ATMs: Proposed measures questioned after positive protocol evaluation

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23 April 2026 - 3 min Reading time

Febelfin has taken note of the communication from the competent ministers regarding the evaluation of the ATM Protocol and the announced Cash Action Plan.

 

Access to cash remains a key point of attention for Febelfin and its members. That is exactly why the ATM Protocol was concluded in 2023 between the government and the banking sector, with the aim of guaranteeing access to cash for everyone, both today and in the future. Febelfin notes that the evaluation of this protocol on its implementation at the end of 2025 by the competent ministers is positive and confirms that the sector takes its commitments seriously and complies with them.

Against that background, Febelfin is surprised by the communication from Minister Beenders stating that a significantly higher number of ATMs would need to be installed in the future. The measures referred to – such as the distance rules (2 km, 3 km and 5 km depending on the type of area) and the presence of at least one ATM per main municipality – already form an integral part of the commitments set out in the 2023 Protocol, which remains in force until the end of 2027.

According to the ATM Protocol, at least 2,369 locations and 4,061 ATMs should have been operational by the end of 2025. The evaluation of the protocol by the competent ministers and the National Bank of Belgium shows that this target has been achieved. According to the evaluation, only 7 additional ATM locations still need to be installed to fully meet all accessibility criteria. Media reports suggesting that 2,000 additional ATMs would need to be installed are therefore incorrect and not in line with the agreements in the protocol. The principle of 24 free cash withdrawals per year is also a service that banks have already been offering for more than 20 years (and is fairly unique in Europe) and is therefore not a new measure.

Furthermore, Febelfin takes note of the announced Cash Action Plan and welcomes the fact that consideration is being given to a broader and forward-looking vision about cash. At the same time, we question the need to embed existing commitments in a binding legal framework with sanctions, while the evaluation confirms that the sector is meeting its commitments. This sends a signal to banks that is difficult to understand.

We would therefore like to emphasise that there is as yet no agreement with the sector on this binding legal framework with any potential new measures. Febelfin has taken note of the ministers’ intentions, but further dialogue will be necessary. We will therefore analyse this Action Plan thoroughly and discuss it with our members.

Febelfin remains willing to reflect together with the competent ministers on the future of cash after the expiry of the current protocol. The sector is committed to continuing to guarantee access to cash, both today and in the future, including beyond 2027. In the coming months, Febelfin wishes to engage in constructive dialogue on this matter with the ministers concerned.