Australian Banking Association (CIT Initiatives and Business Continuity Planning)

On 18 October 2024, the Australian Banking Association (ABA) lodged an application for authorisation with the ACCC relating to cash in transit initiatives and business continuity measures. Under the application, the ABA sought revocation of authorisation AA1000664 and substitution of the authorisation suspended.

The ABA requested interim authorisation to enable participants to engage in the proposed conduct while the substantive application for authorisation is being assessed by the ACCC. On 23 October 2024, the ACCC granted interim authorisation with conditions.

On 9 April 2025, the ABA made two small variations to its application for authorisation, to:

1. remove the word ‘urgent’ from the definition of Proposed Conduct in the Application to make clear that the Application extends to short, medium and long-term solutions provided that the activities fall within the prescribed purposes of the Application.
2. seek to vary the term of the authorisation by a further 12 months so that it will expire on 31 December 2026.

As varied, the ABA sought authorisation for the ABA and two or more of the authorised parties to:

(a) engage in discussions and exchange information that is for the purposes of, and reasonably necessary for, developing and evaluating potential responses to:

1. the viability of wholesale cash distribution in Australia
2. securing continued access by banks, retailers, other businesses and/or members of the public to retail cash services in one or more metropolitan and/or regional locations, and/or
3. supporting customers and businesses who use cash in the event of a suspension, disruption or exit of Armaguard's cash in transit services, and

(b) reach in-principle agreement on the form and content of any industry responses to be pursued. Substitution would also provide this protection to these parties to implement business continuity measures in the event of, or in reasonable anticipation of, a suspension, disruption or exit of Armaguard's cash in transit services.

This application for revocation and substitution sought to consolidate conduct which was authorised under two separate authorisations relating to the cash-in-transit industry (AA1000654 and AA1000664).The ABA submits that the Proposed Conduct is the same in all material aspects as the authorised conduct under those applications, except that the ABA proposes some modifications to the conditions of authorisation.

On 24 October 2025, the ACCC issued a draft determination proposing to grant authorisation with conditions until 31 December 2026.

On 17 December 2025, the ACCC decided to grant authorisation with conditions, until 31 December 2026.

Copies of the ACCC’s final determination, draft determination and interim authorisation are available below.