We are publishing our first Annual Review of Specific Direction 12 (SD12), designed to make sure LINK continues to do all it can to fulfil its commitment to maintain a broad geographic spread of free-to-use (FTU) ATMs. SD12 was issued to LINK in March 2022, replacing SD8 (and SD8a), which had been in place since October 2018.
Having considered the results of our analysis and responses to the call for views, we conclude that SD12 is working well and should remain in place. We will undertake another review of SD12 in spring 2024. At that point we will assess SD12’s role in protecting free access to cash in the context of changes to the regulatory landscape through implementation of the Financial Services and Markets Act 2023.
Why we are publishing this document
Cash remains an important payment method for many people in the UK. We are committed to ensuring that the UK’s cash system remains sustainable and continues to provide access to those who need cash for as long as that is required.
Who should read this document
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.
What this document contains
This is our first review of how well LINK is meeting the requirements we set out in SD12, and whether the direction should continue. This takes into account analysis of data received from LINK and current trends in cash usage, the feedback received from stakeholders through our Call for Views earlier this year and the changes to the regulatory framework introduced by the Financial Services and Markets Act 2023.
As set out above, we conclude that SD12 is working well and should remain in place. Nevertheless, we have identified four areas for improvement, which we will work on with LINK:
- Understanding how LINK makes use of the flexibility in SD12 (the ‘defined radius’ approach) to ensure a broad geographic spread of FTU ATMs, including how economic activity is taken into account in considering replacement or installation of FTU ATMs.
- Increasing the visibility and the level of detail of LINK’s published data on Protected ATM coverage, including decision-making on ATM replacement and updates to the Protected ATM list.
- The transparency of LINK’s decision-making on setting interchange fees.
- Improvements to LINK’s ATM replacement procedures (e.g. reviews of Protected status, reinstatement of Low-Volume and Protected ATM Premiums at closing sites, Post Office criteria).
We have also published non-confidential responses to our call for views which we conducted in spring 2023.
We are engaging with LINK about the feedback received from stakeholders and the findings of this review. We will discuss what further work is necessary and agree any associated timescales in due course. We will continue to monitor how LINK is meeting its commitments and will engage with LINK directly where we have concerns.
SD12 is due for a second review in March 2024, at which point we will gather feedback from stakeholders and assess any broader market developments to decide if further changes to SD12 are required.
We will continue to work with the FCA as they assume the lead role in protecting access to cash in the long term, while we retain our role regulating LINK.
Stakeholder submissions to call for views (redacted)
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