The ACCC has today given Linfox Armaguard Pty Ltd (Armaguard) an interim direction that requires it to continue to supply cash in transit services and provide access to its facilities to its customers across Australia, and that sets the terms on which Armaguard provides these services.
The interim direction does not override existing contracts between Armaguard and its customers, and allows Armaguard and its customers to negotiate new agreements on different terms. The direction applies to existing Armaguard customers and a small subset of new customers.
In August this year, the Australian Government passed laws that gave the ACCC new powers to regulate cash distribution services, reflecting the essential role that cash continues to play in the economy.
The ACCC has now used its transitional powers to give an interim direction in relation to Armaguard’s cash in transit services and facilities access that applies until 30 June 2027. Armaguard is Australia’s biggest provider of these services.
With the interim direction in place to support ongoing supply to customers on fair and reasonable terms, the ACCC will now consider longer-term regulatory settings to support a reliable and sustainable cash distribution system.
“Australia is in a critical period in which reliable access to cash is still important for many consumers and businesses, but the cash-in-transit industry is under pressure due to the significant decline in cash use,” ACCC Chair Gina Cass-Gottlieb said.
“Without this regulatory intervention, we consider there would be potential risks to the continued supply and availability of cash in Australia. We also note that this is a highly complex situation, involving customers of many different sizes in urban, regional and remote parts of the country.”
“Our interim direction strikes a balance in the short-term between considering Armaguard’s financial position and providing a level of price and non-price clarity and stability to Armaguard, retailers, banks and other businesses that still use cash,” Ms Cass-Gottlieb said.
“We have carefully set the terms of the interim direction with a view to the longer-term settings for the sector. Those settings will take into account the availability and viability of cash, economic efficiency, the public interest, Armaguard’s legitimate business interests, and employee compensation as a key cost of providing these services.”
Armaguard recently submitted a proposed undertaking to the ACCC in relation to its interim prices, service offering and national coverage, among other things.
“We conducted extensive consultation on Armaguard’s proposed undertaking, including directly with Armaguard and many of its customers,” Ms Cass-Gottlieb said.
“The ACCC considered a wide range of material, including the proposed undertaking, and the perspectives of the many stakeholders involved. We also conducted our own analysis on different approaches.”
“We believe our interim direction is, at this time, the most appropriate short-term response to a complex situation. Importantly, we have flexibility to adapt or modify our regulatory settings should we need to,” Ms Cass-Gottlieb said.
“We will continue to engage closely with all parties on the longer-term settings for cash distribution services.”
The obligations the interim direction places on Armaguard include that:
- it must continue to supply services and access to approved cash centres to businesses that are currently receiving those services or access.
- there are different maximum price paths for different sized customer groups.
- previous non-price terms that applied at 30 June 2026 continue.
- it must not unreasonably discriminate in favour of its own operations or one of its related body corporates in its dealings with independent ATM customers and third-party cash-in-transit providers.
The interim direction and explanatory statement can be accessed through the ACCC website: Cash Distribution Framework transitional arrangements.
More information about the ACCC’s role in relation to cash is available on the ACCC website: Cash Distribution Framework.
Background
The cash-in-transit industry is in structural decline due to the decreasing use of cash as a payment method across the Australian economy. However, cash use has stabilised in recent years and it continues to be crucial to certain customers and parts of the economy.
The RBA designated Linfox Armaguard under the Cash Distribution Framework Act on 3 September 2026, meaning Armaguard became subject to legal obligations administered or enforced by the ACCC under the Act.
Under the legislative framework, the ACCC can issue an interim direction to a designated entity requiring it to provide cash distribution services or facilities access to a customer on terms specified in the interim direction.
Designated entities can also submit a court enforceable undertaking to the ACCC on matters relating to the CDF Act at any time. Linfox Armaguard provided a proposed undertaking to the ACCC on 23 September 2026.
Linfox Armaguard and Prosegur, the two main providers of cash distribution services at a national level in Australia prior to 2022, sought ACCC clearance to merge in 2022.
In 2023, the ACCC approved the merger subject to a legally enforceable undertaking which contained a number of commitments by Linfox Armaguard relating to pricing, non-price terms, supply of services and other matters.
That previous undertaking expired on 4 September 2026.
The ACCC also previously authorised arrangements for a number of parties to discuss, share information, reach agreement on and/or implement (as relevant) a number of assistance measures for the purpose of supporting wholesale cash viability and access to cash by businesses and members of the public, including short term financial contributions to Armaguard.
That authorisation expired on 30 June 2026. There are no ongoing short term financial contributions being provided under those arrangements.
Extracted in full from: https://www.accc.gov.au/media-release/accc-issues-linfox-armaguard-with-interim-direction-to-support-ongoing-access-to-cash
