On 27 March 2024, the Payment Systems Regulator (PSR) announced that it is conducting its second annual review of Specific Direction 12 (SD12) and published a call for views.


SD12 is designed to ensure that Link Scheme Holdings Ltd (LINK), the operator of the LINK ATM network, maintains the broad geographic spread of the UK’s free-to-use (FTU) cash machine network and meets service-user needs by having in place and maintaining effective policies and measures. SD12 was issued by the PSR in March 2022, and the PSR committed to reviewing SD12 (and publishing its findings) after 12 and 24 months (the findings of the first review can be found here). The Direction will be in force until 2 January 2025, unless varied or revoked by the PSR.

Scope of the call for views

The PSR is inviting respondents to submit views on the following four areas, which focus on the operation of SD12:

  • How effective SD12 has been in delivering its purpose, i.e. requiring LINK to maintain a broad geographic spread of FTU ATMs and meet service-user needs. 
  • How well the requirements under SD12 have worked in practice in relation to maintaining and replacing protected ATMs, as defined in paragraph 3.7 of SD12. 
  • How successful LINK has been in addressing the areas for improvement identified in the first annual review of SD12. 
  • The role of SD12 in the regulatory landscape introduced by the Financial Services and Markets Act 2023. 

The call for viewswill be of particular relevance to ATM operators, consumer groups and merchants, as well as anyone with an interest in the provision of access to cash.

Next steps

The call for viewsis open until 5pm on 2 May 2024. Once it closes, the PSR will consider all responses and plans to publish a report summarising comments and setting out its findings later in 2024.