Australia Moves to Safeguard Cash Distribution: What the New Framework Means for ATMs and Access to Cash

Australia has introduced a new regulatory framework for cash distribution, recognising that maintaining payment choice requires more than keeping cash in circulation – it also requires sustainable infrastructure to ensure cash can reach ATMs, businesses and consumers.

Australia has taken a significant step towards safeguarding the future resilience of its cash infrastructure with the introduction of the Cash Distribution Framework Act 2026.

The legislation received Royal Assent on 26 August and came into force on 27 August 2026. It establishes a regulatory framework for organisations that play a significant role in distributing cash across Australia, giving new responsibilities and powers to the Reserve Bank of Australia (RBA) and the Australian Competition and Consumer Commission (ACCC).

For the ATM industry, the development is particularly relevant. While much of the international debate about cash has focused on whether consumers can access and use it, the Australian legislation addresses a fundamental issue further down the chain: how do you maintain the infrastructure required to get cash to the places where people need it?

A changing cash environment

Australia, like many developed markets, has experienced a substantial long-term shift towards digital payments. However, declining transactional use does not mean that the need for cash has disappeared.

The RBA's 2025 Consumer Payments Survey found that around 15% of payments were made using cash, while approximately half of Australians used cash during a typical week. Around one-third said they would experience hardship or major inconvenience if cash became difficult to access or use.

Cash also continues to provide an important fallback when electronic payments are unavailable, particularly during outages, emergencies and natural disasters.

At the same time, maintaining the infrastructure supporting cash has become increasingly challenging. Lower transaction volumes have placed pressure on a system with substantial fixed costs, including cash depots, transportation, security and processing.

Those pressures became particularly visible following the 2023 merger of Australia's two largest cash-in-transit providers, Linfox Armaguard and Prosegur Australia. The resulting business was estimated to account for more than 90% of the market. Subsequent financial support from major banks and retailers highlighted concerns about the sustainability of the country's cash distribution arrangements.

The issue therefore became not simply whether Australians should continue to have access to cash, but how the infrastructure enabling that access could remain commercially sustainable and operationally resilient.

What does the new framework do?

The Cash Distribution Framework Act establishes a system for identifying and regulating organisations considered significant to Australia's cash distribution network.

Under the legislation, the Reserve Bank of Australia can designate a company where it considers that the organisation supports a significant part of the cash distribution system, or where disruption to its operations could threaten continuity of the wider system.

Once designated, providers can become subject to regulatory requirements covering their commercial arrangements, service standards and preparedness for disruption.

The ACCC is given oversight of agreements involving designated providers. Among other measures, the framework provides for approved standard terms, good-faith negotiations and an arbitration mechanism where parties cannot agree on proposed terms.

Importantly, the ACCC can also establish service-level standards covering areas such as the availability, frequency, timeliness and location of cash distribution services, as well as pricing and access to relevant facilities.

The RBA, meanwhile, is given significant crisis-readiness and resolution responsibilities. These are designed to provide authorities with greater ability to intervene before problems affecting a major provider result in widespread disruption to cash availability.

This represents an important shift: cash distribution is being treated not simply as a commercial service but as infrastructure whose continuity can have wider implications for the payments system.

The connection with ATMs

Although the legislation regulates the cash distribution system rather than ATM deployment itself, the relationship with ATM access is clear.

An ATM is only useful as an access point if there is a functioning network behind it capable of delivering, processing and replenishing cash.

Australia's Government specifically identified keeping ATMs stocked with cash as one of the intended outcomes of the new framework.

This is particularly important for regional and remote communities. The RBA has found that while most Australians continue to have relatively convenient access to withdrawal facilities, access has become less convenient as bank branches and bank-owned ATMs have declined. Independent ATMs and Australia Post's Bank@Post network have consequently become increasingly important parts of the country's cash-access infrastructure.

For ATM operators, banks and other cash stakeholders, the Australian approach therefore raises a broader question being faced in many markets: as cash volumes decline, how should the fixed costs of maintaining adequate cash access be shared and sustained?

Protecting both sides of cash access

The new legislation is also part of a wider Australian policy approach.

Since 1 January 2026, most grocery and fuel retailers have been required to accept cash for in-person purchases of A$500 or less between 7am and 9pm, with exemptions including qualifying small businesses.

Taken together, the measures address two different parts of the same challenge.

One seeks to ensure that consumers who want or need to use cash can continue to do so for essential purchases. The other seeks to ensure that the infrastructure exists to distribute that cash to businesses, banks and ATMs.

This distinction matters. A requirement to accept cash has limited practical value if consumers cannot conveniently obtain it, just as access to an ATM has less value if the underlying cash supply and replenishment network becomes unsustainable.

A wider lesson for the payments industry

Australia's approach could therefore provide an important case study for policymakers and the ATM industry internationally.

As payments become increasingly digital, the challenge is no longer simply about preserving cash or promoting digital payments. It is about creating a resilient payments ecosystem in which consumers retain meaningful choice and alternative payment channels remain available when they are needed.

There is also an economic reality that cannot be ignored. Cash volumes may decline while many of the fixed costs associated with maintaining cash access remain. If that imbalance becomes too great, commercial pressures can eventually affect service coverage, particularly in less densely populated or higher-cost locations.

Australia's response is to introduce regulatory guardrails around the infrastructure underpinning cash availability while recognising the changing economics of the market.

For ATMIA and its members across Asia-Pacific, this is an important development to watch. Different markets will inevitably require different solutions, and regulation alone cannot resolve every challenge associated with declining cash volumes. However, Australia's new framework demonstrates growing recognition that access, resilience and sustainability need to be considered together.

Ultimately, payment choice depends not only on having different payment methods available at the point of sale. It also depends on ensuring that the infrastructure supporting those choices remains viable.

As governments around the world consider the future balance between cash and digital payments, Australia's new Cash Distribution Framework may provide an increasingly relevant model for that discussion.