR 3,000 or more will apply in the Netherlands. In this blog, we will explain what the ban entails and what we can do for you.
What does the ban mean?
The ban means that payments for an amount of EUR 3,000 or more must be handled electronically. These may no longer be made in cash. Payments may also not be artificially split to stay below the limit even if the total amount is higher, also known as ‘smurfing’. This is prohibited, as it is seen as an evasion of the ban.
Previously, entrepreneurs were required to conduct customer due diligence for cash payments of EUR 10,000 or more. Due to the current ban on cash payments of EUR 3,000 or more, this customer due diligence will lapse for many traders. Cash payments of EUR 10,000 will then no longer be permitted.
Does the ban apply to me?
The ban applies to transactions between entrepreneurs who buy or sell goods to each other and transactions between entrepreneurs and customers (such as at companies and shops). A transaction between two private individuals (for example, via Marktplaats) does not appear to fall under this ban. At present, the ban does not yet apply to the provision of services (such as hairdressers and travel agencies).
Why was this ban introduced?
This new obligation stems from the Money Laundering and Terrorist Financing (Prevention) Act (Wwft). Large amounts of cash are often used in criminal activity. Cash is difficult to trace because banks cannot see where the money comes from or where it goes. By setting a legal limit, the government hopes to restrict money laundering.
What if I do not comply with my Wwft obligations?
Failure to comply with these obligations can have unpleasant consequences for you. The Wwft Supervision Office monitors compliance with the Wwft and can initiate investigations. This can take place at your office, but you may also receive a letter of inquiry. If it is established that you are not complying with the Wwft, or are doing so insufficiently, the supervisor can impose an administrative sanction in the form of an order subject to a penalty or an administrative fine. In more serious cases, you may be subject to criminal prosecution.
Do you suspect that you have failed to meet certain obligations? Or is an investigation underway? We can assist you in identifying the points on which you may have fallen short. We can also manage communication if an investigation is in progress.
Do you suspect that you have fallen short in your obligations? Then please contact us. You can, of course, also contact us if you simply require more information about obligations that were not addressed in this article. Our experienced and specialized lawyers are ready to assist you.
