Cash Distribution Framework Act 2026: new regulation for Australia’s cash

Key takeaways

Cash Distribution Framework Act 2026: new regulation for Australia’s cash

Banks, retailers and ATM operators depend on cash transport, processing and management services to maintain access to cash. Rates of cash use are collapsing, placing the sector in structural decline with service providers in the industry under pressure (such as Armaguard which has received $100 million in funding support from major banking and retail customers over several years to maintain continuity). Against that challenged backdrop, Australia’s new Cash Distribution Framework Act seeks to establish regulatory guardrails for fair and transparent contracting, continuity and crisis management for cash distribution services.

A new Cash Distribution Framework Act 2026 overhauls pricing, access and continuity of Australia’s near-monopoly cash-in-transit infrastructure. The legislation permits the RBA to designate a cash distribution services provider which has a significant role in the cash distribution system as a ‘designated entity’. It would regulate how a designated entity negotiates service agreements and access agreements for cash distribution services and facilities access.

The framework has features familiar from the ACCC's regulation of NBN Co and the Australian Rail Track Corporation: the designated entity proposes baseline terms for ACCC approval, but customers retain scope to negotiate alternative terms. The Cash Distribution Framework also adds ACCC powers to determine standard terms, an arbitration pathway if negotiations fail and service-level standards for cash distribution services and facilities access.

Implications for customers

For customers of a designated entity, the framework adds regulator-backed protections for negotiation, pricing transparency, dispute resolution and service levels.

• Negotiation protections. A designated entity must negotiate cash distribution service or facilities access agreements in good faith.
• Contract transparency. Each service and access agreement must state the pricing (or how price is determined), customer complaints procedures and alternative dispute resolution processes.
• Reference terms and arbitration. A designated entity must apply to the ACCC for approval of standard terms for cash distribution services or facilities access. However, parties may negotiate alternative terms and either party may request that the ACCC appoint an arbitrator where terms cannot be agreed. The designated entity must reasonably attempt to enter into the agreement on the terms determined by the arbitrator and comply with the determination, which takes account of pricing principles, the public interest and relevant service-level standards.
• Service levels. The ACCC may set service-level standards for availability, frequency, speed, timeliness, location, pricing, relevant facilities and reporting. Civil penalties apply for contraventions.
• Transitional power. During a 24-month transition period, the ACCC may issue an interim direction requiring a designated entity to provide cash distribution services or facilities access to a new or existing customer on specified terms, including pricing, or to report information or provide documents. An interim direction does not apply to services or access provided under an agreement already in force when the entity becomes designated if that agreement has not been varied.
• Cash access and acceptance. Maintaining nationwide cash access as cash use declines will increase costs and the pricing principles may require metropolitan customers to cross-subsidise regional services. The ACCC’s power to set service-level standards for availability and location represents a regulatory expectation that banks and retailers cannot fully withdraw from cash acceptance or go entirely digital.
• AML/CTF obligations. The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) expressly prevails over the Bill’s crisis stay and moratorium provisions. An Australian Transaction Reports and Analysis Centre -regulated entity’s compliance obligations (e.g. suspicious-matter reporting, threshold-transaction reporting and record-keeping) continue unaffected during a designated entity’s crisis.

Implications for secured and priority creditors

The Bill would permit the RBA to trigger crisis resolution for a designated entity on various triggers, such as where its financial viability is at risk or critical services have ceased or are likely to cease. Once a crisis power is exercised, creditor enforcement rights are limited to protect continuity of services.

• General stay. Counterparties cannot deny obligations, accelerate debts, terminate or close out arrangements or transactions, or enforce security against a designated entity merely because the RBA has exercised a crisis power or the body corporate is under statutory management or subject to a transfer determination or direction. The protection extends to relevant related bodies corporate. However, close-out netting, market netting and related arrangements remain effective.
• Moratoria. Court and tribunal proceedings, enforcement processes and disposals of property are stayed while the moratorium applies, except with a court order or RBA or statutory manager consent. The usual decision-period enforcement opportunity for a secured creditor holding security over all or substantially all of a company’s property does not apply.
• Termination and self-executing clauses. The RBA may, in some circumstances, declare that certain termination rights and self-executing provisions in contracts with designated entities are temporarily suspended.
• Compulsory transfers. Subject to Ministerial consent and the framework’s other conditions, the RBA can transfer shares or all or part of a business to a receiving body despite contractual restrictions on assignment or transfer. The receiving body is substituted for the designated entity in instruments relating to transferred assets, liabilities or shares.
• Insolvency. A person proposing to appoint an external administrator to a designated entity must first give the RBA at least seven days’ notice, unless the RBA consents to an earlier appointment. A new insolvent-trading safe harbour applies to debts incurred during that notice period in the ordinary course of business or with RBA consent or by court order.
• Employee entitlements. The RBA must not exercise its crisis-resolution powers in relation to a designated entity if doing so would make an employee’s entitlements less beneficial than immediately before the action or would engage a replacement employee to perform the same or substantially the same work on less beneficial terms.

The regime therefore prioritises continuity of cash distribution services over ordinary creditor control, limiting restructuring options if a designated entity enters financial distress.