COTA Australia supports the Government’s objective of safeguarding Australia’s cash distribution system, but argues the Bills need to do more than protect the wholesale network. They must guarantee practical access to cash through ATMs, deposit facilities and other consumer-facing services.
Cash remains essential for many older Australians, particularly people on low or fixed incomes, those in regional and remote communities and people with low confidence using digital banking. As bank branches and bank-operated ATMs decline, access that is distant, unreliable or costly is not meaningful access.
COTA Australia recommends strengthening the Bills by bringing all consumer-facing cash infrastructure into scope; creating a clear statutory obligation for reasonable withdrawal and deposit access, including low-cost or fee-free options and protection from cash surcharges; establishing measurable geographic access standards; enabling communities to trigger access assessments when services are withdrawn; and making the ACCC the national coordinator of comprehensive public cash-access data and reporting.
These changes would protect independence, financial inclusion and resilience during digital outages and emergencies, not just cash-distribution infrastructure.