A new law that requires financial institutions to ensure that an ATM is located within 10km of the vast majority of homes and businesses has come into force.

As one of his first acts as the new Minister for Finance, Simon Harris has formally signed the “access for cash” legislation. It will set the minimum number of ATMs to be available per 100,000 people, and also contains measures to prohibit ATM withdrawal fees in some instances, and to set a maximum amount when a fee may be charged.

The Finance (Provision of Access to Cash Infrastructure) Bill 2024 is to provide for the continued provision of sufficient and effective access to cash infrastructure for individuals and SMEs. The bill emerged from a recommendation made by the Ratil Banking Review, published in November 2022.

Once signed, the Finance (Provision of Access to Cash Infrastructure) Act 2025 (section 5) Order 2025 and the Finance (Provision of Access to Cash Infrastructure) Act 2025 (section 10) Order 2025 will came into effect on 28^th November, 2025

The legislation was passed by the Oireachtas in May and signed into law by then President Michael D Higgins.

Section 5 of the act requires the Minister for Finance, in consultation with the Central Bank, to prescribe the percentage of the population that must be within a specified distance of not less than 5km and not more than 10km of an ATM and cash-service point in each of the State’s eight regions.

Section 10 requires the minister, also, in consultation with the Central Bank, to prescribe thresholds for ‘designated entities’, credit institutions that hold a set percentage of both current accounts and household deposits in the Irish market for two consecutive quarters.

Designated entities include AIB, Bank of Ireland, and Permanent TSB. These under current data are responsible for maintaining the access-to-cash criteria.

Brain Hayes of the BPFI said the legislation means the three retail banks will have sole and legal responsibility for maintaining both the prescribed levels of access to ATMs as well as counter services across the State.

This is despite the fact they only control about one-third of the general infrastructure.

He said if an independent ATM provider withdraws one or more ATMs, or leaves the market entirely, leading to a breach of these criteria, it will fall to the retail banks to fill the gap. He also stated that the likes of Revolut and An Post will not be required to provide ATMs.

Central Bank Governor Gabriel Makhlouf described the regulations as “an important step” towards ensuring that consumers continued to have access to cash and in protecting the resilience of the cash system.

“They will also provide for the fair, orderly and transparent management of Ireland’s cash infrastructure as payment preferences continue to evolve,” he added.

The Central Bank will start a consultation before the end of the year on proposed guidelines outlining how individuals and businesses can notify it about a potential local deficiency in cash services.

NB – This is a guide for information purposes only and does not constitute legal advice. If you have an issue requiring legal advice, please contact any of the team at Nolan Farrell & Goff LLP, whose numbers can be found on our website www.nfg.ie, or email info@nfg.ie.