

City Atrium T +32 2 277 52 72       info@bma-abc.be 
Rue du Progrès 50                                                                                   http://www.belgiancompetition.be 
1210 Brussels   
 
 
 
 
PRESS RELEASE 
N° 15/2025 
25 March 2025 
 
 
 
      The  Belgian  Competition  Authority  has  accepted  commitments  from  BNP  Paribas  Fortis,  KBC,  ING 
and Belfius to extend their integrated ATM network (Batopin) and maintain the quality of service 
 
The Belgian Competition Authority (“BCA”) has decided to make binding the commitments offered by BNP 
Paribas Fortis, KBC, ING and Belfius as founding banks and shareholders of Batopin SA (hereinafter ‘Batopin’), 
and  to  terminate  thereby  its  ongoing  investigation  into  their  cooperation  agreement  in  the  field  of  cash 
distribution.   
 
On 1 April 2022, the BCA opened an investigation into the cooperation agreement between BNP Paribas Fortis, 
KBC, ING and Belfius, the four main banks operating in Belgium, aimed at replacing their respective networks of 
automated teller machines (“ATMs”) with  a  single,  neutral  and  independent  network  managed  by  Batopin 
(hereinafter the “Batopin network”)
1
. Although this cooperation will result in a reduction in the number of sites 
and ATMs of the four founding banks, it also aims to optimise their geographical distribution.  
 
The  investigation  sought  to  determine  whether,  and  to what  extent,  the  cooperation  agreement  in  question 
was  likely  to  affect  the  accessibility  of  ATMs  and  the  quality  of  cash  distribution  services  in  breach  of  the 
competition rules prohibiting anti-competitive agreements.   
 
As  part  of  its  investigation,  the  BCA  consulted  various  stakeholders  and  cooperated  with  other  public 
authorities. This collaboration, combined with the complementary expertise mobilized during the investigation, 
enabled the BCA to develop a methodology for assessing the impact of the deployment of the Batopin network. 
On this basis, the BCA reached the preliminary conclusion that the cooperation had negative effects on both 
ATM accessibility for users and the quality of cash distribution services.  
 
Regarding ATM  accessibility,  the  BCA  examined  whether,  following  the  implementation  of  the  cooperation 
agreement,  Belgian  consumers  had  to  travel  significantly  further  on  average  to  reach  the  nearest  ATM  site 
compared to a scenario without the cooperation, while also considering changes in cash demand. The analysis 
highlighted an increase in the average distance travelled due to the cooperation. Although the agreement of 31 
March 2023 between the sector and the federal government
2
 significantly mitigates this effect, it does not fully 
offset it.  
 
 
 
1
 Batopin stands for “Belgian ATM Optimisation Initiative”. 
2
 Accès aux distributeurs automatiques de billets - Accord entre le gouvernement fédéral et Febelfin, 
https://economie.fgov.be/fr/themes/services-financiers/services-de-paiement/acces-aux-distributeurs  
Toegang tot de geldautomaten - Akkoord tussen de federale regering en Febelfin, 
https://economie.fgov.be/nl/themas/financiele-diensten/betalingsdiensten/toegang-tot-de-geldautomaten 
 

City Atrium T +32 2 277 52 72       info@bma-abc.be 
Rue du Progrès 50                                                                                   http://www.belgiancompetition.be 
1210 Brussels   
Regarding the quality of cash distribution services, the BCA assessed whether Belgian consumers were likely to 
experience a deterioration in the quality of ATM services as a result of the cooperation, compared to a scenario 
without the cooperation. To this end, the BCA conducted several quantitative and qualitative analyses, which 
revealed  that  the  average  intensity  of  ATM  use  was  expected  to  increase  following  the  deployment  of  the 
Batopin  network  with  possible  effects  on  the  waiting  time  of  users  and  the availability  of  ATM  machines. 
Furthermore, the pooling of the networks of the four founding banks could also have a negative impact on their 
incentives to maintain the quality of service.   
 
