What counts as «means of payment» — and what is a «movement»?

For the purposes of Ley 10/2010 (art. 34), means of payment fall into four categories: (1) banknotes and coins, national or foreign; (2) negotiable instruments and bearer means of payment — cheques, promissory notes or payment orders payable to bearer, endorsed without restriction or signed with the payee left blank —; (3) non-nominative prepaid cards; and (4) commodities used as highly liquid stores of value, such as gold.

The last two categories are the novelty brought by European harmonisation (Regulation (EU) 2018/1672): whoever thought of dodging cash controls by crossing the border with loaded prepaid cards or bullion no longer has a loophole. Traveller's cheques also count as bearer instruments.

And what is a "movement"? Any change of place or position occurring outside the holder's home. Carrying €12,000 from home to your bank branch is not a declarable domestic movement (the domestic threshold is €100,000), but crossing the border with it does require the S-1 (threshold: €10,000).

When each threshold applies and how to declare is covered in our guide to the S-1 declaration.

Legal basis and official sources:

• Art. 34 of Ley 10/2010 (definition of means of payment and of movement)
• Regulation (EU) 2018/1672

Reviewed: August 2026 · PBK Asesores — external experts in AML/CTF before SEPBLAC since 2010, more than 900 exams performed.

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Related:

• The S-1 declaration
• Car dealers and cash
• Penalties under Ley 10/2010
• All frequently asked questions