Treasury designates 14 large banks and building societies and 2 LINK entities for the access to cash regime

His Majesty's Treasury announced on 24 May 2024 the designation of the large banks and building societies that will be subject to the Financial Conduct Authority's new access to cash regime, together with two LINK entities¹. The 14 designated firms are AIB Group (UK) plc, Bank of Ireland (UK) plc, Bank of Scotland plc (including Halifax), Barclays Bank UK plc, Clydesdale Bank plc (Virgin Money), HSBC UK Bank plc, Lloyds Bank plc, National Westminster Bank plc (including Ulster Bank), Nationwide Building Society, Northern Bank Limited (Danske), Santander UK plc, The Co-operative Bank plc, The Royal Bank of Scotland plc and TSB Bank plc¹. The Treasury also designated Link Scheme Limited and Link Scheme Holdings as an operator of cash access coordination arrangements, meaning LINK can coordinate cash access assessments on behalf of designated firms¹.

The regime was set out in the FCA's Policy Statement PS24/8, published in July 2024, following consultation in December 2023 (CP23/29)¹. The Financial Services and Markets Act 2023 gave the regulator a new remit and powers for the purpose of "seeking to ensure reasonable provision" of cash access services, meaning cash deposit and withdrawal services for personal and business current accounts, including access to notes and coins and access free of charge for consumers with personal current accounts¹. The FCA's rules come into force on 18 September 2024, an eight-week implementation period after the Policy Statement was published¹.

Under the rules, designated firms must carry out cash access assessments in response to closures of, or material reductions or changes to, cash access services at an existing facility¹. A "relevant closure" is defined as a full closure, or material reduction or change in services, reasonably anticipated to last, or having lasted, at least six months¹. Cashback, pay-to-use services for personal current accounts, and cash delivery or collection services are excluded¹. The FCA has amended the ATM exemption so it applies only where the remaining ATM or ATMs are, between them, accessible 24 hours a day, and has kept a three-month backstop for delivery of services, with longer permitted in exceptional circumstances¹. Firms may stop providing a service required by an assessment a minimum of two years after it has been delivered, subject to a new assessment¹. Firms should communicate closures to customers at least 12 weeks before they take effect¹.

Designated banks and building societies have been placed in a new fee-block, A.24, with the fee rate for 2024/25 set at £1.01 per £1m or part-£m of Modified Eligible Liabilities¹. The FCA's powers do not extend to wider banking services such as card and PIN management or fraud and scam support¹. The regulator's data suggests 1,358 bank and building society branches closed in the two years to June 2023, and as of June 2023, 95.0% of the UK population were within one mile of a free-to-use cash withdrawal point, with 99.7% within three miles¹.

Why it matters for households

The designation determines which firms carry the legal duty to assess and fill gaps in local cash provision, and from 18 September 2024 those firms must act on closures or material changes to cash facilities¹. Where an assessment finds a significant gap, designated firms must provide additional cash access services without unreasonable delay, and must not close cash facilities, including branches, until any required services are in place¹. The regime covers deposit and withdrawal services for personal and business current accounts, including free access for personal current account holders¹. The FCA notes that over 6% of adults, 3.1 million people, used cash to pay for everything or most things in the 12 months to May 2022, rising to 9% among vulnerable groups¹. The rules also set standards for how firms communicate and engage with communities, and consumers and businesses can make a cash access request and ask for an assessment review¹. The FCA has said its powers do not cover wider banking services such as card and PIN management or fraud and scam support¹.

What happens next

The FCA's rules come into force on 18 September 2024¹. In March 2024 the Payment Systems Regulator published a Call for Views as part of the second annual review of SD12, and in April the Bank of England published its consultation response and final Codes of Practice for the wholesale cash distribution market¹.