After being informed of the BCA's preliminary conclusions, Batopin actively cooperated with the investigation 
and  proposed  commitments,  which  were  subject  to  a  market  test  involving  market  participants,  public 
authorities and consumer protection organizations.   
 
Batopin committed in particular to expanding its ATM network in Belgium by adding 70 new ATM sites by the 
end  of  2027  spread  across  Flanders,  Wallonia  and  Brussels,  in  addition  to  the  220  additional  sites  already 
pledged following the agreement reached between the sector and the government on 31 March 2023, which 
are now made binding (i.e. 290 additional sites compared to the 750 initially planned). Furthermore, Batopin 
guarantees that its presence will be maintained until 2030 in the municipalities covered by its current location 
plan, and that it will ensure coverage enabling 95% of Belgians to withdraw cash and 85% to deposit cash within 
5 km by road of their home. Batopin also commits to ensuring at least 95% network availability, indicating the 
nearest Batopin site in case of unavailability, and maintaining 24/7 ATM access (except in cash-shops and other 
exceptions). Arrangements are also in place to allow the BCA to monitor the implementation of and compliance 
with these commitments.  
 
The  BCA  eventually  concluded  that  the  commitments  offered  are  proportionate  and  sufficient  to  address  its 
preliminary  concerns,  and  has  therefore  made  them  binding.  On  this  basis,  the  BCA  has  decided  to  close  its 
ongoing investigation without determining whether or not Batopin has infringed competition law. Similarly, the 
BCA  does  not  take  a  position  on  the  compliance  with  competition  law  of  all  provisions  contained  in  the 
agreement of 31 March 2023 concluded between the sector and the government.   
 
The decision will be available soon on the BCA's website. 
 
For more information you may contact:  
Damien Gerard  
Prosecutor general  
Tel: +32 (2) 277 76 57  
E-mail: damien.gerard@bma-abc.be  
Website: www.abc-bma.be  
 
 
 
 
 
 
 
 
The Belgian Competition Authority (BCA) is an independent administrative authority that contributes to the definition  and 
implementation  of  competition  policy  in Belgium.  Concretely,  the  BCA  pursues  anti-competitive  practices,  such  as cartels 
and abuses of a dominant position, and reviews the main merger operations. The BCA cooperates with the other competition 
authorities of the member states of the European Union and the European Commission within the  European  Competition 
Network (ECN) 

Belgian Banks Commit to Expanding ATM Network Amid Competition Concerns

The Belgian Competition Authority (BCA) has made binding commitments from BNP Paribas Fortis, KBC, ING, and Belfius regarding their cooperation in the Batopin ATM network. This decision comes after an investigation into their agreement aimed at consolidating their ATM services into a single, independent network.

 Initiated on April 1, 2022, the investigation focused on whether the cooperation would negatively impact ATM accessibility and cash distribution service quality, potentially violating competition rules. The BCA's analysis indicated that the agreement could lead to increased distances for consumers to access ATMs and a decline in service quality.

 To address these concerns, Batopin proposed commitments that were tested with market participants and consumer protection organizations. These commitments include adding 70 new ATM sites by the end of 2027, ensuring 95% of Belgians can access cash within 5 km, and maintaining a 95% network availability rate.

 The BCA concluded that these commitments sufficiently addressed its concerns, allowing the investigation to close without determining any infringement of competition law. The decision reflects the BCA's role in ensuring fair competition while balancing the needs of consumers.



The Belgian Competition Authority has accepted commitments from BNP Paribas Fortis, KBC, ING and Belfius to extend their integrated ATM network (Batopin) and maintain the quality of service

Belgian Banks Commit to Expanding ATM Network Amid Competition Concerns

The Belgian Competition Authority has accepted commitments from major banks to enhance their ATM network, addressing concerns over accessibility and service quality.