The ACCC has issued a determination granting authorisation with conditions to allow the Australian Banking Association Ltd (ABA), major banks, major retailers and supermarkets, Australia Post and other industry participants to collaborate on the future continuity of cash-in-transit services.
The authorisation allows the major banks and retailers to provide financial support to Armaguard and for the parties to discuss, agree and implement operational sustainability and efficiency measures across the services provided by Armaguard's cash-in-transit business to those banks and retailers.
The authorisation also allows the parties to develop, but not implement, an independent pricing mechanism in respect of their cash services agreements with Armaguard.
"We consider that the conduct would be likely to reduce the risk of disruption to Armaguard's cash-in-transit services in the immediate future, while the increased sustainability of those services would support ongoing access to cash across Australia," ACCC Deputy Chair Mick Keogh said.
"This is a significant public benefit."
The ACCC considers that, with the conditions set out in this determination, the conduct is likely to result in minimal public detriments.
"This decision will increase future consultation in the cash-in-transit industry," Mr Keogh said.
"The ABA is now required to ensure that an independent expert will conduct reasonable consultation with stakeholders in the development of an independent pricing mechanism proposal."
Further information about the ACCC's final determination is available on the authorisations public register.
Note
The ACCC's role is to consider requests for exemptions from competition laws that may be breached to enable competitors to collaborate on such arrangements.
ACCC authorisation provides statutory protection from court action for conduct that might otherwise raise concerns under the competition provisions of the Competition and Consumer Act 2010 (Cth).
Broadly, s 91 of the Competition and Consumer Act 2010 (Cth) allows the ACCC to grant an authorisation when it is satisfied that the public benefit from the conduct outweighs any public detriment.
Background
Cash-in-transit services involve providing cash transport, management, and processing services. These services are provided to banks, retailers, and independent ATM operators.
On 13 June 2023, the ACCC granted merger authorisation to Armaguard and Prosegur Australia to combine their cash distribution, management and other businesses in Australia, and accepted a court-enforceable undertaking, which is a condition of the merger authorisation. Following this merger, Armaguard became the major supplier of cash-in-transit services in Australia.
On 27 May 2024, the ACCC granted authorisation with conditions to the ABA, the Customer Owned Banking Association, banks, retailers and other industry participants to allow them to develop responses to support the distribution of cash across Australia.
On 3 July 2024, the ACCC granted interim authorisation with a condition to allow the ANZ Bank, Commonwealth Bank, National Australia Bank, Westpac, Australia Post, Coles, Wesfarmers and Woolworths (the Funding Parties) to provide financial contributions to Armaguard.
On 12 September 2024, the ACCC revoked the interim authorisation dated 3 July 2024 and granted a new interim authorisation for an expanded range of conduct with 4 conditions.
On 11 December 2024, the ACCC issued a draft determination proposing to grant authorisation with conditions until 30 June 2026. Also on 11 December 2024, the ACCC revoked the interim authorisation with conditions dated 12 September 2024 and granted a new interim authorisation with amended conditions.
On 25 June 2025, the ACCC granted authorisation with 6 conditions which broadly require:
- the ABA provide regular reports to the ACCC, Reserve Bank and Treasury about discussions, developments and decisions made under the authorisation relating to operational sustainability and Efficiency Measures and the Independent Pricing Mechanism, including any consultation undertaken
- prior to any operational sustainability and Efficiency Measures being implemented, the ABA to provide a report to the ACCC, the RBA and Treasury which describes the measure in detail and sets out the consultation undertaken with other parties (smaller ABA members, COBA, IGA/Metcash, the Australian Hotels Association and Clubs Australia) about the measure including its potential impact on the accessibility of cash in regional and remote areas
- discussions, contracts, arrangements or understandings regarding any operational sustainability and Efficiency Measure and/or Independent Pricing Mechanism to occur at, in preparation for, or arise out of, a meeting, meetings or communications of the ABA Weekly Cash SteerCo or a meeting involving the Reserve Bank or Treasury
- the ABA to ensure that Deloitte (or any alternative independent facilitator) conducts reasonable consultation with specified parties in respect of the development of the Independent Pricing Mechanism prior to any in-principle agreement.
The authorisation made on 25 June 2025 does not extend to the implementation of any pricing proposal. A further application for authorisation of implementation of the pricing proposal is anticipated once agreement between the Funding parties and Armaguard is reached on the proposal.
A separate application lodged by the ABA relating to cash-in-transit sustainability measures and business continuity measures remains before the ACCC for consideration.
