Cash is legal, but there's no ATM. Will UOKiK make certain there's a place to pay it?

instytutsprawobywatelskich.pl 2 weeks ago

Imagine a female surviving in a country. The pension is credited, in a close store can pay cash, but the nearest ATM is 10 kilometres away. The car's gone, the bus's gone. Does this female truly have access to cash? On paper, yes. In practice, no.

That's how exclusion starts. Not since the ban, the bill, or the announcement that you are not allowed to usage banknotes from tomorrow. It starts much little spectacularly – with disappearing infrastructure. We have already done this in Poland with public transport. For 30 years I've heardthat a bus is not worth living, there are not adequate passengers on a given route, and the self-government cannot afford to pay for another connection. 1 course disappeared, then another. On paper, the man inactive had the right to go to a doctor, work or office. The problem was that he had nothing. According to a nationwide survey presented in March 2026, Communication exclusion affects more than 10 million Poles and Poles27 percent of the population.

Cash in the technofeudal planet Jan Oleszczuk-Zygmuntowski, Paweł Jaworski

Something like this could happen with cash. If the only criterion for maintaining an ATM is its profitability, any single decision to close a device may be business-wise. An operator liquidates an ATM that brings a loss, the bank closes a branch with a cash registry that is not utilized by adequate customers, another bank facility will limit cash handling to a fewer hours a day. After a fewer years we can wake up in a reality where the right to pay with cash inactive exists, but for our own money you gotta drive 10 kilometres – if you have a car.

The freedom to choose how to pay exists only if both cash and digital payments are actually available.

The specified formal admission of cash is not adequate if the infrastructure needed for its withdrawal gradually disappears. If you can pay with bills, but you gotta go 10 kilometers, the choice becomes apparent.

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Scott warned against disappearing infrastructure

When I spoke to Brett Scott in 2022, economical anthropologist and author of the book “Cloudmoney. Cash, cards, code – the war for our wallets”, pointed to this mechanism. He argued that the decline in the importance of cash could not be explained only by the communicative of consumers who spontaneously choose more convenient technologies. The large institutions besides form the environment in which we make these choices.

Scott was talking about a cash infrastructure degradation.

The harder it is to usage cash, the more convenient digital systems seem. The more people decision to the digital world, the easier it is to justify further restrictions on cash infrastructure.

A feedback is formed. In our conversation, Scott spoke straight about "the attack on cash infrastructure, its reduction". A fewer years later, this diagnosis of an anthropologist of financial systems can be brought to a very mundane question: where is the nearest ATM?

This is not a problem invented by opponents of digitization. The National Bank of Poland in the National strategy for the safety of Cash Trading uses the word “banknote waste” and combines the problem of access to cash with safety of cash trading. It's an crucial distinction. We're not just talking about the convenience of a client who doesn't want to go a fewer streets away. We are talking about infrastructure, which the central bank considers important.

Failures, failures, cyber attacks. Cash and our financial safety Angelica Kaczorowska

Ten kilometers for my own money

The strategy adopts as 1 of the indicators a situation where 90 percent of Polish residents have access to an ATM or a bank branch with a cashier service not more than 10 kilometres away. On a map, it could look beautiful reasonable. It looks different for a elder without a car or a municipality in which public transport practically does not exist. A female at the beginning of this text, having an ATM 10 kilometers from her home, would be included in this accessibility criterion. So what if there's nothing to get to this ATM?

The problem is not theoretical. At the end of March 2026 there were 20 337 ATMs in Poland, compared to 20,622 years earlier. Importantly, in the first 4th of 2025, NBP indicated that according to information provided by 1 operator, the decrease in the number of devices was due to the liquidation of unprofitable ATMs, usually located in tiny towns.

And ATMs are just part of the problem. The physical banking network is besides shrinking.

According to KNF (Financial Supervision Commission) data, between March 2025 and March 2026 the number of branches decreased from 4912 to 4877 and the number of subsidiaries, exhibitions and another client service facilities from 2207 to 2166. This is simply a full decrease from 7119 to 7043 facilities. While the presence of the facility on the map does not find anything yet: not everyone operates classical cash handling and cash handling can operate little than the facility itself.

