Bundesbank Payment Behaviour in Germany 2025: What the Survey Findings Mean for PSP Compliance and Reporting

ByOfficer

Last updated: June 2026

A consumer survey is not a reporting obligation. Treat the two as the same thing and you mis-scope your year, because the Bundesbank payment behaviour study tells you where transaction volumes are moving, while a separate set of European Central Bank rules tells you which of those movements you have to count, code and submit. The reporting teams that get caught out are the ones who read the headline, cashless has overtaken cash in Germany, and assume nothing in their own filings changes.

On 17 June 2026 the Bundesbank published “Payment behaviour in Germany in 2025”, the latest edition of a study series it has run since 2008. For the first time, cashless means of payment accounted for more recorded purchases than cash. That shift sits on top of the ECB payments statistics framework the Bundesbank, as Germany’s national central bank, uses to collect transaction data from payment service providers. The survey describes behaviour. The framework decides what you report. This article keeps the two apart and shows where the survey numbers touch a PSP’s reporting workload.

Related reading: our PSD2 reporting requirements guide

What the Bundesbank payment behaviour study actually measures

The study is a representative survey of people in Germany aged 18 and over, not a return filed by institutions. The Bundesbank collects the data in two stages: respondents first answer an interview about which payment instruments they know and hold, then keep a payment diary for three days, logging every payment at the point of sale, online, and to other people. That diary method is why the study reports shares of transactions, not just attitudes.

The 2025 figures: cashless means of payment covered 55 percent of all recorded purchases, the first time cashless exceeded cash. Cash fell to 45 percent, down 6 percentage points from the 2023 edition. Debit cards were second at 26 percent, with the girocard by far the most common. Mobile payments reached 10 percent, up 4 percentage points, and e-payment methods doubled to 6 percent. By transaction value the order changes: debit cards 28 percent (down 4 percentage points), cash 23 percent, and credit transfers 23 percent.

The trap is reading a point-of-sale behavioural share as a regulatory metric. The 55 percent figure is a count of purchases logged in consumer diaries. It is not the share of your transaction value, not a fraud rate, and not a line you report anywhere. The previous edition was published on 1 December 2024 and described 2023 behaviour, so the comparisons run survey-to-survey, not calendar-year to calendar-year.

The reporting framework behind the numbers

PSPs in Germany do not report to a survey. They report into the ECB payments statistics regime, which the Bundesbank administers as the national central bank. The legal basis is Regulation (EU) No 1409/2013 of the European Central Bank on payments statistics (ECB/2013/43), as amended by Regulation (EU) 2020/2011 (ECB/2020/59), published in the Official Journal on 11 December 2020. The ECB compiles euro area payments statistics through harmonised collections run by each national central bank, structured as nine tables. PSPs report Tables 1 to 6 and Table 9; payment system operators report Tables 7 and 8.

The tables map onto the categories the survey moves. Table 2 captures cards by function and scheme; Table 3 captures card-accepting devices, splitting ATMs, point-of-sale and e-money terminals. Table 4a captures transactions by payment service and initiation channel, with a breakdown between strong customer authentication (SCA) and non-SCA, plus the reasons for any non-SCA. Table 5a captures fraudulent transactions on the same axes. Table 9 is a quarterly return by payment service and initiation channel, with card-based transactions further split by merchant category code.

This is where the survey and the framework connect, but the mapping is not one-for-one. When the study shows mobile payments rising to 10 percent and e-payment methods doubling to 6 percent, PSPs should map those flows to the instrument, remote or non-remote channel, and authentication treatment used in the ECB/Bundesbank reporting taxonomy. A remote app-based card payment falls under the mobile payment solution channel, which under the Regulation covers only remotely initiated card-based transactions. A wallet payment or contactless tap at a physical POS terminal is captured instead as initiated at a physical EFTPOS, the non-remote card channel, and within that as a contactless payment, including the NFC sub-breakdown. If SCA is not applied, the reported non-SCA reason must match the exemption actually used, including the relevant low-value or contactless low-value category.

