The banking industry recognises the vital importance of cash for many consumers and small businesses. Mindful of the decline in ATM cash withdrawals, which according to CBI figures have fallen by 32% since the pandemic as more people choose to manage their money digitally, BPFI and its member banks are committed to ensuring there is reasonable access to cash both now and in the future in accordance with consumer demand.
However, as the payments landscape continues to evolve rapidly and demand for cash likely decreases over time, the criteria used to measure demand levels must be updated regularly to stay in step with changing consumer preferences. It is therefore essential that the legislation is sufficiently flexible and forward-looking, allowing the requirements to be reviewed and updated efficiently.
As the legislation is developed, it is also imperative that there is a level playing field among market players. A level playing field is a vitally important component for the health of every business sector, and the financial services sector is no different. The provision and cost of reasonable access to cash should be a shared industry responsibility across all current and future providers of cash and current accounts.
Of equal importance is the issue of oversight and measurement of the legislative requirements of reasonable access to cash. We believe this should be the responsibility of the Central Bank of Ireland which is the designated Competent Authority in charge of supervising the financial services sector in Ireland and for regulating other aspects of the cash landscape. It is also important to note that an EU Regulation on Cash as Legal Tender is under discussion and that any measures introduced domestically should align with the Regulation.