In the fight for cash preservation Robert Azembski

In the monograph Arkadiusz Manikowski and Rafał Zbyrowski, published in 2025 by Wydawnictwo Uniwersytet Warszawskiego, “The conditions for managing the ATM network in Poland – a profitability analysis”, the authors set an acceptable distance to the ATM at about 5 kilometres in agrarian areas and little than 3 kilometres in cities and towns. The data they utilized besides shows that within a radius of 5 kilometres the ATM had 99.99 percent of residents of urban municipalities, but only 74.59 percent of residents of agrarian municipalities. So it is easiest to say that there are adequate ATMs in Poland if you look at the country from the position of the city center. I was late at the Cash Service legislature in Warsaw, and again I felt that the large city's position was besides easy dominated in the discussion of access to cash.

You can besides look at Britain. There, the policy of access to cash assumes that at least 95 percent of residents should have access to withdrawal and payment services at a distance of about 1.6 kilometres in urban areas and about 4.8 kilometres in agrarian areas. It's not just about ATMs, but the difference between this approach and our ten-kilometre criterion makes you think. Why in Poland should we consider it real access to our own money?

What has UOKiK determined for 2 years?

That question leads me to the Office for Competition and Consumer Protection. On June 18, 2024, after a loud protest of Euronet, The president of UOKiK initiated an investigation into the ATM market. In March 2025, the Office informed that the case was ongoing and that it was investigating possible infringements related to the activities of payment organizations or banks in establishing, clearing or charging charges in ATM transactions. I did not find any subsequent public information which would clearly show how the proceedings initiated more than 2 years ago ended and what the UOKiK established.

Therefore, the Institute of civilian Affairs applies to the UOKiK for information. Not due to the fact that I want to be a Euronet spokesman. Besides, Euronet is not the only large independent operator – the second is ITCARD, the operator of the Planet Cash network. Whether a peculiar operator wants to make more money is not my point of reference. I am curious in the more basic question: can an economical model of the ATM marketplace lead to the decommissioning of devices precisely where they are most needed for residents?

So we are asking the UOKiK, among another things, whether he was investigating the way Visa and Mastercard set fees, the remuneration for BLIK withdrawals, the actual cost of ATM operations, the impact of these conditions on the maintenance of the network and the hazard of expansion of “bankroll waste”. We besides ask what the Office did with the ATM Cost task study prepared by the squad of the University of Warsaw, which, as its authors inform, was transferred to UOKiK.

It gets even more interesting erstwhile we look at the December 2025 decision of the UOKiK on a separate case – the acquisition by SIBS global of control over ITCARD, operator of the Planet Cash network.

Here comes a method shortcut that is worth translating from the language of the financial planet into Polish: CDF, or Cash Disbursement Fee. The mechanics is simple. erstwhile a bank client pays money from an independent operator's ATM, the bank pays the operator to make that withdrawal. That fee is CDF. It should not be confused with the commission that the bank can collect from its client – CDF is the settlement between the bank and the ATM operator.

UOKiK wrote that the default CDF fee level is determined by payment organizations specified as Visa and Mastercard, and the default terms of the transaction mostly affect the conditions of competition on the ATM market.

More simply, the CDF determines how much the ATM operator receives from the bank for the withdrawal of cash made by the customer.

If the wage for years fails to keep up with the cost of maintaining the device, transporting and protecting cash, servicing, energy or telecommunications, at any point the question arises: why keep an unprofitable ATM?

In turn, the authors of this monograph of the University of Warsaw indicate that the rates applicable in Visa and Mastercard systems become a mention point besides for many contracts concluded straight between banks and operators.

So if the parties formally negociate the price, but the negotiations take place around the level previously determined by global payment corporations, how much is the real free marketplace mechanism? I don't know the answers and I don't want to pretend I know her. From answering specified questions we have among others the UOKiK.

There is no request for conspiracy to be ruled out.

It's worth going back to Scott, due to the fact that in our conversation he was very clearly cut off from a conspiracy translation of the world, in which respective presidents meet behind closed doors and decide to destruct cash. His diagnosis is more interesting. Large players prosecute their own interests, compete, automate processes and respond to economical incentives. No central plan is needed to make a strategy that gradually displaces cash. Scott even said that "you don't request a conspiracy" to make specified a process happen.

This reminds me of public transport again. No local government that eliminates an unprofitable bus course has to want to make a communication exclusion in Poland. Each decision may be rational. The problem arises erstwhile we look at the sum of these decisions and see full areas of the country without transport. The ATMs could be similar.

