The Bundesbank's payment studies document a structural shift: cashless transactions have overtaken cash payments in Germany. Recent analyses indicate that digital payment methods now account for the majority of transactions. At the same time, the Bundesbank has noted that "complete freedom of choice does not currently exist." A significant portion of the population lacks the ability to pay cashless. The discrepancy is precise: Germany celebrates the transition to digital payment while simultaneously documenting that part of its population is structurally excluded from this development.
The Gap Between Claim and Access
The term "freedom of choice" presupposes that both options are available. In Germany, freedom of choice in payments currently means: cash is legally protected, digital payment methods are available, but not accessible to all. Those without access to cashless payment methods are not a homogeneous group. They include elderly people without bank accounts, people with poor credit ratings who cannot obtain credit cards, people without fixed addresses who cannot open current accounts, and people who reject digital payment methods out of distrust or habit.
The structural cause lies in the missing implementation architecture. Germany has no legal obligation to accept at least one cashless payment method. There is no public documentation of which shops, authorities, or service providers accept only cash. There is no strategy ensuring that access to digital payment methods is understood as part of basic services. The Bundesbank documents the problem, but responsibility for the solution is distributed unclearly among the Finance Ministry, consumer protection, banking supervision, and the states.
Denmark: Freedom of Choice Through Legal Clarity
Denmark is often cited as an example where regulatory changes in the mid-2010s allowed shops to refuse cash if they accept at least one digital payment method. The regulation reportedly does not apply to pharmacies, medical practices, and public service providers, which must continue to accept cash. The result: cashless transactions have come to dominate Danish retail, with digital payment methods accounting for the vast majority of transactions. Reports suggest that the share of the population without access to digital payment methods has declined. The difference lies not in technology but in implementation architecture. Denmark defined freedom of choice not as the absence of regulation but as the result of clear rules: those who offer digital payments may refuse cash. Those who provide basic services must accept cash. Banks were required to offer every citizen a basic account, regardless of creditworthiness or residence.
Germany has no comparable regulation. The debate about cash is conducted as a cultural question, not as an implementation problem. The Bundesbank demands freedom of choice, but the instruments to establish this freedom of choice are missing. There is no legal obligation for banks to offer all citizens a basic account with digital payment methods. There is no documentation requirement for shops that accept only cash. There is no strategy ensuring that the transition to digital payment is designed inclusively.
The Cost of Ambiguity
The lack of freedom of choice generates measurable costs. People without access to digital payment methods are excluded from growing parts of the economy. Online commerce, mobility services, digital administrative services presuppose digital payment methods. At the same time, the number of shops refusing cash for cost reasons is growing, without this being documented or regulated.
The structural cause lies in the incentive structure. For banks, providing basic accounts is associated with low margins. For shops, accepting cash is associated with costs for counting, transport, and insurance. For the state, regulating payment methods is a complex field between consumer protection, financial supervision, and monetary policy. The consequence: each actor optimizes locally, but no one is responsible for the overall outcome. The Bundesbank documents the problem, but responsibility for the solution remains unclear.
Bauplan
The next step for a capable state consists of two elements: first, a legal obligation to accept at least one cashless payment method for all shops outside basic services. The Danish model shows that this regulation is implementable. The definition of basic services must be clear: pharmacies, medical practices, authorities, grocery stores below a certain size remain obligated to accept cash. All other shops may refuse cash if they offer at least one digital payment method. The regulation creates clarity for consumers and shops and reduces the costs of cash infrastructure for those who no longer need it.
Second, a public register documenting where freedom of choice is lacking. Every shop that accepts only cash or only digital payments must report this. The register is made publicly accessible. The documentation creates transparency and enables consumers to make informed decisions. At the same time, it becomes visible where access to digital payment methods is missing and where targeted support is necessary.
Implementation requires no new authority. Banking supervision can enforce the obligation to provide basic accounts. Trade supervision can monitor the reporting requirement for payment methods. The Bundesbank can maintain the register. The pitfalls are known: resistance from shops that prefer cash, concerns from consumer advocates who defend cash as a freedom right, technical challenges in implementing the register. But the opportunity outweighs them: freedom of choice without choice options is not freedom but structural failure. The state owes its citizens not the preservation of cash or the promotion of digital payments, but the guarantee that both options are actually available.
Band 1 "Freistaat" describes the mechanics of implementation: how political declarations of intent become measurable impact, and why Germany systematically fails at this step. Payment freedom is an example of a pattern that runs through all policy fields.