As of 1 January 2026, the Netherlands will implement significant domestic amendments to the Dutch Money Laundering and Terrorist Financing (Prevention) Act (in Dutch: Wet ter voorkoming van witwassen en financiering van terrorisme, ‘’Wwft’’). These changes are intended to further strengthen the regulatory framework for preventing money laundering and terrorist financing. Companies doing business in the Netherlands or with Dutch counterparts should assess the impact of these amendments on their compliance obligations and update their internal policies accordingly.
This blog will elaborate on i) restrictions on cash payments, ii) the supervision by the Financial Economic Integrity Service (in Dutch: Dienst Financieel-Economische Integriteit, “DFEI”), iii) the cash acceptance obligation, and iv) the position of the Netherlands within the EU.
Restrictions on cash payments
Under Dutch law, the use of large cash amounts in business transactions is already subject to strict regulation. Until 1 January 2026, large cash payments are not prohibited as such, but were subject to strict client due diligence and reporting obligations under the Wwft.
The core element of the upcoming amendments is the introduction of a cash payment limit of €3,000. Effective as of 1 January 2026, the new Article 1f Wwft establishes an absolute prohibition on making or accepting cash payments of €3,000 or more for the sale or purchase of goods. This prohibition applies to traders of goods that fall within the scope of the Wwft and covers both individual transactions as well as combined or related transactions where the total amount reaches the threshold. It applies to cash payments made in or from the Netherlands and primarily concerns professional or commercial buyers and sellers of goods (traders). Services are excluded from this prohibition. The existing Wwft obligations remain fully applicable.
Until 1 January 2026, traders of goods fall within the scope of the Wwft for cash payments of €10,000 or more, and were therefore subject to Wwft obligations. With the new cash limit, these Wwft obligations will no longer apply to traders of goods.
Supervision of the Non-Financial Sector (DFEI)
As of 1 January 2026, the Dutch Wwft Supervision Office (in Dutch: Bureau Toezicht Wwft) and the Economic Enforcement Office (in Dutch: Bureau Economische Handhaving) will continue together as a department within the newly established DFEI. The DFEI is responsible for supervising compliance with the prohibition under Article 1f.
As a result, violating the prohibition under Article 1f of the Wwft is not merely a procedural oversight. Such a violation can qualify as an economic offence under the Dutch Economic Offences Act (in Dutch: Wet op de economische delicten), exposing companies and responsible individuals to significant legal consequences, including fines and potential criminal liability. Non-compliance is therefore a serious risk that businesses cannot afford to ignore.
Cash acceptance obligation
The European Court of Justice ruled that member states must ensure that cash remains widely accepted, since this is essential for allowing consumers to fully participate in society. After all, cash is a universal legal tender. Accordingly, a legal obligation to accept cash until the amount of €3,000 will be introduced under Article 6:113 (1) of the Dutch Civil Code (in Dutch: Burgerlijk Wetboek), requiring businesses to accept cash payments from consumers at the point of sale. This is expected for 2027.
Possible competitive disadvantage
With the introduction of the €3,000 cash limit for transactions of goods the variation in acceptance of cash amounts in the EU varies further. Despite the EU Commission’s acknowledgment that varying national approaches undermine a level playing field and disadvantage businesses in stricter jurisdictions, it nonetheless permits Member States to impose stricter cash limits. This creates a potential risk of competitive disadvantage for (Dutch) businesses compared to those in Member States with higher cash limits.
Please be aware that transaction processes are adjusted in time: as of 1 January 2026 no acceptance of cash above €3,000. Meanwhile, until 2027 your business is not obliged to accept amounts up to EUR 3.000,- in cash.