Where teams misread the cashless shift

The first misreading is scope. A PSP that issues cards or acquires card transactions in Germany will see the debit-card and POS shift in its own data. A payment institution offering only money remittance or account information services will not see the same card categories, because those point-of-sale flows are not its business. For payments statistics, the reporting population and reportable positions are set by the ECB payments-statistics regulation and the Bundesbank implementation; the PSD2 services an institution actually provides determine which activities need to be mapped, not the survey headline. That scoping starts with the PSD2 reporting and register categories.

The second misreading is the SCA angle. Mobile and contactless growth is not a free pass on authentication. More mobile and contactless transactions means more transactions to classify by authentication treatment and, where SCA was not applied, by the exemption reason actually used. A team that lets wallet or contactless volume grow without tightening the mapping between its authentication logic and the reported non-SCA reason can produce a Table 4a return that does not reconcile cleanly against its own fraud data in Table 5a.

The third misreading is timing. The survey is a snapshot; the obligations have their own cadence, semi-annual for the main tables and quarterly under Table 9. The shift does not create a deadline. It changes the shape of the data inside deadlines you already have. A press release is not a trigger for a reporting change. It is evidence that your data distribution is moving.

The PSD3 and PSR context, without overclaiming

The behavioural data lands while the EU rewrites the payments rulebook. The Commission published two proposals on 28 June 2023: a Payment Services Directive (PSD3), COM(2023)366, and a Payment Services Regulation (PSR), COM(2023)367. The European Parliament and Council reached a provisional political agreement on 27 November 2025, and the Parliament’s ECON committee approved the agreed text on 5 May 2026. The texts are close to adoption but not yet published in the Official Journal at the time of writing, and the package is generally expected to apply after a transitional period following entry into force, with the verification-of-payee obligation phased in separately. How that lands for institutions is covered in our PSD3 and PSR explainer for payment and e-money institutions.

The PSR is not yet in force, and nothing in the Bundesbank study changes that. What the study does show is that the categories PSD3 and PSR strengthen, mobile and e-payments, fraud, and authentication, are exactly the ones already growing in the data. Building clean Table 4a and Table 5a returns now is the same work the new regime will lean on. The digital euro sits in the same frame: 80 percent of respondents consider cash payment options important, and Bundesbank Executive Board member Burkhard Balz stated that preserving cash as a cost-effective, efficient and inclusive means of payment is a key concern of the Bundesbank. That cash-preservation line is part of the policy context for the ECB’s continued digital euro work, though the survey sets no reporting obligation on either.

What a German reporting team should check this cycle

Start with the distribution, not the headline. Pull your most recent payments statistics submission and review whether mobile, e-payment and contactless activity is mapped to the correct Table 4a positions. Do not treat the survey’s mobile-payment share as a direct proxy for one Table 4a mobile-solution line: remote mobile app card payments, non-remote wallet payments at POS, contactless card payments and NFC payments sit in different positions. If your business tracked the national trend, check the relevant remote, non-remote, contactless/NFC and authentication-exemption breakdowns, not a single mobile-solution channel.

Check the non-SCA reasons next. Contactless low-value and trusted-beneficiary exemptions move with mobile growth, and the reason codes in your return must match the exemption your authentication engine actually applied. This is the most common reconciliation gap when a contactless book grows fast, because the front-end exemption logic and the back-end reporting mapping usually sit with different teams. The same discipline applies to credit transfers, where the verification of payee check now sits alongside the transaction data you submit.

Keep the acceptance data in proportion. Cash was accepted in 94 percent of recorded physical-location purchases, and cashless payment was possible in 86 percent, 5 percentage points more than in 2023. That is a consumer-diary acceptance measure, not a direct Table 3 terminal count. For acquirers, the operational checks are whether POS, EFTPOS, contactless and e-money terminal populations are complete and whether Table 9 card transactions carry the required merchant-category breakdown where the MCC is known. A flat terminal file should be tested against onboarding, closure and estate-management data before being treated as consistent with the market trend.

