ACCC and ACAPMA are strongly urging retailers who are experiencing issues complying with the cash mandate to apply for exemptions now, before the penalties for non compliance come into effect.

Members will be aware that ACAPMA has been staunchly advocating for a practical and common-sense based implementation of the Federal Cash Mandate Code that places requirements on supermarkets and fuel retailers to accept cash at all outlets unless they hold an exemption.

The Cash Mandate Code came into effect from 1 January 2026 with a 6 month education and transition period while the Exemption Framework, which is to be administered by the ACCC, was finalised.

ACAPMA has been in close contact with members sourcing general and specific information as part of our advocacy around a sensible exemption framework.  This information has been central to our advocacy with the regulator around the final shape of the Exemption Framework, which has now been finalised and is being utilised by retailers and the ACCC.

The Exemption Framework represents a common-sense approach that ACAPMA had been advocating for and is welcome.

The Mandate

The Cash Mandate Code requires some* supermarkets and fuel retailers to honour cash transactions up to $500 during certain times (07:00-21:00) unless they are exempted.

*The Mandate will not apply to supermarkets or fuel retailers with a turnover of less than $10M will be exempt (unless trading on behalf of a business with a turnover of more than $10M).

This means that if the fuel retailer is an independent flying their own independent brand, and their turnover is less than $10M the Cash Mandate will NOT apply to this business (they will not need to apply for an exemption).

However, if the fuel retailer is an independent flying the brand of a business that has over $10M in turnover, the Cash Mandate WILL apply to this business and they will need to apply for an exemption if they are not able to meet the Mandate

The Mandate will not apply to sites that supply only diesel fuel.

Exemptions

There are two mechanisms ACCC can utilise to exempt a retailer from the Cash Mandate Code.  The first is to grant an Exemption Application that is submitted by the individual retailer, the second is for the ACCC to issue an Exemption to a particular class of retailers in exceptional circumstances.

Individual Retailer Exemption Applications

Individual retailers can apply to the ACCC for an Exemption.  There is not a standard form or format for the Exemption, the retailer simply needs to provide the ACCC information/evidence so that the ACCC can be satisfied that;

  • there are exceptional circumstances outside the retailer’s control such as natural disasters that are preventing or will prevent the retailer from complying with the mandate, and the retailer has taken all reasonable steps to be able to comply with the obligation under the codes or

 

  • the costs associated with complying with the obligation under the codes pose a significant risk to the ongoing feasibility of the retailer’s business.

Individual retailer Exemptions can apply to the whole business, a single site, a number of specified sites, or even in time limited conditions (such as in those sites that accept cash through the day but are OPT at night).

For example;

Sites that do not accept cash

321 Fuels Pty Ltd has an aggregated annual turnover exceeding $10 million. It routinely makes supplies of unleaded petrol at all of its retail sites. Of these sites 40% are fully cashless and have never accepted cash payments. 321 Fuels Pty Ltd may consider applying for an exemption for the 40% of its retail sites that have never accepted cash payments. It will need to demonstrate that the costs of them complying with the obligation under the codes at the retail sites pose a significant risk to the business’s profitability.

Sites that sometimes accept cash

XYZ Fuels Ltd has an aggregated annual turnover exceeding $10 million, so the codes apply. It routinely makes supplies of unleaded petrol at all of its retail sites.  All XYZ Fuels Ltd’s retail sites are staffed at certain times during the day and accept cash payments during these times. Of these sites 30% are not staffed between the full 7 am to 9 pm each day. These sites do not accept cash payments when unstaffed. For example, some sites are not staffed on weekends. Other sites are only staffed between 9 am to 5 pm each day. XYZ Fuels Ltd may consider applying for an exemption for the 30% of its retail sites that do not accept cash payments between the full 7 am to 9 pm each day. The days and times during which XYZ Fuels Ltd’s retail sites do not accept cash varies between sites. XYZ Fuels Ltd could apply for an exemption that applies only at specified times of day or on particular days of the week. XYZ Fuels Ltd should provide enough information for the ACCC to be able to assess its application.

ACCC Initiated Exceptional Circumstances Exemptions

In the event of ‘exceptional circumstances’ such as flood or fire the ACCC can, on its own initiative, issue an Exemption to a class of retailers if they are satisfied that circumstances outside of the control of the retailers in that class ill prevent them from complying with the Mandate.

Next Steps

ACAPMA and the ACCC encourage fuel retailers who are seeking an Exemption to apply as soon as possible to ensure it can be processed prior to the end of the transition period in June 2026.

Exemption applications made on Cost of Compliance grounds claiming that compliance with the Mandate would pose significant risk to the ongoing feasibility of the business, businesses need to provide:

  • details of turnover,
  • details of current costs of cash acceptance (if applicable), and
  • quotes or detailed cost estimates for the establishment or future provision of cash acceptance.

Exemption Applications can be directed to cashacceptancecode@accc.gov.au

More Information

For more information on the Cash Mandate Code see; https://www.accc.gov.au/business/industry-codes/cash-acceptance-industry-codes

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