In its Retail banking Review, the Department of Finance points to the pressure on cash services from the disappearance of bank branches and the move to digitalisation It suggests that Government policy should support the development and maintenance of a sustainable and resilient cash system for as long as cash is needed.

To achieve this objective, the Review Team believes a legislative framework should be put in place to manage any further decline in the cash infrastructure.

"The objective of this framework must not be to reverse what has occurred or seek to maintain cash usage at its current level but rather to manage further decline in an orderly way," states the report. "It is important future changes in the cash infrastructure do not outpace the expectations or needs of society."

The high cost of providing cash services, as well as the move to a more digitalised banking model has incentivised banks to move away from the direct provision of cash services. Instead, the effective operation of the cash system now relies on a small number of Cash-in-Transit (CIT) firms and ATMs owned and operated by unregulated non-bank providers.

The report further recommends that such firms are brought within the regulatary perimeter of the Central Bank.

It also advocates for the developmentn of a National Payments Strategy to set out a roadmap for the future evolution of the entire payments system.

"Work should start in early 2023, and the work should be completed in 2024," states the report. "The strategy should take into account developments in digital payments, and guide how future changes should be made to access to cash criteria and other issues."