Late last month the Council of Financial Regulators (CFR) and the Australian Competition and Consumer Commission (ACCC) issued a consultation paper, Regulating Cash Distribution in Australia, aiming to explore a regulatory framework for physical cash logistics and distribution.
As digital payments have surged, cash usage declined sharply—from roughly 70% of in‑person transactions in 2007 to just around 13% in 2022. Despite this decline, many Australians – particularly older people, low‑income households, and residents in regional and remote areas – continue to rely on cash for economic participation and resilience during emergencies.
The cash distribution industry is under strain from falling demand and high operating costs, especially in rural and regional areas.
Following the 2023 merger of Linfox Armaguard and Prosegur, a single provider now handles over 90% of national cash logistics. That merger was authorised by the ACCC under conditions including price constraints and coverage obligations, which expire in September 2026
The consultation outlines several preliminary regulatory options:
- Mandatory registration of cash distribution entities with reporting requirements to monitor capacity and risks.
- Designation as “critical infrastructure”, giving regulators authority to enforce continuity measures when providers are under threat.
- Crisis resolution powers, such as the ability to appoint statutory managers or redirect shares when service continuity is at risk.
- Price-setting authority: to manage fee disputes and prevent service disruptions if commercial agreements fail.
- Rural and regional service obligations, ensuring minimum service standards in high‑cost areas.
- Penalties and enforcement regimes to deter non‑compliance or service failures
The CFR and ACCC are inviting submissions from retail banks, cash‑in‑transit providers, consumer groups, regional stakeholders, and others such as ACAPMA.
ACAPMA
