The Hellenic E-Commerce Association (GR.EC.A.) has expressed serious reservations about the proposed ban on cash payments for orders delivered by courier companies.
GR.EC.A. recognises the importance of promoting electronic payments, improving transaction transparency and tackling tax evasion. These aims contribute to healthy competition, market confidence and a secure, modern environment for electronic transactions.
However, support for these aims does not mean accepting every proposed measure unreservedly, particularly when the way it is implemented could create unequal treatment between businesses, limit consumer choice and place a disproportionate burden on the market.
The proposed ban on cash payments for orders delivered by courier would represent a significant change to an established practice in Greek e-commerce. The association believes the measure should not proceed without prior evidence and meaningful consultation with the market.
1. Unequal treatment of in-store and online commerce – distortion of competition
The main issue raised by the proposed measure is the different treatment of transactions depending on the sales and delivery channel.
While cash payments for transactions below 500 euros are generally still permitted in physical shops, a total ban on cash payments is proposed for online purchases paid for on delivery by courier, regardless of the transaction value.
This means a consumer could buy a product from a physical shop and pay in cash, but might not have the same option when ordering the same product from an online shop for delivery by courier.
This difference raises legitimate questions about the principle of proportionality and the conditions for fair competition between in-store and online commerce. It is also concerning that the restriction applies to a transaction channel that is already subject to a significant degree of electronic recording and traceability.
The scope of the provision also needs to be clarified, particularly in relation to:
Payment for orders at courier companies’ physical service and collection points.
Deliveries made using the seller’s own vehicles.
Deliveries of products and meals by food-service businesses or third-party delivery providers.
Other product delivery and collection models that may be subject to a different regime.
If similar transactions are treated differently depending on the delivery method, there is a risk of distorting competition and treating businesses operating in the same market unequally.
The aim is not to impose identical rules on every transaction, but to ensure that any difference in treatment is objectively justified, serves a specific public interest and does not place a disproportionate burden on e-commerce.
2. Insufficient evidence of the measure’s necessity and existing traceability
The proposed measure should be supported by clear evidence of the problem it seeks to address and of its effectiveness in tackling tax evasion.
Cash-on-delivery transactions handled by organised courier companies are not, by their nature, unrecorded. The process generates electronic data on the order, dispatch, delivery and collection of payment, while the amounts collected can be remitted to partner businesses through bank accounts.
Subject to the applicable legal requirements, this data can be used for audit and cross-checking purposes. The seller is also independently required to issue a valid tax document, regardless of how the payment is made.
Payment by card does not in itself ensure that a valid tax document is issued, just as payment in cash does not automatically imply tax evasion.
For this reason, GR.EC.A. believes priority should be given to strengthening interoperability, electronic record-keeping and the use of available transaction data, rather than imposing a blanket ban on a lawful means of payment. Such a restrictive measure should be based on an evidence-based assessment of its expected benefits and of less restrictive alternatives.
3. Freedom of choice, consumer protection and the risk of excluding vulnerable groups
Cash on delivery is not simply a payment method; it also serves as a way of building trust between consumers and online shops.
The option to pay on delivery is particularly important when a consumer is making a first purchase from an online shop they do not know or have not dealt with before.
Keeping this option available helps e-commerce grow and is particularly beneficial to small businesses and start-ups, which have yet to build the profile and trust enjoyed by larger, established retailers.
Requiring electronic payment on delivery could also make it harder for certain groups of consumers to participate in e-commerce, including:
Older people and those less familiar with digital payments.
Consumers who do not have a card or access to suitable electronic payment methods.
Visitors and tourists who may face restrictions on using the payment methods available to them.
People living in remote and island areas where connectivity or access to financial services may be limited.
For some consumers, the option to pay on delivery also provides added reassurance, as it does not require them to pay an unknown seller in advance.
Although cash on delivery does not guarantee the quality or compliance of a product, the option to pay on delivery reduces some of the risks associated with prepayment to unreliable sellers.
Requiring electronic payment on delivery does not necessarily mean requiring payment in advance. However, where a suitable electronic payment option is unavailable or does not work at the point of delivery, prepayment could in practice become the only option.
The move to electronic payments should improve transaction security without restricting freedom of choice or creating new barriers to inclusion for consumers.
4. Impact on the competitiveness of Greek e-shops and competition with international platforms
Cash on delivery has long been an important payment method in Greece’s e-commerce market and is still used by a significant proportion of consumers.
A sudden change to the existing payment model could affect the conversion of visits into orders, the acquisition of new customers and the overall commercial activity of online shops.
