On Mar. 22, UK PSR announced review of how well SD12 is working.
UK PSR announced 1st review of specific direction 12 on how well it works in practice.
Follows UK PSR Mar. 2022 issued specific direction 12 (SD12) to LINK to maintain broad geographic spread of UK's FTU cash machine network, see #119777.
Specific Direction 12 (SD12)
PSR issued SD12 to LINK in Mar. 2022, in force to Jan. 2, 2025, unless varied/revoked.
SD12 is designed to ensure that LINK maintains a broad geographic spread of the UK’s free-to-use (FTU) cash machine network; and that it meets service-user needs by having in place and maintaining appropriate and effective policies and measures.
UK PSR said it would review SD12 after 1 year and, if still in place, after 2 years.
SD12 has been in place for just over a year, so PSR sought views on how it is working.
Scope of Call for Views
Invited comment on four areas, focused on the operation of SD12, namely how effective SD12 has been ensuring appropriate policies, measures in place to support maintenance of a broad geographic spread of the FTU ATM LINK network in the UK.
How well SD12 requirements worked in practice regarding maintaining, replacing protected ATMs; whether monitoring requirements under section 8 of SD12 led to sufficient transparency, if any is superfluous, or further aspects require monitoring.
Whether SD12 should remain in place, given some wider initiatives since introduced.
These include, among other things, the Financial services and markets bill.
Consultation End
The call for views is open until 5pm on Apr. 21, 2023.
Jul. 2023 SD12 Review Outcome
On Jul. 14, 2023, UK PSR issued the findings of its review of the functioning of SD12, including the non-confidential responses to call for views published in spring 2023.
PSR concludes SD12 worked well in ensuring LINK continues to meet its commitment to maintain geographic spread of free-to-use ATMs, and meet service users' needs.
Regulator therefore decided that SD12 should remain in place, will review in 2024 in context of changes made by Financial Services and Markets Act 2023 to regulation.
Despite positive findings, 4 areas for improvement which PSR will work on with LINK.
Understanding how LINK makes use of the flexibility in SD12 (defined radius approach) to ensure broad geographic spread of ATMs, including how economic activity is taken into account in considering replacement or new installation of free-to-use ATMs.
Increasing the visibility and level of detail of LINK's published data on protected ATM coverage, including decision-making on ATM replacement and updated to the list.
Transparency of LINK's decision-making on setting interchange fees, improvements to LINK's ATM replacement procedures e.g. protected status reviews, Post Office criteria.
PSR engaging with LINK about feedback received from stakeholders, review findings, to discuss if further work needed and agree any associated timelines in due course.
In Mar. 2024, UK PSR called for views on specific direction 2nd review, see #206538.