Therefore, the issue does not end with me asking how much Euronet should gain or who should pay an additional fewer twelve cents for the payment.

The question is who looks at the full strategy and at the right time notices that a social problem is beginning to arise from seemingly rational decisions of individual entities.

Cash in time of crisis

There is another reason why we cannot look at ATMs solely through the cost table – the crisis.

Cash – salvation in times of crisis or liquidation? Justyna Pierzyńska

After the start of the war in Ukraine, within 8 operating days from 28 February to 7 March 2022, the banks collected PLN 42.1 billion from the National Bank of Poland. The NBP later wrote about her stabilizing role. In Ukraine, in consequence to attacks on energy infrastructure and long-term energy supply interruptions, the POWER BANKING network was established – facilities prepared to supply basic financial services besides during blackouts.

Blackout in Spain and Portugal on 28 April 2025 reminded us again how rapidly problems with electronic payments and the operation of parts of ATMs could arise. Banco de España later described that electronic payments had ceased to work, any ATMs were closed due to a deficiency of power or communication, and any of the operating devices were emptied of the banknotes. The banknote has 1 feature that it is easy to forget erstwhile everything works: it does not request the Internet, application, battery or operating terminal. Cash is kind of like a fire extinguisher at home. all day we may think he's just taking a seat. To the first fire.

Blackout? Only cash will save us! Robert Azembski

This does not mean, of course, that the state should keep all ATM at all costs. Just like it doesn't make sense to send an empty bus all half hr to all village.

But between keeping everything at all costs and leaving the full infrastructure solely accounting for profitability, there is inactive something like a minimum standard of availability.

And this standard is worth arguing about. Is access to cash within a 10-mile radius sufficient? Would 5 kilometers be more reasonable? Should there be mechanisms to support the maintenance of infrastructure in areas at hazard of exclusion? Or do we consider that we do not request any standard and where Poles will be able to pay their money, should the marketplace decide only? This is besides a possible answer. Just tell it to Poles and Poles.

From Paying Day Cash to libraries and UOKiK

On August 16th, we celebrated Cash Pay Day for the 5th time. This year's slogan was "STOP cash exclusion!". The civilian Affairs Institute, the ESG PRO and the Coalition for Cash drew attention to a simple paradox: cash can stay legal and at the same time become increasingly hard to pay and use.

V Cash Pay Day – August 16. halt cash exclusion Małgorzata Jankowska, Rafał Górski

On that day, we besides started the recruitment of public libraries and their subsidiaries, to which 3,000 free copies of Brett Scott’s book “Cloudmoney. Cash, cards, crypto – war on our wallets”, issued by the Institute in Polish. We want a discussion about the future of cash not just between banks, operators, global paying corporations and officials. It should besides run in libraries, local communities and between average people who make simple choices all day: cash, card or phone.

It's not about getting anyone to throw distant a payment card or a smartphone. It is about preserving the alternate and knowing the strategy from which we become increasingly dependent. Brett Scott points to this trap: if 1 infrastructure is gradually expanded and the another restricted, at any point it is hard to talk of an equal choice.

In the same direction, the activities of the Coalition for Cash, to which both the civilian Affairs Institute and the ESG PRO belong. The ESG PRO implements the task "Stop cash exclusion – participation of citizens in defence of the right to choose payments". Education, books going to libraries, mobilising citizens and questions addressed by the Institute to public institutions are fundamentally 1 problem: whether the choice of how to pay will stay a real choice.

We can set up Cash Pay Day, give out books and repeat to people: you have cash, you have a choice.

But if at the same time the places where you can retreat the banknotes will vanish from the map, sooner or later, you will gotta ask how much more of this choice is left.

Thirty years of work for better transport has taught me that exclusion does not begin at a time erstwhile individual takes the formal right to travel to a doctor, school or work. It starts erstwhile the bus stops coming. Cash could be the same. Nobody has to ban her. It is adequate that gradually the places where you can get it or pay it without proceeding from the seller “I should not spend”.

That's why I ask the UOKiK not only about Euronet, Planet Cash, Visa, Mastercard, BLIC or the amount of fees. I'm asking you something more basic: Does individual in Poland make certain that we do not have the right to cash on paper?

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