The Batopin project consists in restructuring the cash distribution network of the four largest commercial banks in the country, namely Belfius, BNP Paribas Fortis, ING and KBC. They aim at developing an optimal network of ATMs in Belgium, by removing these machines from the branches and by making them neutral.
On 23 December 2022, the Investigation and Prosecution Service of the Belgian Competition Authority (BCA) confirmed that it had opened an investigation to determine whether this agreement could affect the quality of banknote distribution and deposit services or the competition between retail banking service providers under Article IV.1 of the Economic Law Code and/or Article 101 of the Treaty on the Functioning of the European Union. For Damien Gerard, BCA’s auditor general, this enquiry is one of the priorities for this new year.
Batopin aims at setting up an ATM every 5 kilometers at the most, which means that some population centers will no longer have an easy access to ATM.
On the other hand, the cooperation is justified by the decline in the use of cash that makes it costly to supply sufficient machines. Batopin aims at maintaining a sufficiently large network of ATMs.
The investigation is still at an early stage and its duration depends on the case’s complexity, the exercise of the rights of defence and the cooperation of the undertakings concerned. The parties concerned may also offer commitment during the investigation in order to eliminate any concern under competition law.
Annabelle Lepièce
Partner, Brussels
Nawal Bouzinab-Chuitar
Paralegal, Brussels
