FCA consults on proposed access to cash rules

The Financial Conduct Authority (FCA) published a consultation on 7 December 2023 setting out proposed rules for a new access to cash regime, using powers given to it by the Financial Services and Markets Act 2023¹. The consultation closed on 8 February 2024¹. The FCA said the proposals would require banks and building societies designated by the Government to assess and fill gaps, or potential gaps, in cash access provision that significantly impact consumers and businesses¹.

The Financial Services and Markets Act received Royal Assent on 29 June 2023³. It requires the FCA to seek to ensure the reasonable provision of cash withdrawal and deposit services for personal and business current accounts across the UK, including access to both notes and coins and access free of charge for consumers with personal current accounts³. The Treasury published a Cash Access Policy Statement on 18 August 2023, and the FCA published its own statement the same day³.

The consultation set out the FCA's proposed approach. It said the new rules would go further than the existing voluntary scheme run by industry by requiring all designated firms to develop a more comprehensive cash assessment process, publish assessment outcomes, respond to a wider range of trigger events and meet set timeframes for delivery of additional cash access services². The FCA said it was concerned that current and significant delays in installing services risked harming cash-reliant small and medium-sized enterprises and individuals: 101 banking hubs and 88 deposit solutions had been recommended, but only 23 hubs had been delivered, with another 7 expected before the end of the year².

The FCA's data suggested that in the two years to Q1 2023, 1,391 bank and building society branches closed, as did 2,176 free-to-use ATMs². As of Q1 2023, 95.1% of the UK population were within one mile of a free-to-use cash withdrawal point, such as cash machines and Post Office branches, with 99.7% within three miles of one². The FCA's Financial Lives Survey found 3.1 million adults (6%) used cash to pay for everything or most things in the 12 months up to May 2022, rising to 9% for those with one or more characteristics of vulnerability².

The House of Lords Library reported that the number of bank branches in operation in the UK fell from 14,689 in 1986 to 5,745 in 2023, while building society branches fell from 6,954 to 1,925 over the same period⁴. A separate Lords Library briefing published in February 2025 gave different figures, stating that in 1986 there were 21,643 bank and building society branches in the UK, compared to 6,870 in 2024⁵. The two briefings use different sources and definitions.

Why it matters for households

The proposed rules would apply to banks and building societies designated by the Treasury, and would require them to assess local cash access needs and deliver additional services where significant gaps are found¹. The FCA said the rules would allow local residents, community organisations and representative groups to request an assessment of whether there are gaps in local cash access³. The FCA's powers focus on access to cash rather than wider banking services, and do not prevent bank branches from closing³. The FCA said its rules would have an impact where branch closures leave significant gaps in communities' cash services³.

The consultation followed a long period of branch and ATM closures. The FCA published guidance in September 2020 setting out its expectation that firms should consider the impact of branch and ATM closures on customers' everyday banking needs and consider the availability and provision of alternatives³. It updated that guidance in October 2022³. In January 2021, the FCA asked banks to pause closures where, due to the pandemic, they were unable to meet the expectations laid out in its guidance³.

What happens next

The consultation closed on 8 February 2024¹. The FCA published its final rules on 24 July 2024, and they came into force on 18 September 2024³. In May 2024, the Treasury announced the designation of the banks and building societies that will be subject to the new rules, as well as the designation of an operator of cash access coordination arrangements³. The FCA said designated firms must identify gaps in cash provision, assess a wide range of local needs and provide additional cash access services promptly if assessments find a significant gap¹. Where firms had already announced closures of cash access services taking place before the rules came into force, these would not be subject to the new regulatory regime¹.