On 18 August 2023, HM Treasury published a Cash Access Policy Statement setting out the government’s policy concerning access to cash deposit and withdrawal services for relevant personal and business current accounts across the United Kingdom (UK). The Policy Statement is also intended to inform the FCA’s approach, including in relation to what constitutes ‘reasonable provisions’ of cash access services in the UK.


By way of background, the Financial Services and Markets Act 2023 introduces a requirement for the FCA to exercise its new functions for the purpose of “seeking to ensure reasonable provision of cash access services in the United Kingdom, or a part of the United Kingdom”. This includes the ability for the FCA to set rules which designated firms, and, where applicable, designated operators of cash access coordination arrangements, must follow. The Act also places a requirement on HM Treasury to publish a statement of policy concerning cash deposit and withdrawal services, to which the FCA must ‘have regard’, including in determining what constitutes ‘reasonable provision’ of cash access services in the UK.


The HM Treasury Policy Statement provides that the government’s aim is to maintain reasonable access to deposit and withdrawal services for these accounts. On the basis that data suggests that on a nationwide basis the distribution of cash access is broadly comprehensive, the government does not consider that a substantial redistribution or large-scale introduction of additional access points is required. Based on the data the government’s understanding of the distribution of cash access services across the UK is that the vast majority of people in predominately:

  • Urban areas of the UK have access to cash deposit and cash withdrawal services within a maximum of 1 mile of where they live.
  • Rural areas of the UK have access to cash deposit and cash withdrawal services within a maximum of 3 miles of where they live.

The above reflects at least 95% of the UK population being within these distances of cash facilities as of Q2 2022.

The government’s policy is that coverage for business and personal users should be maintained in line with the distribution of cash access services across the UK as set out above, while recognising that deposit and withdrawal needs may differ by location, and between individuals and businesses, and that local circumstances and user needs may change over time with lack of access impacting locations differently. In addition, with respect to personal current accounts, the government’s view is that ‘reasonable provision of cash access services’ (as to be determined by the FCA) means free cash access services. This does not preclude the provision of pay-to-use services. However, the government does not consider it appropriate for pay-to-use services to contribute towards ‘reasonable provision’ in relation to such accounts.

When determining ‘reasonable provision’ the government is of the view that consideration should be taken of the degree to which services meet local needs in relation to both business and personal use. This may include the following factors as appropriate in the circumstances:

  • Types of cash services and nearest alternatives available.
  • Hours of availability.
  • Travel and geographic factors.
  • Demographic factors in a local area, such as age, and characteristics of vulnerability that may reflect a greater need for cash access.
  • Potential for reliance on assistance with accessing cash that is provided in-person.

It is the government’s policy that, in the event of a significant change or closure to a cash access service, any proposed alternative service that has been identified for the purpose of maintaining reasonable access, in line with any FCA rules and guidance, is put in place no later than when the significant closure or change takes place.

FCA statement

The FCA has issued a statement Financial Services & Markets Act 2023 gives FCA new powers to protect access to cash.

The statement notes that over the past few years, the FCA has been carefully monitoring access to cash. Its current assessment is that, despite branch closures, for most people, access to cash is generally good. The FCA also recognises that the shape of branch networks is changing rapidly, as the way payments are made adapts too. The volume of payments that do not involve cash in the UK has risen from around 45% a decade ago, to 85% as of 2021. This change is being driven by technological advances. While digital payments make life easier for many, cash is still vital for some consumers in the UK with 3.1 million adults (6%) using cash to pay for everything or most things in the 12 months up to May 2022.

In line with HM Treasury’s Cash Access Policy Statement, the FCA states that it will seek to maintain a network of cash access facilities that is in keeping with the current distribution of services so that people and businesses who remain reliant on cash are able to withdraw and deposit it. The FCA will consult on new rules in due course and ensure they work together with its existing branch closures guidance. 

The FCA also adds that:

  • It expects to propose rules that focus designated firms’ efforts in local areas where deficiencies in cash access would be likely to have a significant impact, considering several factors. The FCA expects those factors to include: the number and characteristics of people likely to be affected including the impact on those in vulnerable circumstances; the number of businesses which accept cash payments likely to be affected; the distance to the nearest suitable access and the costs people and businesses face to travel there.
  • It plans to consult on rules that will require each of the banks and building societies designated by the government as subject to the new access to cash regime to conduct assessments of the reasonableness of cash provision when certain significant changes in local access occur or are proposed. For example, this could include a decision to close a bank branch. The FCA expects these rules to also require an assessment where a community requests one. 
  • It expects the proposed rules to require a designated firm to fill gaps in provision where, broadly, assessments conclude the gap will have a significant impact and it is reasonable for the firm to provide an additional service. It also anticipates the proposed rules will provide for flexibility in the type of facility used to deliver the additional services and that firms may choose to install shared services such as banking hubs. The FCA expects firms to be able to comply with applicable requirements including under UK Competition Law whenever coordinating with each other.
  • Under the FCA’s Branch and ATM Closures and Conversions Guidance it already expects firms to conduct good quality analysis and, where it is reasonable for a firm to provide an alternative solution, it is expected this (or suitable interim arrangements) will be opened ahead of the closure or conversion. The FCA plans to adopt a similar approach to access to cash in rules – if an assessment shows additional cash services should be put in place because of a pending closure by a designated firm, the closure must wait until those services are in place.
  • As provided for in the HM Treasury Policy Statement, the new powers given to the FCA does not extend to cash acceptance. It does not have powers to ask retailers to accept cash as payment for goods or services. Retailers are free under the existing law to decide whether to accept cash or to only accept digital payments.

In terms of next steps:

  • The government will designate which firms the FCA’s regulation of cash access will apply to and may designate co-ordination bodies.
  • Before making any rules the FCA will undertake a full consultation.
  • Depending on the outcome of the FCA consultation, the FCA currently expects any new rules to take effect by summer 2024.

The FCA also reminds firms:

  • The new Consumer Duty came into force on 31 July 2023 setting a higher standard of protection for banking customers, including where they are impacted by branch closures and ATM conversions. PRIN 2A.1.16G to PRIN 2A.1.18G explain how the FCA’s existing guidance on branch and ATM closures or conversions remains relevant to consideration of firms’ obligations under the Duty.
  • Firms must anticipate the foreseeable harm to their customers of any decision to close a branch or close or convert an ATM and address it before proceeding with a closure or conversion. As outlined in non-Handbook Guidance for firms on the Consumer Duty (Finalised Guidance 22/5), firms should engage with the FCA if they are considering withdrawing or restricting access to products or services in a way that will have a significant impact on characteristics of vulnerability or on overall market supply.