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New legislation aimed at protecting access to cash has now come into force, placing clear obligations on financial institutions to maintain ATM availability nationwide. The measure responds to growing concerns about the disappearance of cash services, particularly in rural communities affected by branch and post office closures.

While the use of digital payments has accelerated for years, especially since the pandemic, cash remains central for many people who rely on it for budgeting, security or everyday transactions. Despite the growth in card payments, more than €51 billion worth of bank notes were in circulation at the end of 2024, and withdrawals remained relatively stable at €12.76 billion for the year.

The move also reflects a wider concern about resilience. As digital payment systems become increasingly sophisticated, they also create vulnerabilities. The Government is expected to issue guidance encouraging households to keep a modest emergency cash reserve at home for situations like power cuts, severe weather or cyber incidents that disrupt electronic payments.

Both the Government and the Central Bank have stated that cash must remain widely available and accepted, and the new law is designed to guarantee that access.

How the new rules will work

The legislation sets specific benchmarks for ATM availability. A minimum percentage of the population must live within 10 kilometres of an ATM, and there must be a defined number of ATMs per 100,000 people. A proportion of these machines must operate around the clock.

Alongside ATMs, the law requires a minimum number of designated cash service points within the same 10-kilometre radius. Post offices are expected to play a key role here.

The access standards are based on research conducted by the Central Bank in 2022, which found very high ATM proximity rates nationwide. These benchmarks will now form the compliance targets for the new law.

Who is responsible for maintaining ATMs?

Responsibility will fall on credit institutions that hold at least 6 per cent of current accounts and 7.5 per cent of household deposits for six consecutive months. This places the obligation firmly on the main retail banks, including AIB, Bank of Ireland and PTSB.

The Central Bank will oversee compliance, monitor ATM locations, and enforce corrective actions where needed.

Addressing ATM gaps and local deficiencies

If a community experiences difficulty accessing cash, even where the national criteria are met, anyone can notify the Central Bank of a possible deficiency. The regulator will assess the submission and decide whether the area requires intervention.

Where an ATM blackspot is confirmed, banks will be notified and given up to eight weeks to propose and implement a solution.

The law also allows for flexibility. If national cash usage falls by more than 15 per cent in a single year, the required number of ATMs can be adjusted. The Central Bank and the Minister for Finance can also conduct broader reviews to reflect changing patterns of consumer behaviour. Engagement with consumer groups, older people, individuals with disabilities, and businesses will form part of that process.

What happens next?

The Central Bank will shortly launch a public consultation covering key operational issues such as ATM opening hours, withdrawal limits and the denominations available from machines. The process will also seek feedback on areas facing particular challenges in accessing cash.

Its first report under the new framework is expected in February, providing early insights into how the system is functioning.

Although the legislation will not reverse the wider shift towards digital payments, it reinforces the principle that cash remains an essential option for many people. Research continues to show strong demand for the ability to pay in cash, with two-thirds of Irish consumers surveyed by the ECB in 2024 saying it is important to retain the option.

The objective of the new law is to preserve choice. For most people, daily life will not change significantly. For others who rely on cash or feel vulnerable without it, the reassurance and accessibility delivered by this measure may prove highly significant.

Disclaimer: This article is based on publicly available information and is intended for general guidance only. While every effort has been made to ensure accuracy at the time of publication, details may change and errors may occur. This content does not constitute financial, legal or professional advice. Readers should seek appropriate professional guidance before making decisions. Neither the publisher nor the authors accept liability for any loss arising from reliance on this material.