This is an English translation. The original Dutch article is authoritative.
The lawsuit against Worldline revolves around a fundamental and simultaneously very practical question: can a payment service provider terminate an entire sector while acknowledging that no individual objections exist against the entrepreneurs involved? On 20 November, several coffeeshops received a termination letter ending their debit card processing contracts. This termination was not based on concrete violations, not on individual integrity incidents, and not on a specific shortcoming on the part of an entrepreneur. According to Worldline, the basis lay in its own payment infrastructure. This means the problem is not found with the coffeeshops, but in the banking chain within which Worldline operates.
That distinction is crucial. The debate is not about whether risks must be managed. That goes without saying. It is about the way in which that happens. The framework of anti-money laundering legislation is based on individual assessment. It must be determined per customer whether concrete risks exist and whether those risks can be mitigated by appropriate measures. In this situation, no individual assessment was conducted and no specific risks per enterprise were identified. Furthermore, Worldline itself has indicated that it has no individual reservations regarding the business operations of these coffeeshops. Consequently, a customer-related basis for termination is lacking. What remains is a categorical decision.
This approach also runs counter to the policy set by the government and regulators. The Minister of Finance has explicitly stated in writing that coffeeshops may not be categorically excluded from payment facilities and that existing relationships may not be terminated solely due to the nature of the enterprise. In doing so, the importance of promoting non-cash payments to limit cash flows was specifically pointed out. The regulator DNB also emphasises that an increased inherent risk does not mean that a category of customers must be refused, but that it must be assessed per individual customer whether risks are manageable. The starting point is individual assessment, not exclusion.
Worldline relies on its dependence on acquiring banks within its payment infrastructure. According to the company, that is the reason for the cancellations. This means that the termination does not result from the behaviour of the entrepreneurs, but from an internal dependence in Worldline's chain. A change in that chain is resolved by terminating all coffeeshop relationships simultaneously. Thus, an internal chain problem is shifted to the customer, while the legal framework is precisely based on individual assessment and mitigation.
Debit card traffic constitutes a significant part of the turnover for many coffeeshops. The shift to non-cash payments in recent years has not only been a development in payment traffic but also the result of policy in which the limitation of cash is central. Coffeeshops operate within agreements with their bank regarding the ratio between cash and electronic turnover. That ratio is monitored. Banks apply deposit limits and attach conditions to cash flows. Entrepreneurs are expected to keep their cash intensity manageable and transparent.
When debit card facilities fall away, turnover shifts to cash. This changes the ratio between cash and non-cash, while banking expectations remain unchanged. This can lead to additional questions, intensified supervision, or a reassessment of the banking relationship. A decision within the payment infrastructure thus directly impacts the broader financial position of the entrepreneur. At the same time, operational burdens increase and the safety risk rises because larger amounts of cash are present on-site.
Furthermore, Worldline actively recruited this sector as a customer two years ago. The nature of the business operations has not changed since then. The risk profile was known when entering into the relationship. Entrepreneurs could therefore assume that, as long as no individual violations or shortcomings were identified, access to non-cash payment traffic would be maintained. The change is not with the coffeeshops, but in Worldline's own chain.
The core of this case is therefore not a contractual formality, but a fundamental question about the limits of freedom of contract within an essential infrastructure. When a payment service provider acknowledges that there is no individual problem, but nevertheless chooses collective termination, the distinction between risk management and sector policy becomes visible. Instead of individual assessment, the exclusion of a category of customers is chosen.
Worldline acknowledges no individual objection. Yet, the relationships are terminated collectively. The cause thus lies not with the entrepreneurs, but in Worldline's banking chain. The outcome of this procedure will clarify whether internal chain issues may be passed on to entrepreneurs who are dependent on access to non-cash payment traffic for their daily business operations.