National Payments Strategy – Public consultation – IPRA Response

National Payments Strategy – Public consultation – IPRA Response

13th February 2024
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The Irish Petrol Retailers Association [IPRA] makes the following set of submissions in relation to the National Payments Strategy on behalf of our members, being forecourt operators and retailors across the country.

The IPRA understand that “the overarching goal of the NPS is to enhance and build public trust in, and the effectiveness of, the payments system” and that four key principles will guide this work, being:

· Access and Choice – promoting reasonable options for consumers and small business.

· Security and Resilience – of the payments system and system operators.

· Innovation and Inclusion – future focus that enhances interoperability and inclusion.

· Sustainability and Efficiency – solutions that have regard to cost / benefit and the environment.

We also note the scope of the NPS as “primarily focused on the experiences of, and outcome for, consumers and small business within the retail payment system”.

The IPRA does not believe the Minister for Finance should be given the necessary power to require certain classes of firms, sectors or sub-sectors to accept or facilitate (to whatever level) the acceptance of cash. We believe that, if required as part of the NPS, the only class of business that the Minister for Finance should be given the necessary power to require to accept or facilitate the acceptance of cash is for public bodies, and not for private enterprise.

We note the European Commission has suggested “healthcare, supermarkets, post offices and pharmacies” and that the public consultation has refrained from suggesting sectors in the Irish marketplace but please note in this context the only sector that the Minister for Finance could perhaps be given the necessary power over should be public services or perhaps solely An Post.

The IPRA has set out it’s submission responses below, noting, we have only responded to questions we believe relevant to our trade association and its members, being “small businesses” for the context of the scope of the NPS.

6.1 Do you believe there is, or there may be, a trend emerging of non-acceptance of cash in

Ireland? Where or in what circumstances have you experienced this?

We do not believe this is the case for our industry, being petrol stations across the country. We believe this would be a deterrent to customers and therefore businesses would not choose to go down this route of not accepting cash. We believe that cash will always be accepted in service stations across the country and therefore it does not need the Minister to have the power to require the acceptance of cash.

Some of the larger supermarkets have “card only” tills, presumably this is to speed up transactions and get queues moving faster. They have continued to also provide self-check out “cash tills as well so no one in society is being left out.

The majority of our member stations still have employees physically present at the tills so the cash or card payment method takes roughly the same amount of time and therefore deciding to not accept cash would not be a decision retailers would be taking anyway. Some members offer card or card and cash payment at their pumps. This decision has been made to reduce costs (for service stations without shops attached to the pumps) or where there is a shop has been implemented to prevent fuel theft.

There is no evidence whatsoever of fuel retailers being reluctant to accept cash.

6.2 Do you agree with the principle of universal cash acceptance? Or do you believe it can be

limited to certain critical classes of payment?

We believe, cash will remain in society for a variety of reasons, further we believe if it were to become limited to certain classes then this surely should be only to public state related bodies.

6.3 Do you believe it remains appropriate or necessary to ensure acceptance of cash as a form of payment?

Yes, but we don’t believe the Minister should have the power to demand this.

6.4 Do you believe you have enough choice as to how you can pay for everyday goods and services?


6.5 If monitoring shows that the acceptance of cash is inadequate, what should be considered when developing remedial measures?

Focus on public services, public transport, local authority fees, An Post, TV license payment, NCT testing centres, Recycling centres, National museums entrance fees etc.

Research shows the breakup of spending to be 45% retail, 38% services, 14% social and 3% miscellaneous. This mix shows the importance of cash remaining in use both in retail and services as a fairly close mix. Thus, any decision to focus solely on mandating the usage of cash in healthcare, supermarkets, post offices and pharmacies would make no sense given the high percentage also spend in services. Targeting solely essential retail makes no sense as even the vulnerable non tech users in society spend their money also on services and social requirements so any mandate must include other businesses outside of the essential retail services sector. There is enough choice for people to use various methods of payment.

