PSR call for views: Specific Direction 8 - Which? response

Summary:

• Which? welcomes the opportunity to respond to the PSR’s call for views of Specific Direction 8. 
• Specific Direction 8 should remain in place at least until legislation to protect access to cash has been passed and a regulatory framework has been introduced. 
• The PSR should review how Specific Direction 8 fits into a wider regulatory framework once legislation has passed. In the interim, Specific Direction 8 should be maintained to protect the widespread geographic footprint of ATMs. 
• We disagree with the argument that Specific Direction 8 should not remain in place because of the introduction of other initiatives in the cash space. It would be particularly unwise to remove Specific Direction 8 based on the promise of schemes such as cashback without purchase, which are yet to be introduced and tested.
• We are concerned by the continued closure of protected ATMs, including the temporary closure of 48 protected ATMs due to the pandemic. LINK and the PSR should work closely on identifying improvements to the Protected ATM scheme to prevent further closures.