Some highlights from the German federal election manifestos 2025
Payments are not just a topic for lawyers. It has long since reached the political arena. Let us think, for example, of the political debate on payment cards for refugees. The political significance is also reflected in the party manifestos for the upcoming federal election in Germany on 23 February. I have ‘only’ looked at the programmes of the 7 parties with a say in the Bundestag: AfD, BSW, CDU/CSU, Die Grünen, Die Linke, FDP and SPD. The italicised quotations can be found in the respective election programmes without page numbers (for reasons of readability).
Table of Contents
Payments card
Let’s stay with the topic of payments cards. CDU/CSU is brief: ‘no compromises’. FDP calls for widespread use ‘without unnecessary exceptions’. The combination of benefits in kind plus payment card is also advocated by AfD, in addition to FDP. Die Grünen consider the necessity of a payment card (‘completely without inappropriate cash ceiling’) only for reasons of bureaucracy reduction and inclusion. Die Linke do not want benefits in kind or payment cards, but only ‘regular’ cash benefits. The BSW and SPD programmes are silent on this topic.
At this point, we can already tick off SPD’s election manifesto. On the subject of payments, there is a yawning void. The only thing mentioned is the goal of combating tax fraud in ‘cash-intensive’ industries. It remains unclear what measures SPD has in mind here.
Cash vs. ‘no cash’
The topic of cash vs. ‘no cash’ is traditionally a perennial issue. According to AfD, the existence and use of cash should be enshrined in the Basic Law as a right of freedom. State agencies should be obliged to accept it. The demands of BSW are almost identical. Cash protects privacy and enables the right to a non-digital existence. CDU/CSU also describes cash as ‘lived freedom’, but emphasises its fundamental openness to ‘all new payment methods’. FDP goes one step further and, in addition to maintaining cash, advocates a ‘wide acceptance of card payments’.
Credit card payments
Die Grünen has some reservations about card payments, however, and specifically about credit cards. The reason: high payment transaction costs for German companies and consumers. They want to use the following weapons against high payment transaction costs: innovative competitors, competition law, measures against usury and capping the annual percentage rate of charge. I suspect that some things have been mixed up here. The possibly high costs for the consumer do not result from the use of the credit card for payment transactions, but from the use of the card to borrow money. The high payment transaction costs for German companies, which are the subject of complaint, in turn have nothing to do with the respective borrowing. With a share of approx. 2% of all card payments, the question also arises as to the social relevance of these credit cards with a credit function.
Digital Euro
Discussions about the Digital Euro (D€) have recently died down somewhat in public. This is reflected in the party programmes. It is no longer an issue for SPD, Die Grünen and BSW. CDU/CSU only support the D€ if it offers ‘real added value’. In addition, it should (only) supplement cash, not endanger financial stability, protect the privacy of consumers and be usable free of charge. The list of demands is largely identical to that of FDP. FDP’s additional demands are: online and offline use and no compulsory use. It remains to be seen whether no compulsory use also implies no compulsory acceptance. Compulsory acceptance (according to the Commission’s draft, currently largely intended for legal entities) means compulsory use for the payee if the payer wants to use the D€.
AfD justifies its rejection of the D€ with a dystopian scenario: compulsory use, dominant legal tender, programmable payments, abolition of cash and full surveillance. Die Linke, on the other hand, welcomes the D€. In this context, this party advocates the legal anchoring of anonymous digital payment for small amounts. (Author’s note: This demand has already been met, at least for e-money, including at EU level.)
How to deal with cryptocurrencies
Another hot topic is cryptocurrencies. However, there are two proponents here; the rest are silent. It is not surprising that FDP explicitly welcomes cryptocurrencies after FDP leader Lindner publicly promoted the use of Bitcoin as part of currency reserves. The party’s election manifesto also calls for the admission of crypto ETFs. Crypto innovations are to be better supported by expanding the financial centre promotion. The existing regulation regarding proportionality is also to be reviewed. If this is aimed at the MiCAR, it will certainly not be an easy undertaking, as this is a matter of European law.
AfD also criticises the MiCAR and demands a ‘deregulation of Bitcoin, Bitcoin wallets and trading venues’ and the ‘right to self-custody of the coins in self-managed wallets’. In my opinion, however, this right is not affected by MiCAR. AfD’s approach is remarkable in terms of monetary theory. On the one hand, it advocates the return of a national monopoly currency (instead of the euro); at the same time, it welcomes Bitcoin as ‘state-free money’ in the ‘competition between currencies’.
Criticism of the ECB
Die Linke still has some interesting, but not very realistic demands, which I would not want to withhold at the end. It criticises the ECB sharply: interest rate policy ‘on the backs of the working population’, a failure in the fight against inflation and influence by financial lobbyists. For these reasons, the ECB should be ‘democratised’, which ultimately amounts to the political dependence of the central bank. The leading personnel (Council, Directorate) should be elected by the European Parliament (EP). The EP should also determine the ECB’s monetary policy. It addresses a legitimate regulatory issue as to why a central bank, as a ‘key political actor’, is not subject to democratic co-determination. It will be interesting to see the results of this discussion, which has so far been largely ignored.
Role of banks
Die Linke would also like to change the role of banks. They should become smaller and give up investment banking, although it remains unclear who should take over this business. Banks should ‘only’ act as intermediaries between savings and investments and continue to be active in payment transactions. However, this party does not have much confidence in the banks when it comes to payment transactions, because at the same time ‘public alternatives to the payment systems of the large Internet companies’ should be provided.
Election manifestos are certainly interesting reading, but what is more important is what is subsequently formulated in the new coalition government’s programme.