Cash is expensive to interact with as a retail business. There is a cost to safely store this on site, protect employees from any threat of cash theft or attempted cash theft while working, cost to transfer cash to and from banks and the time spend by employees counting each working till throughout the day to make sure it balances. None of these costs are associated to the same extent with electronic payments. Yet, retailers still take cash and will continue to do so but should not be mandated to do so as this would be an impediment on their right to run their business as they choose (nothing that it would be very unlikely for essential retailers to stop taking cash for the reasons already set out above).

In the instance that the Minister were to get and use the power to mandate cash acceptance of our members stores there would most likely need to be a subsidy offered for providing this service if it ever came to the point in the future (which we cannot foresee at the present time) where it was not worth the retailers’ expenses to continue to accept cash. This would be due to potential increases in the cost of keeping cash and employees handling cash safe and transporting this cash to banks regularly. Again, this is not something we can foresee but should be borne in mind in case cash use was to be mandated only for a specific sector.

5.5 Within the Access to Cash legislation, what factors should be considered when the distance and population density criteria are met in order to identify if a local deficiency exists? How should this be addressed?

This should be addressed by re-opening and maintaining existing An Post offices throughout the country. Compelling frontline retail only to accept cash raises costs for frontline retail. If cash acceptance is, in fact, to be mandated by the Minister (whom the IPRA believes should not be given this power at all) then it should be compelled for all businesses, off licences, coffee shops, GAA events, concerts, festivals, public services, hospitals, professionals etc. This cannot be just another hit on frontline retail.

There would also need to be mandates on the banks to provide and properly maintain more ATMs across the country even in rural areas. The banks are leaving the ATM space and there are only 9 private ATM operators in the country. Presumably the banks are leaving the space because it is not profitable so any mandating placed on the private ATM operators will only increase their costs of doing business which will firstly, raise the costs on retailers are they pass these costs off and eventually will push the private ATM operators out of the market also. This will be detrimental to the entire goal of the NPS.

If this plan did proceed to just hit frontline retail in order to address local deficiencies, then there would need to be a very large concession made to frontline retailers in the form of a large reduction in bank fees and additional subsidies for the cost of businesses being required to handle cash.

5.6 Have you (as a consumer or small business) experienced barriers to access to cash? If so, what are they? What would be helpful to counter these?

No, as consumers. Cash is expensive to handle as a small business. Often frontline retailers end up needing to buy cash in order to fill ATMs. This urgency comes because the local bank ATMs run out of cash and customers needing access to cash need to use the frontline retailers ATM. This rush on cash places significant pressure on retailers ATM machines and costs them money to keep the cash stocked in the ATM. The banks should be compelled to have a maximum fill on their ATMs at weekends, bank holidays and Christmas etc. to help to prevent the rush on ATMs in retail shops.

By way of example, AIB charges one IPRA member 45 cents per Eur100 for handling their cash. This needs to be massively reduced in order to decrease the barrier to accessing cash for retailers.

Public bodies have an obligation to act efficiently in their duties to minimise their impact on the taxpayer and provide a high quality services. While doing so they must also provide fair access to public services. Therefore, ensuring a balance between efficiency and access by the public is important.

6.6 What is your view on the levels of acceptance of cash in Ireland by public bodies for public services?

Not many public services accept cash. For the vulnerable, older, with lower income levels, limited digital or low literacy skills or those without internet access. etc. in society expending the cash acceptance levels of public services would be the quickest and easiest way to solve the access to cash issue.

6.9 Should all public services have an obligation to accept or facilitate the acceptance of cash?

Yes, and certainly before mandating frontline retail to accept cash. The Minister should only be given the power to mandate this for public services.

is there a sub-set of essential services that should be obliged to accept cash payments?

Yes, An Post and GPs.

Annex 4 – About you

1.  What is your name

Orla Allen

2.  What is your email address?

3.  I am responding as:

A representative of an organisation

4.  If you are responding on behalf of an organisation, please enter your organisation name

here: Irish Petrol Retailers Association

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