Banks Given Green Light to Keep Working Together to Protect Australians’ Access to Cash

Source: Original media release by the Australian Competition and Consumer Commission (ACCC), dated 24 October 2025.

Disclaimer: Bane Legal Services is not a law firm and does not provide legal advice. We connect clients with trusted commercial lawyers through over 30 years of business experience.

The ACCC supports continued collaboration among Australian banks to maintain nationwide access to cash, especially in regional communities.

ACCC backs collaboration to secure cash access

The Australian Competition and Consumer Commission (ACCC) has released a draft determination proposing to allow the Australian Banking Association (ABA) and other industry participants to continue working together to maintain cash distribution across Australia.

This move comes as part of ongoing efforts to ensure that both consumers and businesses — particularly those in regional and remote areas — can continue to access cash securely and reliably.

Why this matters

Access to physical currency remains critical for many Australians, especially those in communities where digital payments aren’t always practical or accessible. According to ACCC Deputy Chair Mick Keogh, collaboration between banks and cash distribution providers helps protect these consumers from being left behind as the economy becomes increasingly cashless.

Cash-in-transit services — responsible for transporting, processing, and storing physical currency — form the backbone of the national cash system. These services supply banks, major retailers, and hospitality venues, while also refilling ATMs and managing cash logistics across the country.

The conditions attached

The ACCC’s proposed authorisation includes three key conditions, including one that requires the ABA to develop specific initiatives to support cash access in remote regions.

The draft determination also allows the parties to prepare contingency plans in case Armaguard, the nation’s main cash distributor, faces operational disruptions. However, any further measures — such as implementing new pricing mechanisms — will require a separate application for authorisation.

Previous authorisations

The ACCC’s latest proposal follows a series of authorisations since 2023 relating to cash-in-transit services, including:

• June 2023: Approval of the Armaguard–Prosegur merger, creating Australia’s dominant cash distribution provider.

• May 2024: Authorisation for the ABA and other banking groups to collaborate on national cash distribution support.

• September 2024: Permission for collaboration between banks, Australia Post, retailers, and supermarkets to ensure continuity of cash services.

• June 2025: Approval for banks and major retailers to contribute financially to Armaguard’s sustainability measures and discuss future pricing frameworks (subject to future applications).

Public submissions open

The ACCC is now seeking public submissions on the draft determination before making its final decision. Interested parties can make submissions by 14 November 2025 via the ACCC website.

Importantly, this proposal does not include authorisation for any pricing arrangements between Armaguard and its customers — these will be addressed through a separate process.

Understanding the legal framework

When competitors collaborate, they generally need an ACCC authorisation to avoid breaching Australian competition laws. Under section 91 of the Competition and Consumer Act 2010 (Cth), the ACCC may grant such authorisations if the public benefit outweighs potential detriment.

In this case, ensuring ongoing public access to cash — particularly for vulnerable consumers — is considered a strong public benefit.

How Bane Legal Services can help

While this ACCC process deals with regulatory authorisations, many Australian businesses face similar challenges when navigating competition and compliance frameworks. Whether you operate in banking, retail, logistics, or franchising, understanding where collaboration is permitted — and where it crosses legal boundaries — can be complex.

That’s where Bane Legal Services comes in.

We’re not a law firm, but we use our 30+ years of business experience to connect you with the right commercial or competition lawyer for your needs — helping you protect your business and comply with Australian competition laws.