The €10,000 cash limit and what it means for traders in goods and services
The AMLR caps cash payments at €10,000 for traders in goods and services across the EU, with Member States free to set a lower limit. Who is affected, what must be refused and what obliged entities must record.
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The AMLR introduces the first EU-wide cap on cash payments: persons trading in goods or providing services may not accept or make a cash payment of €10,000 or more, whether in one transaction or in several linked operations. Member States may set a lower limit, and several already have. The cap applies from 10 July 2027.
Who is affected
Every trader in goods or services, not only the dealers in high-value goods who are obliged entities today. A car dealer, a jeweller, an art gallery, a furniture retailer, a contractor: all must refuse cash above the limit. Payments between natural persons acting privately are excluded, as are payments made or deposited at credit institutions, payment institutions and e-money institutions.
Linked operations
Splitting a purchase into several cash payments does not escape the cap. Payments that appear to be linked, for example instalments on one contract, count together. Traders need a way to recognise linked operations, which means recording cash payments with the customer and the purpose.
Obliged entities among traders
Dealers in precious metals and stones, and traders in other high-value goods above the thresholds set in the AMLR, remain obliged entities with full customer due diligence and reporting obligations. For them the cash cap comes on top of due diligence; the cash payments they still accept below the limit trigger the occasional-transaction rules.
Supervision and sanctions
Member States designate an authority to supervise the cap and set penalties for breaches. In the Netherlands the supervision of traders sits with the Bureau Financieel Toezicht and the tax authority for parts of the sector; the implementation act allocates the new task.
What to do now
- Traders: set a policy that refuses cash at or above the applicable limit, train cashiers and record cash payments with customer details to detect linked operations.
- Obliged-entity traders: align the policy with the occasional-transaction thresholds and the reporting process.
- Everyone: check the national limit in each country where you sell; it can be lower than €10,000.
The dashboard tracks the AMLR provisions for dealers in goods when the entity filter is set to other obliged entities.