This week new legislation requiring financial institutions to ensure an ATM is located within 10km of the vast majority of homes and businesses came into effect.
The law is designed to address a shortcoming in access to cash, particularly in rural towns and villages hit by numerous bank branch and post office closures in recent years.
It comes at a time when cash usage is in decline - a trend that's been hardening for years but accelerated during the Covid-19 pandemic, with the proliferation of digital payments.
Central Bank figures show that for every €1 withdrawn in cash (via ATM or cashback) in the country, roughly €7 is spent using debit and credit cards.
Despite this, cash remains a key element of the payment systems in Ireland and is an important budgeting tool for many - especially older people.
The value of bank notes in circulation at the end of 2024 was more than €51 billion (up 6% from €48.63bn at the end of 2023), while last year cash withdrawals in Ireland totalled €12.76bn, which was only a small drop on the €13.03bn figure in 2023.
The technology around digital payments is only improving, but when there's a problem it can be a big issue, particularly when people turn away from cash and rely on tech in greater numbers.
In fact, the Government is expected to issue guidance to households soon advising them to keep a small amount of cash (between €70 and €100) at home that can be used in the event of power outages, extreme weather events, or cyber-attacks that impact digital-payment methods.
The Government and Central Bank have both made clear there is a commitment to ensure cash remains widely available and accepted as a means of payment, and access-to-cash legislation will support this.
How will the measure work?
The new law will ensure that a certain percentage of the population must be within 10km of an ATM, with a minimum specified number of ATMs per 100,000 people.
There will also be a minimum number of ATMs that can be accessed on a 24-hour basis.
In addition, there will be a requirement to have a certain number of cash service points (e.g., a post office) within 10km of a significant proportion of the population.
In 2022, the Central Bank carried out research in relation to access to cash.
It found the minimum percentage of the population within 10km of an ATM across different regions of the country was:
Border 98.5%
West 96.5%
Mid-West 98.8%
South-East 99.3%
South-West 98.6%
Dublin 99%
Mid-East 99%
Midland 98.3%
These percentages will be used as the targets for the access-to-cash legislation, because the Department of Finance deemed access to cash "in a reasonable position at that time".
Who will be responsible for operating any new ATMs under the legislation?
Credit institutions that have at least 6% of the current accounts and 7.5% of total household deposits in Ireland for at least six consecutive months will have responsibility.
That means the pillar banks - AIB, Bank of Ireland, and PTSB will take on the role.
The Central Bank will be responsible for the monitoring and enforcement of the measure.
What if there are still areas where accessing cash proves difficult?
If so-called 'local deficiencies' arise (i.e., there are regions where particular difficulties arise in accessing cash, despite the criteria in the legislation being met), it can be notified to the Central Bank by anyone.
The Central Bank will then assess any submissions and determine whether there is a local deficiency that needs a remedy.
If there is an ATM blackspot, the regulator will notify the banks and they will have up to eight weeks to come up with a proposal to address the issue.
Could the proportion of ATMs allowed for in the law be changed?
If cash demand drops by more than 15% from one year to the next, there is an allowance for the number of ATMs to be reduced in line with such a drop.
The Minister for Finance and/or the Central Bank can also review the situation and make adjustments in response to the demand or need for cash in the State.
As part of its review process, the Central Bank will consult with consumer bodies, older people, people with disabilities, and businesses.
What happens next?
This coming week the Central Bank will begin a public consultation to look at requirements for ATM operators, including the hours of ATM availability, cash withdrawal limits, and banknote denominations available from ATMs.
The regulator will also seek opinions on areas where particular difficulties in accessing cash may arise, and it will likely publish its first report and have relevant data on the issue next February.
The access-to-cash law is unlikely to reverse the trend away from cash and towards digital payments - a clear direction of travel has been established in this regard.
However, it recognises that cash plays a vital role for financial inclusion and ensuring the financial-services needs of some consumers are still being served.
Indeed research suggests there is still a strong demand to be able to use cash.
A 2024 ECB study on 'Payment Attitudes of Consumers in the Euro area' found that 65% of people surveyed in Ireland felt it was important to have the option to pay with cash (compared to 64% in a 2022 survey).
Crucially, this initiative is about giving people choice, regardless of what the most efficient and popular options are.
For most people it won't make much of a difference, but for some who really value being able to access and use cash it's valuable reassurance.
