The new €10,000 EU cash limit — what it means for Irish businesses

Ireland has never had a general legal limit on paying for goods and services in cash. That changes on 10 July 2027, when Regulation (EU) 2024/1624 (the AMLR) begins to apply. The AMLR introduces an EU-wide cap of €10,000 on cash payments for commercial transactions — and because it is a directly applicable EU regulation, it takes effect in Ireland without any Irish transposing legislation.

If your business accepts large cash payments today, or you advise clients who do, this is one of the most visible changes in the whole EU AML package. Here is what the rule says, who it touches, and what to do before the date.

What the rule actually is

The AMLR sets a maximum of €10,000 for cash payments made in the course of commercial transactions. The cap applies whether the payment is made as a single operation or as several linked operations — so splitting one €14,000 sale into two cash payments of €7,000 does not take it outside the limit.

Two features matter for Irish readers:

• It is directly applicable. Regulations, unlike directives, do not need to be written into Irish law. The cap arrives on 10 July 2027 by operation of EU law itself. The institutional side of the package — supervision and enforcement arrangements — sits in Directive (EU) 2024/1640 (AMLD6), which Ireland transposes separately.
• It is a commercial-transaction rule. The cap is aimed at businesses trading in goods and services. It is not a ban on holding cash or on private, non-commercial dealings between individuals.

Because AMLA technical standards and Irish implementation detail are still being finalised through 2026 and 2027, treat the fine print — including any national choices around enforcement — as something to re-check against the AMLR text on EUR-Lex closer to the date.

Why the cap exists

Large cash payments are the classic way to move criminal proceeds into the legitimate economy: no bank in the chain, no electronic trail, no institution filing a report. Until now, some member states had strict national cash limits and others — including Ireland — had none. The AMLR replaces that patchwork with one harmonised ceiling, closing off the option of carrying cash to whichever member state had the loosest rules.

The cash cap is not the only cash rule

It is easy to conflate the €10,000 cap with the AMLR's customer due diligence thresholds. They are different rules doing different jobs:

So a trader who accepts a €5,000 cash payment is well under the cap — but still faces a CDD obligation, because €5,000 in cash is above the €3,000 occasional-cash trigger. The cap tells you what you cannot accept; the CDD thresholds tell you what you must check on the cash you can accept.

One important clarification for anyone familiar with regimes elsewhere: Ireland has no threshold transaction reporting regime, and the AMLR does not create one. There is no equivalent of the Australian-style report filed for every cash transaction over a set amount. Your reporting obligation in Ireland remains suspicion-based — Suspicious Transaction Reports to FIU Ireland and the Revenue Commissioners — not automatic threshold reporting.

Who feels it most

The cap applies to commercial transactions generally, but some sectors will feel it more than others:

• High-value and luxury goods dealers. Traders in high-value goods — including dealers in precious metals and stones, who remain squarely in scope of the AMLR — are the businesses most likely to see five-figure cash offers today. For unaffiliated dealers of this kind, the AML supervisor in Ireland is the Anti-Money Laundering Compliance Unit (AMLCU) at the Department of Justice.
• Motor, marine, machinery and similar trades. Anywhere a single item routinely costs more than €10,000, staff need to know the answer before a customer opens a bag of notes.
• Professional firms handling client transactions. Solicitors (supervised for AML purposes by the Law Society of Ireland), accountants (supervised by the designated accountancy bodies such as Chartered Accountants Ireland, ACCA and CPA Ireland) and PSRA-licensed estate agents rarely take large cash payments themselves — but they advise, and sometimes facilitate, clients who do. A property deposit or fee arrangement involving substantial cash needs to be assessed against both the cap and your CDD triggers.

A hypothetical worked example

Suppose, purely hypothetically, a machinery dealer in Galway agrees a €16,000 sale in early August 2027. The buyer offers €8,000 in cash now and €8,000 in cash on delivery. These are linked operations for a single commercial transaction totalling €16,000 in cash, so the arrangement falls foul of the cap even though each individual payment is under €10,000. The dealer could instead accept the price by bank transfer or card — or take part in cash within the limit — and would still need to apply the relevant due diligence to any cash element of €3,000 or more if it is an occasional transaction.

What to do now

1. Map your cash exposure. Pull the last two years of transactions and identify how often you received cash of €3,000 or more, and whether anything approached €10,000. This tells you whether the cap is a real operational issue or a footnote for your firm.
2. Set an internal cash policy ahead of the deadline. Many firms will simply set an internal acceptance limit below €10,000 — with a linked-payments check — rather than police the legal ceiling exactly.
3. Update your Business-Wide Risk Assessment. Large cash acceptance is a risk factor in its own right; your BWRA and your policies, controls and procedures should reflect the new cap and the €3,000 occasional-cash CDD trigger.
4. Train front-line staff. The person on the counter or taking the booking needs a script: what the limit is, how linked payments count, and when a cash payment triggers due diligence.
5. Refresh your CDD procedures. Your current thresholds date from the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 regime. From 10 July 2027 the occasional-transaction threshold drops to €10,000 and the occasional-cash trigger is €3,000 — make sure your onboarding forms and checklists say so.
6. Know your escalation route. A customer insisting on structuring a payment to dodge the cap may itself be grounds for suspicion. Make sure staff know how that reaches your MLRO, and that your STR process covers dual reporting to FIU Ireland via goAML and to Revenue via ROS.

Where CompliDesk fits

CompliDesk Ireland is being built AMLR-native, with cash-rule warnings at the €10,000 cap and the €3,000 occasional-cash CDD trigger wired directly into client and transaction workflows. If you want a head start, work through our AMLR explainer or check whether the new rulebook catches your firm at Am I in scope?.