Access to cash bill could hurt competition, hearing is told

Oireachtas Finance Committee hears cash is ‘a crucial budgeting tool for many of those on fixed and lower incomes’

The competition watchdog should examine proposed legislation aimed at safeguarding cash into the future, the Oireachtas Finance Committee has been told.

The call, from the Banking and Payments Federation of Ireland (BPFI), came at a hearing examining the Access to Cash Bill at which officials from the Department of Finance also appeared.

In his opening remarks, the chief executive of the BPFI Brian Hayes said that some of the proposals in the proposed legislation were “neither fair nor equitable and more critically pose a very real risk to the present and future competitiveness of the Irish retail banking sector”.

He noted that, under the proposed provisions, it will be the State’s three retail banks that will have “sole and legal responsibility for maintaining the prescribed levels of access to both ATM and cash access points or counter services. This is despite the fact they only control around one third of the general infrastructure”.


Mr Hayes said that other providers who make up the remaining cash access infrastructure, including An Post, independent ATM providers and Credit Unions were excluded from responsibility for the provision of physical cash.

“In a scenario where any one of these providers withdraws an ATM or ‘bricks and mortar’ counter service, leading to a breach of the cash access criteria, under the current proposals it will be the responsibility of the retail banks to remedy and replace this service, even in circumstances where this is not commercially viable.”

Mr Hayes stressed that it was the BPFI’s view that “cash is here to stay”, but he pointed out that the number of retail banks in the Republic has declined from 12 to just three in recent years.

He called on the Competition and Consumer Protection Commission (CCPC) to give its view on the bill on the basis that “three banks are being asked to provide this infrastructure to the exclusion of everyone else”.

The hearing heard that, both domestically and internationally, the trend towards electronic payment options is “clear and strong”.

Oliver Gilvarry of the Banking Division in the Department of Finance noted that, before the pandemic, just under €20 billion was withdrawn from ATMs in the State annually. By 2022, that figure had fallen to around €13.5 billion in 2022, a decline of just under a third.

However, he told the hearing that cash was still “a crucial budgeting tool for many of those on fixed and lower incomes, and it also allows individuals, including those who are older, to control their finances and maintain their financial independence. It is also important to small-to-medium enterprises (SMEs)”.

He pointed out that, while the Bill introduces new obligation on the retail banks, “the legislation has been drafted to avoid imposing an excessive burden on the designated entities. Accordingly, it contains provisions for the criteria to be reviewed following updated census figures, or if cash demand drops significantly in a calendar year compared to the previous calendar year”.

The Bill, if passed, will also require banks to be responsible for ensuring 99 per cent of the population are no further than 10km away from a cash service point where money can be deposited or withdrawn with in-person assistance.

While the BPFI said that should be revised to 15km, Sinn Féin’s finance spokesman Pearse Doherty suggested a revision might go in the opposite direction.

He said that, if enacted as currently envisioned, some people in rural areas would be faced with a 20km round trip to access cash.

He called for consideration to be given to modify the Bill to mandate that the vast majority of the population would live within 5km of a physical cash infrastructure instead.

Conor Pope

Conor Pope

Conor Pope is Consumer Affairs Correspondent, Pricewatch Editor and cohost of the In the News podcast