CP21/9 Draft Specific Direction on maintaining free-to-use ATMs

This consultation closed on 16 November 2021, and we have published our response. Specific Direction 8 was revoked by Specific Direction 12 on 3 March 2022, and Specific Direction 12 expired on 2 January 2025. 

We’re proposing to issue a new Specific Direction to continue to support the operator of LINK in ensuring that it can meet the objective of continuing to maintain a broad geographic coverage of the Free-to-Use (FTU) ATM Network in the UK and meet service user needs. We want LINK to continue to have in place and maintain appropriate and effective policies, measures and reporting obligations.

Why have we chosen to issue this new Direction?

Over five million people, according to the latest data[1], rely on cash - the second most frequently used payment method. We are therefore committed to ensuring that cash, and the infrastructure that supports it, remains available for those who need it.

ATMs are important because most people access their cash through them.[2] Our priority therefore is to support the ATM network and ensure that UK’s cash system remains sustainable, resilient and accessible to those who need it.

What do we want LINK to do?

LINK has done a good job in supporting the broad geographic spread of FTU ATMs in the UK. Our annual reviews of SD8 found LINK’s application of policies and measures to maintain the broad geographic spread of FTU ATMs to be generally effective.

Our second SD8 review highlighted a few areas where LINK could enhance the effectiveness of its policies. As such, we expect LINK to consider:

• ways in which the resilience of its ATM replacement procedures could be enhanced
• how it can improve the transparency of its Direct Commissioning process

The draft Specific Direction requires the operator of LINK to continue to have in place and maintain appropriate policies and measures so that the broad geographic spread of the FTU ATM Network can be maintained – this includes a defined radius which is currently set at 1km. The defined radius is used to define a protected ATM (an FTU ATM which has no other FTU ATM within the defined radius).

The draft Specific Direction also requires:

• LINK’s policies and measures to meet certain objectives – this includes requesting LINK to set out the criteria it will use to determine the circumstances in which alternative cash access will be considered as an adequate substitute for a Lost ATM[3].
• Fewer monitoring and reporting requirements.
• LINK to provide us with one months’ notice if it proposes to vary, revoke or replace any of its procedures, policies processes and measures, including the defined radius which is current set at 1km. LINK cannot bring any of its proposed changes into effect if we raise objections within the one-month notice period.

[1] https://www.fca.org.uk/publications/research/financial-lives-2020-survey-impact-coronavirus

[2] ATMs are responsible for over 90% of cash accessed. (UK Finance Payments Statistics 2021).

[3] A Lost ATM refers to a Protected ATM (subject to not having been removed by LINK’s Filter to decide whether to replace a Lost ATM) that has ceased to operate, switched to PTU or scheduled to close within the next 12 weeks.