Frequently Asked Questions

Does the Bundesbank payment behaviour study create a new reporting obligation for PSPs?

No. The study is a representative consumer survey of people in Germany aged 18 and over, based on interviews and three-day payment diaries. It imposes no filing requirement. PSP reporting comes from the ECB payments statistics regime under Regulation (EU) No 1409/2013 (ECB/2013/43), as amended, a separate framework the Bundesbank administers as national central bank.

Which ECB payments statistics tables are affected by the rise in mobile and e-payments?

Mainly Table 4a (transactions by payment service and initiation channel, with an SCA versus non-SCA breakdown) and Table 9 (the quarterly return with merchant category code splits for card transactions). Table 2 (cards by function and scheme) and Table 3 (card-accepting devices) also move as card and terminal mixes change.

How does contactless growth affect strong customer authentication reporting?

Mobile and contactless transactions still have to be assessed against the SCA requirement and any exemption actually used. The statistics return asks for the authentication method and, where SCA was not applied, the reason, including low-value and contactless low-value exemptions. A larger contactless book may change the SCA and non-SCA mix, but the reported reason must match the authentication or exemption decision your engine actually applied.

Are PSD3 and the PSR in force, and does this survey change that timeline?

No to both. PSD3 (COM(2023)366) and the PSR (COM(2023)367) were proposed on 28 June 2023, reached a provisional political agreement on 27 November 2025, and the ECON committee approved the agreed text on 5 May 2026. They are close to adoption but not yet published in the Official Journal, and are generally expected to apply after a transitional period following entry into force, with the verification-of-payee obligation phased in separately.

Why do the year-on-year comparisons run survey-to-survey rather than year-to-year?

The study is published periodically, not annually. The 2025 edition was published on 17 June 2026; the previous edition was published on 1 December 2024 and described 2023 behaviour. So the 6 percentage point fall in cash is the change since the 2023 study, not a single-calendar-year move.

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Key Takeaways

  • The Bundesbank “Payment behaviour in Germany in 2025” study, published 17 June 2026, is a consumer survey, not a reporting obligation. Cashless reached 55 percent of recorded purchases for the first time.
  • PSP reporting runs through the ECB payments statistics regime under Regulation (EU) No 1409/2013 (ECB/2013/43), amended by Regulation (EU) 2020/2011 (ECB/2020/59), administered in Germany by the Bundesbank.
  • The shift moves the distribution inside Tables 2, 3, 4a, 5a and 9, not your deadlines. Use the survey as a data-quality sense-check: if your channel and acceptance distributions do not move with the national trend, that is a flag worth checking before the NCB does.
  • Contactless growth may change the SCA and non-SCA mix, depending on the authentication or exemption actually used. The reported non-SCA reason has to match the exemption your authentication engine actually applied, or Table 4a will not reconcile cleanly with fraud data in Table 5a.
  • Your reporting population is set by the services you provide under PSD2 register categories, not by national point-of-sale behaviour. A remittance-only PI does not see the card shift in its own data.
  • PSD3 (COM(2023)366) and the PSR (COM(2023)367) are close to adoption after the 27 November 2025 provisional agreement and 5 May 2026 ECON approval, but are not yet in force.

Sources and References

Reading the survey without rewriting your reporting plan

The Bundesbank study is a strong signal about where German payment volumes are going, and a weak signal about what changes on your reporting desk. The right response is not a project. It is a reconciliation. Open your last payments statistics submission, check that the channel mix and SCA distribution moved the way the national data says behaviour moved, and fix the mapping where they have not. The survey will be quoted everywhere as proof that cash has lost its lead in Germany. The more useful fact for a reporting team is that every one of those cashless purchases already had a place in a table you file. The work is making sure they all landed in the right one.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.

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