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The rules that were meant to stop Britain running out of cash points will be two years old this month, and by the government’s own yardstick they are working: more than 95 per cent of the population now lives within the distances ministers set for reaching cash. The harder question, as the branch network keeps shrinking, is what exactly those rules guarantee. The answer is notes and coins. It is not a bank.

Since 18 September 2024, when the Financial Conduct Authority’s access-to-cash regime came into force under powers in the Financial Services and Markets Act 2023, banks and building societies have had to assess the impact before they close a branch or an ATM and, where a significant gap opens up, plug it. In practice that has meant a fast-growing network of shared “banking hubs”, run for the industry by Cash Access UK and staffed over the counter by the Post Office, with community bankers from the high-street lenders rotating through by day of the week.

The numbers are real. In the regime’s first year, the FCA counted 121 banking hubs opened and 93 new cash deposit services, delivered through ATMs and Post Office counters. Twenty of those hubs came not from a bank closure at all but from communities using the rules to request one. By the House of Commons Library’s count there were around 225 hubs operational in March 2026, and by the spring more than 230 were open, with over 275 recommended. The industry and the government have committed to 350 by the end of this parliament. That leaves roughly 120 still to build, and a lengthening list of towns waiting.

That gap between recommended and open is where the promise frays. LINK, the network operator that assesses each community against distance and travel-time criteria, can recommend a hub within weeks of a branch closure being announced. Opening one, finding premises, fitting them out and staffing them, routinely takes many months more. A town can lose its last bank and then wait the better part of a year for the shared counter that is supposed to replace it. For a small business banking its daily takings, or a pensioner who budgets in cash, that interval is not a rounding error.

And what arrives at the end of it is deliberately narrower than what left. A banking hub is not a branch. The Post Office counter handles deposits, withdrawals and balance enquiries; the community banker who can talk through a specific lender’s products is typically present one or two days a week, on a rota shared between the banks. There is no mortgage adviser, no business relationship manager, no in-person route through a fraud case or a bereavement. The regime was designed around one measurable thing, access to cash, and it has hit that target. The slower erosion of face-to-face banking that sits alongside it is largely outside the rules.

It is also a floor being poured under a receding tide. LINK’s own figures show its network dispensed £76.7 billion across roughly 1.3 billion transactions from about 44,000 ATMs in 2025, both down on the year before as card and mobile payments keep taking share. The FCA reckons about five million people still rely on cash or cannot use digital alternatives, and it is that group, not the national average, that the hubs exist to protect. The uncomfortable read is that Britain is building physical cash infrastructure at pace precisely as the volume flowing through it falls, because the cost of stranding the minority who depend on it is judged too high. That is a defensible policy choice. It is not the same as a healthy branch network, and it should not be mistaken for one.

The criteria themselves invite argument. LINK’s assessments lean on distance and travel-time thresholds, which means a community that loses its only bank can still fall short of qualifying for a hub if a branch or a Post Office sits a prescribed distance away, however awkward the journey. MPs have pressed the point through the spring in a run of parliamentary questions and debates on banking hubs and on access to banking services more broadly, and the Treasury has leaned on the 350 commitment as the answer. Whether 350 is the right number, or merely the number that was promised before anyone counted how fast branches would keep going, is a question the rollout has not yet had to confront.

For now the trajectory is set. The Post Office has signed a five-year deal with Cash Access UK to keep running the hubs, which puts the operating model on a durable footing and signals that this parallel network is meant to last, not to bridge a gap until something better appears. That permanence cuts both ways. It guarantees that cash will stay reachable for the people who need it, which is no small thing. It also quietly concedes that the full-service branch, for most of the places that have lost one, is not coming back, and that the shared counter with a banker who visits on Tuesdays is now the settled shape of physical banking across much of the country.

Two years in, the cash-access rules have done the specific job Parliament wrote for them. The mistake would be to read the rising hub count as a sign that Britain’s banking presence is recovering. It is a measure of how carefully the state has chosen to manage the decline.

Finance & Markets Correspondent
Covers: Finance, capital markets, technology investing

David Whitmore covers the intersection of capital and code — the funding rounds, market structures and policy moves that shape how money flows through the technology economy.