ISO Compliance Insights & Best Practices
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ISO Compliance Insights & Best Practices
The AMLR cash payment limit is the rule in Article 80 of Regulation (EU) 2024/1624 that caps cash payments for goods and services at EUR 10,000, or the equivalent in another currency, whether the payment is made in one transaction or in several operations that appear to be linked. It applies across the European Union from 10 July 2027, and Member States may set lower limits of their own. For any business that accepts or makes large cash payments, the rule changes what can be sold for cash and how staff should respond when a customer arrives with a bag of banknotes.
This guide explains what Article 80 says, who it affects, what the exemptions are, how linked transactions work, and what to do now to prepare. The regulation itself is available on EUR-Lex, and this article is general information and not legal advice.
Article 80 limits large cash payments in exchange for goods or services. The text has seven paragraphs, and the main points are these.
| Paragraph | What it does |
|---|---|
| 1 | Sets the limit at EUR 10,000 or equivalent, for single or linked payments |
| 2 | Lets Member States set lower limits, after consulting the European Central Bank and notifying the Commission |
| 3 | Keeps existing lower national limits in force |
| 4 | Exempts payments between individuals acting non-professionally and deposits at credit institutions, e-money issuers and payment service providers |
| 5 and 6 | Require Member States to apply proportionate and effective penalties |
| 7 | Allows temporary suspension if electronic payment is unavailable |
Two features are worth noting. First, the cap applies to payments for goods and services, so it is about commercial transactions, not about holding cash. Second, it is a limit, not just a reporting threshold: above it, the cash payment should not be accepted, and the consequences of breach are set by national penalty rules.
Retailers of high-value goods, car dealers, jewelers, art and antique dealers, property developers, hospitality and service businesses, and anyone else who might be offered a large cash payment should look at the rule. The rule also concerns the customer, since a person making a cash payment above the cap is part of the breach. If you are an obliged entity under the wider regime, the cash limit sits alongside your customer due diligence and reporting duties. Our overview of the AMLR in 2027 explains the whole package, and the comparison of AMLR and AMLD shows how the regime differs from the earlier directives.
The regulation refers to “several operations which appear to be linked.” A customer who buys a piece of jewelry on Monday for EUR 6,000 in cash and returns on Wednesday to pay another EUR 6,000 for a matching item has probably made linked payments that add up to more than the cap. The same applies to a deposit followed by a balance, or instalments paid in cash on a short cycle, if they relate to one purchase. Look at the timing, the goods, the parties and any sign that the payment was split to avoid the limit.
The following example is hypothetical. A car dealer agrees a price of EUR 14,000. The customer offers EUR 9,000 in cash today and EUR 5,000 in cash tomorrow. The dealer should treat this as a single payment for one sale exceeding the cap, refuse the cash structure, and offer a bank transfer or card payment for at least the excess. The deal is recorded, the reason is noted, and the compliance officer is told if the behavior looks like an attempt to evade the limit.
EUR 10,000 is a ceiling that Member States may lower. The text lets them set a lower limit after consulting the European Central Bank and notifying the Commission, and existing national limits below EUR 10,000 continue to apply. Businesses that operate in several countries therefore need a table of the limit in each country where they take payments, and a process to keep it current. If your national rule is stricter, follow it.
Article 80 does not apply to payments between natural persons who are not acting in a professional capacity, or to deposits made at credit institutions, electronic money issuers or payment service providers. In the case of a deposit above the limit, the text calls for reporting to the financial intelligence unit within the deadlines it sets, so financial institutions need to look at their own procedures. Confirm the scope of the exemptions with counsel for your business model.
The limit does not replace customer due diligence. Cash payments below the cap can still raise red flags, particularly where the customer has no clear source of funds, pays repeatedly just under the limit or wants to avoid paperwork. The AMLR also sets thresholds for identifying occasional customers, including lower cash-related thresholds for some businesses, so read the relevant customer due diligence articles for your sector. Our guide to CDD versus EDD explains how ordinary and enhanced measures differ, and the AML compliance officer role covers who should own the escalation.
Most customers who are told they cannot pay a large sum in cash are not criminals. They may simply not know about the rule. Give staff a short, friendly script that explains that the law limits cash payments above the threshold, and offer alternatives straight away. Keep a record of the conversation without accusing the customer of anything. If the customer becomes evasive, insists on splitting the payment or asks how to get around the rule, treat that as a sign to escalate to the compliance officer, and do not discuss suspicions with the customer. Manager backup matters: a junior employee should never be left to negotiate with a customer who is pressing to make a large cash payment.
Report the number of refused and escalated cash payments to senior management on a regular basis, together with any repeat customers or patterns. Trends can show where to add controls, for example by removing cash acceptance at a site or for a product line. Review the policy at least once a year and whenever national rules change, and keep the approval and review history so that you can show it to a supervisor.
September 30, 2026
