We are conducting our first annual review of our Specific Direction 12 (SD12), which is designed to ensure that LINK: 

  • maintains a broad geographic spread of the UK’s free-to-use (FTU) cash machine network 
  • meets service-user needs by having in place and maintaining appropriate and effective policies and measures 

We would like to hear your views on how well SD12 is working in practice. 

Why we are publishing this call for views  

We issued SD12 to LINK in March 2022 and it will be in force until 2 January 2025, unless we vary or revoke it. We said we would review SD12 after 12 months and (if still in place) after 24 months.  

As SD12 has been in place for a little over a year, we want to understand how it is working.  

The scope of this call for views  

We invite you to submit your views on four areas, focused on the operation of SD12: 

  1. How effective SD12 has been in ensuring appropriate policies and measures are in place to support the maintenance of a broad geographic spread of the FTU ATM LINK network in the UK and meet service-user needs. 
  2. How well the requirements under SD12 have worked in practice in relation to maintaining and replacing protected ATMs. 
  3. Whether the monitoring requirements under section 8 of SD12 have led to sufficient transparency, if any of it is superfluous, or if any further aspects require monitoring. 
  4. Whether SD12 should remain in place, given some of the wider initiatives that have been introduced. These include, among others, the Financial Services and Markets Bill

We welcome all responses at whatever level of detail you feel is most appropriate to your understanding. 

You can see LINK’s Protected ATM policy here

Who might this call for views be relevant for?  

This document will be of particular interest to ATM operators, consumer groups and merchants, as well as anyone with an interest in the provision of access to cash. 

How to respond 

This call for views is open until 5pm on Friday 21 April 2023. You can submit your responses by email to psrsd12responses@psr.org.uk or write to us at the following address:  

Cash and Digital Team  

Payment Systems Regulator  

12 Endeavour Square  

London E20 1JN  

Next steps  

Once the call for views closes, we will consider all the responses we receive to inform our assessment. We will publish a report summarising comments and setting out our findings later in 2023. 

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