From the EU payment services directive 3 proposal:

● Provisions concerning cash withdrawals
Operators of retail stores are exempted from the requirement for a payment institution license when they offer cash withdrawal services without a purchase on their premises (on a voluntary basis), if the amount of cash distributed does not exceed EUR 50, in line with the need to avoid unfair competition with ATM deployers.

^ That proposal is from 2023. Anyone know if it has been implemented?

Searching eur-lex.europa.eu is a disaster. I could not find any docs on any successors to this proposal, or whether it was implemented.

Blocking shops from offering a decent amount of cashback is shitty. But it’s also shitty how one ATM cartel is killing off competing independent ATMs in each country. It would make more sense to allow shops to offer large cashback amounts (they usually only have small amounts anyway), but then limit the number of ATMs per bank in each region so more independent operators can compete.