Armaguard and the New Cash Law: What It Means for Venues
The short version
- Linfox Armaguard moves most of Australia’s cash. Since 2024 it has needed financial support from the big banks and retailers to keep running.
- The Cash Distribution Framework Act 2026 became law in late August 2026. It is the first law to regulate cash-in-transit (CIT) companies directly.
- The Reserve Bank designated Armaguard under the Act on 3 September 2026. The ACCC can now oversee its prices, service levels and access terms.
- Armaguard has offered the ACCC an interim pricing undertaking. The ACCC consulted on it until 16 October 2026, and its decision is still to come.
- For venues, the aim is steadier cash supply and fairer CIT terms. It does not promise lower costs.
How we got here
Cash-in-transit companies collect, sort and deliver banknotes. They refill bank branches, retailers and many ATMs. As cash use fell, the cost of running armoured trucks and cash centres was spread over less cash, and the sector consolidated.
The ACCC authorised Armaguard to combine with Prosegur, its main rival, with a three-year undertaking on prices and service to existing customers.
Banks and major retailers agreed to fund Armaguard for up to 12 months. The ACCC granted interim authorisation in July 2024.
The funders added $25.5 million for July to December 2025, and work began on an independent pricing mechanism.
Parliament passed the Cash Distribution Framework Act. The RBA designated Armaguard on 3 September.
Sources: ACCC merger and authorisation registers; Australian Banking Association joint statement, 14 July 2025; RBA media release, 3 September 2026.
The 2024 support package came from ANZ, Commonwealth Bank, NAB, Westpac, Australia Post, Coles, Wesfarmers and Woolworths. The ACCC had to authorise it because competitors were agreeing to act together.
In July 2025 the Council of Financial Regulators and the ACCC released a joint consultation on a regulatory framework for cash distribution. The Treasurer introduced the Cash Distribution Framework Bill on 2 July 2026.
What the new law does
The Act gives two regulators separate jobs.
- The Reserve Bank decides which providers are important enough to be covered. It can designate a provider whose failure would seriously affect access to cash. If a designated provider gets into financial trouble, the RBA has crisis powers. These include giving directions, appointing a statutory manager and transferring the business.
- The ACCC oversees the commercial side. It can look at prices and other terms for critical cash services, set service standards such as availability and timeliness, and give interim directions. Designated providers must negotiate in good faith, and there is an arbitration process when parties cannot agree.
The RBA has said designation does not mean it will use its crisis powers. It means it can act if it needs to.
Where things stand now
Armaguard’s 2023 merger undertaking ended on 4 September 2026. On 23 September 2026 Armaguard gave the ACCC a proposed undertaking covering interim prices, service offering, national coverage, third-party access to its cash centres, complaints, dispute resolution and independent audits. If accepted, it would apply while the ACCC assesses long-term prices and service levels.
The ACCC took submissions until 16 October 2026. It is also considering whether to use its interim direction powers. Both decisions are still to come, and we’ll update this page when they land.
What the ATM industry told the ACCC
The ATM Industry Association (ATMIA) speaks for ATM operators, banks, manufacturers and cash-in-transit companies worldwide. On 16 October 2026 it made a submission to the ACCC on the Armaguard undertaking. Its test is simple: the system only works if people can get cash out of a working ATM. Dash contributed to the submission as an ATMIA member.
ATMIA asked the ACCC to:
- Protect independent ATM operators. Fair, non-discriminatory access to cash services, on terms no worse than the banks get. Transparent prices, with at least 90 days’ notice of changes. No tying, and no using an operator’s service information to chase its sites.
- Look at the whole chain. Higher servicing costs can mean fewer refills, or ATMs that stop paying their way. That means fewer places to get cash.
- Keep independent cash-in-transit companies in the game. Fair access to cash centres and wholesale banknotes, and recognition of bank bailment, where bank-owned notes stock independent ATMs.
- Make notes ATM-fit. Brand-new polymer notes can double-pick and jam. One member reported repeated faults in parts of Queensland in late 2024 when new notes dominated. More in Cash quality a problem? Simple fixes.
- Measure real access in regional towns. Count working ATMs, refill frequency and outages, not just whether a postcode has CIT coverage.
- Use interim powers carefully, with the whole cash ecosystem in mind, not just the biggest carrier.
It’s the industry backing what we tell venues every day: keep cash moving, keep it local, keep it affordable.
What it means for your venue
- Who refills your ATM. If your venue loads its own cash, you depend less on CIT runs. If a CIT company refills the ATM for you, its service and prices now sit under ACCC oversight.
- CIT costs. The ACCC’s role is to keep prices and terms fair and transparent. It is not a price cut. Under its proposed undertaking, existing Armaguard customers keep their current contracted price (Armaguard customer explainer).
- Service continuity. The RBA’s crisis powers are designed so that cash keeps moving if a major provider fails. That lowers the risk of a sudden stop in deliveries.
- Coverage. Regional coverage is part of the proposed undertaking. Watch for the ACCC’s decision if your venue is outside a capital city.
How Dash helps
- Managed for you: installation, cash logistics, fault alerts, reconciliation and national field service, all visible in the Dash web portal.
- Options to self-fill, so you can use your own takings to load the ATM and reduce CIT visits.
- We watch the changes. Dash will tell affected venues if CIT terms or service change.
See the options to buy an ATM, or our services for managed venues.
FAQ
Is the cash distribution law in force?
Yes. The Cash Distribution Framework Act 2026 became law in late August 2026, and the Reserve Bank designated Linfox Armaguard under it on 3 September 2026.
Will my CIT costs go down?
Not necessarily. The ACCC can oversee prices and terms so they are fair, but the law does not set a price cut. The ACCC is still assessing Armaguard's proposed interim undertaking.
Does this affect venues that fill their own ATM?
Less directly. Self-fill venues still rely on their bank for cash, and banks rely on CIT companies, so a stable CIT sector helps everyone.
What did the ATM industry ask the ACCC for?
ATMIA asked for fair access and transparent pricing for independent ATM operators and cash-in-transit companies, ATM-fit banknotes, and for the ACCC to measure real cash access, such as working ATMs and refill frequency, especially in regional areas.
Dash ATM has built and managed ATM networks across Australia since 2012, led by founder Paul Wrigley, in the ATM industry since 2002. Keep cash local.
Sources: Armaguard: Understanding the proposed undertaking · ATMIA submission to the ACCC, 16 October 2026 · ACCC: Cash Distribution Framework · ACCC: Armaguard interim pricing consultation · RBA: Designation of Linfox Armaguard, Sept 2026 · Treasury: Government introduces legislation to regulate cash, 2 July 2026 · Parliamentary Library: Cash Distribution Framework Bill 2026 digest · CFR and ACCC: Regulating cash distribution consultation, July 2025 · ACCC: Interim authorisation for Armaguard support, 2024 · ABA: Funding extension for Armaguard, July 2025 · ACCC: Armaguard and Prosegur merger authorisation · Armaguard: Customer explainer on the proposed undertaking