Acceptance of Cash

The Government and the business community must prove that the current strategy of focusing on cash access alone works, and that it works for everyone. (Conclusion)

HM Treasury, the Financial Conduct Authority and the Bank of England must provide an interim assessment of the effectiveness of the access to cash regime as soon as is practical. This must include an assessment of whether the regime has affected the willingness of businesses to accept cash. (Recommendation)

We welcome the commitment by small businesses, including convenience stores, to accepting physical cash from those who need to pay for it. We note that for some types of businesses, including market traders, cash remains fundamental to the preservation of markets. (Conclusion)

We are disappointed that there is not more clarity on the costs of different payment types, and that businesses are continuing to bear the costs of a lack of competition in the payments processing market. (Conclusion)

HM Treasury, the Bank of England and the Financial Conduct Authority must ensure that the work of the Payment Systems Regulator on competition in payments markets is taken forwards during and after the consolidation of the Payment Systems Regulator into other regulators. (Recommendation)

HM Treasury must commit to ensuring that costs of accepting payments by payment method are transparent so that businesses of all sizes can make informed choices on payment methods. HM Treasury should commission work to produce a model of costs produced independently of payment providers. (Recommendation) 47

Digital payments systems are vulnerable to failure for reasons ranging from accidents or hostile actions by state actors, through to failure by a supplier in a retail bank’s digital supply chain. Physical cash has a vital role to play as a payment method that is independent, that is backed by the UK Government and that can be used as an analogue payment method when digital ones fail. (Conclusion)

In discharging its responsibility for national security and resilience, HM Treasury must consider the value of physical cash in emergency preparedness. This may include recommending that cash is held by individuals in case of emergency, and considering what role cash distribution might play in a severe payment systems outage. (Recommendation)

Cash is an enduring payment method that many people prefer to use and on which people who do not have equal access to non-cash payment methods rely. Although technology may progress further and reduce the number of people who rely on cash, demand for physical cash will always exist. The Government’s focus on reducing digital exclusion as part of the work of the Financial Inclusion Committee is welcome, but digital products and services may not fully solve the problem. Developing solutions to financial exclusion must include an examination of all potential options, especially where vulnerable groups face specific problems. For a significant minority of people, that risk entails not only inconvenience but partial exclusion from society. The cost will be borne by vulnerable minorities, including people in poverty, people struggling to escape domestic abusers and people with learning difficulties. (Conclusion)

HM Treasury must broaden the terms of reference of the Financial Inclusion Committee on “digital inclusion and access to banking services” explicitly to address the risk that a two-tier economy will lock the digitally excluded out of the economy. HM Treasury must commit to reviewing internally and externally produced evidence on cash access and cash acceptance in the UK and make a public judgment on whether the system is equitably meeting the needs of consumers and businesses every five years. As financial digitalisation continues, HM Treasury must work to ensure that innovation in this space is guided by a commitment to inclusivity, rather than increasing the number of individuals who are digitally and financially excluded. (Recommendation)

The Department for Business and Trade, the Ministry of Housing, Communities and Local Government and HM Treasury must work together to challenge businesses and local government to set out how they are supporting financial inclusion, particularly for people who rely on cash due to their disabilities, in line with the Equalities Act 2010. (Recommendation) 48

There may come a time in the future where it becomes necessary for HM Treasury to mandate cash acceptance if appropriate safeguards have not been implemented for those who need physical cash, and the level of cash acceptance begins to lead to widespread detriment. To ensure that HM Treasury has the information it needs to make this decision, cash acceptance levels in the UK must be monitored to ensure we do not sleepwalk into a loss of cash acceptance for those who need it. HM Treasury must provide the Treasury Committee with annual reporting on cash acceptance levels and provide an analysis of HM Treasury’s view of the tolerable level of cash acceptance in society. (Recommendation)

We note that this debate is being conducted in other countries, and more interventionist approaches are being considered than is currently acceptable to the UK’s Government. We note with interest the range of approaches to cash in these similar countries, including the approach taken by the European Union and Australia which explicitly sets cash acceptance as inextricably linked to cash access. Other countries have focused on providing digital solutions to some of the issues posed by the decline in cash usage and acceptance, such as Singapore’s MyMoneySense platform and state-backed payment systems such as UPI in India and PIX in Brazil, which lower costs for merchants. (Conclusion)

In its interim assessment of the current cash access regulation (see Conclusions and recommendations for the UK), HM Treasury must include an assessment of how the problem of declining cash access is being tackled internationally. This must include an assessment of elements of, or all of, these approaches would work in the UK. (Recommendation) 49