The impact could be greater for small and medium-sized businesses, start-ups and online shops outside major urban centres, which rely more heavily on building trust with new consumers.
The measure’s competitive impact in relation to large international e-commerce platforms should also be assessed.
International platforms often have greater brand recognition, significant economies of scale and established electronic payment infrastructure, enabling them to adapt more easily to new regulatory requirements.
Smaller Greek businesses, by contrast, may face greater difficulties adapting and could lose a significant competitive advantage in the domestic market.
The proposed measure therefore risks accelerating market concentration and indirectly strengthening the position of large international players relative to smaller Greek businesses.
A potential decline in order volumes could also affect the entire e-commerce value chain, including courier companies, partner businesses and employment in the sector.
The growth of electronic payments should not be accompanied by rules that undermine the competitiveness of Greek businesses and create additional barriers to the development of domestic e-commerce.
5. Implementation costs and the risk of higher delivery charges
Although further digitisation of payments may improve efficiency and reduce the cost of handling cash over the longer term, it cannot be assumed that these benefits will materialise immediately or offset the initial cost of adapting.
Courier companies may need to make additional investments to support the new process, such as acquiring and operating Mobile POS and SoftPOS systems, ensuring connectivity, covering electronic transaction fees, integrating information systems, providing technical support and training staff.
Making the measure compulsory would impose an additional financial burden on businesses unless the caps on fees charged by both banks and payment service providers are reduced.
There is therefore a risk that some of the additional costs will be passed on to online shops and, ultimately, consumers through higher cash-on-delivery charges or delivery fees.
Particular care is needed for small and medium-sized businesses, which have limited bargaining power with courier providers, and for deliveries to remote and island areas, where service costs are already higher.
The total cost of implementation and the potential impact on final charges should be assessed in advance to ensure that mandatory digitisation does not place a disproportionate financial burden on businesses and consumers.
6. Operational resilience and ensuring deliveries can be completed
A particularly important issue is the operational continuity and resilience of the delivery system.
The ability to complete a delivery should not depend solely on the continuous and uninterrupted operation of telecommunications networks, payment terminals, banking infrastructure and payment service providers.
In the day-to-day operation of courier services, issues may arise such as:
A temporary loss of internet connection or inadequate mobile network coverage.
A technical fault or the inability to operate a POS or SoftPOS device.
A temporary outage of banking systems or payment services.
An electronic transaction failing to receive authorisation for technical reasons.
In such cases, the inability to make an electronic payment could result in failed deliveries, additional journeys, higher operating costs and considerable inconvenience for consumers.
This issue is even more important in areas with limited connectivity and during periods of high delivery volumes, such as Black Friday and the festive season.
For this reason, a clear, uniform and workable alternative process (fallback mechanism) is needed for cases when electronic payment is not technically possible.
The process should specify how the transaction can be completed without imposing unjustified costs on the consumer or online shop. The possibility of allowing cash payment as an exception in verified cases of technical failure should also be considered, with appropriate recording and control safeguards.
Operational resilience is essential to maintaining the reliability of courier services and the overall e-commerce experience.
On this basis, GR.EC.A. believes the proposed provision should not proceed in its current form without a thorough review.
Specifically, it proposes:
Reviewing the proposed ban with a view to ensuring equal treatment of in-store and online commerce and avoiding distortions of competition.
Establishing the necessity and effectiveness of the measure in tackling tax evasion, taking into account existing records and traceability data for cash-on-delivery transactions.
Safeguarding freedom of choice and equal access for consumers, with particular consideration for vulnerable groups and people who do not have, or find it difficult to use, electronic payment methods.
Assessing the impact on the competitiveness of Greek businesses, particularly small and medium-sized businesses and start-up e-shops, as well as the potential impact on competition with large international e-commerce platforms.
Conducting a comprehensive study of the economic and operational impact, including the additional cost of technological adaptation, the risk of costs being passed on and the need to ensure operational continuity in the event of technical problems.
Clarifying the scope of the provision to address potential differences between alternative sales, delivery and collection models.
Considering less restrictive alternatives, such as strengthening electronic record-keeping, the integration of information systems and tax traceability.
Providing for an adequate transition period and clear procedures for dealing with technical problems, if a relevant measure is ultimately adopted.
Beginning meaningful dialogue with market representatives, including e-commerce businesses, courier companies, payment service providers and consumer representatives.
GR.EC.A. consistently supports the development of electronic payments, greater tax transparency and the digital transformation of the Greek economy. However, the shift to a more digital transactions environment should be smooth, evidence-based, proportionate and balanced, the statement concludes.