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Monitoring compliance with the rules and regulations on recirculation of euro banknotes and coins – requirements and sanctions


Published: 23 February 2022

We have enforcement powers under Section 9c of the Bank Act, Section 11 of the Coinage Act and Article 6a of Regulation (EC) 1338/2001, as amended by Regulation (EC) 44/2009. This means that we are authorised to impose an administrative fine or an order subject to penalty.

The requirements for checking euro banknotes and the obligation to report on these checks to DNB are further specified in Decision ECB/2010/14. For euro coins, these are further specified in Regulation (EC) 1210/2010.

The general principle is that all parties involved in processing and distributing euro banknotes and coins to the public are to comply with the rules and regulations of their own accord. If we establish non-compliant behaviour, we may decide to deploy enforcement instruments.

We have the power to impose an order subject to penalty or an administrative fine for individual acts of non-compliance in order to enforce compliance with:

  • Section 9a(1) to (3) of the Bank Act
  • Article 6(1) of Regulation (EC) 1338/2001
  • Articles 3(1) and (2) and 4(1) of Regulation (EC) 1210/2010
  • Section 5:20 of the General Administrative Law Act (Algemene wet bestuursrecht - Awb).

The Decision on administrative fines related to authenticity and fitness checking of euro banknotes and coins distinguishes between acts of non-compliance involving euro banknotes and coins, in particular in terms of the level of the fines and penalties. The legislator estimates the potential damage to society to be greater for euro banknotes than for euro coins.

Acting on our own mandate in enforcing rules and regulations, and with due regard to other relevant circumstances and interests, we reach our own independent decisions on the use of enforcement instruments.


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