Pricey unless the user is making use of close to the maximum allowed monthly turnover.
Or does that mean loading with BTC and making payments and ATM withdrawals don't carry any fees even if the currency is other than EUR?
I would say hardly anybody could define the relevant price for anonymity nowadays. It's a relative thing and people are ready to pay for it. If you divide the yearly service fee by the max. turnover per year you would see that your price for anonymity is less than 1% which I think is acceptable.
Certain types of transactions of course incur some fees, like card2card and bank transfers, for ATM there is a limit which can be withdrawn at no fee (varies depending on the bank). POS and online transactions, virtual card issuance (where applicable) are free. Currency conversion spread is usually 1-3% from FX.