The ACCC has issued a draft determination proposing to authorise the Australian Banking Association (ABA) and other industry participants to develop ways to ensure the continued distribution of cash across Australia.
The ACCC also proposes to allow the parties to take certain steps to ensure cash-in-transit services would continue if Armaguard's services were suspended or disrupted. Armaguard is the main national distributor of cash in Australia. The implementation of any other measures would be subject to a separate application for authorisation, if required.
Cash-in-transit services form the basis of the cash distribution system, where physical currency is transported, processed and stored across the country. Cash-in-transit companies service the cash-related needs of banks, large retailers and hospitality venues, and also offer cash management services such as banknote refilling for ATMs.
"We are proposing to grant this authorisation to allow the ABA and other relevant parties to discuss and develop responses to ensure consumers and businesses can continue to access cash," ACCC Deputy Chair Mick Keogh said.
"Public access to physical currency is incredibly important, especially for consumers who are reliant on cash payments including those in regional and remote areas."
The ACCC has included three conditions in its proposed authorisation, one of which requires the ABA to develop initiatives to protect access to cash in remote areas, where there are often fewer options for accessing cash services.
Interim authorisation for this conduct has been in place with conditions since October 2024. The conduct has also been subject to previous ACCC authorisations, including an interim authorisation first granted in December 2023.
The ACCC is now seeking submissions on its draft determination.
This draft determination does not relate to the development or implementation of any pricing mechanisms between Armaguard and its major customers. The ACCC's website will be updated with information relating to those issues when an application for authorisation is received from the parties.
Further information about the ABA's application and how to make a submission by 14 November 2025 is available on the ACCC's website.
Note
When competitors act together, they require some form of exemption from the ACCC to avoid the risk of breaching competition laws.
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, section 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
The ACCC has granted 4 authorisations relating to cash-in-transit services since 2023:
- 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 12 September 2024, the ACCC granted authorisation with conditions to allow the ABA, its member banks, Australia Post, retailers, supermarkets and other industry participants to collaborate so they can ensure there is continuity of cash-in-transit services. The ACCC's authorisation allows the parties to collaborate and prepare for any suspension or disruption of cash-in-transit services.
- On 25 June 2025, the ACCC granted authorisation with conditions for the ABA, and the major banks and retailers ('the Funding Parties') to provide financial contributions to Armaguard and discuss and implement operational sustainability and efficiency measures. The ACCC also authorised the parties to discuss and reach agreement on (but not implement) development of an independent pricing mechanism in respect of each (future) cash services agreement with each of the Funding Parties. Authorisation was granted with conditions until 30 June 2026 but does not extend to the implementation of any pricing proposal - the ACCC expects a further application for authorisation of implementation of the pricing proposal in due course.
