Wholesale Cash Firms: Oversight Regime

Emma Reynolds Excerpts

Thursday 12th June 2025 Written Statements

[The Economic Secretary to the Treasury (Emma Reynolds)]

Wholesale cash distribution is the mechanism that supplies physical cash—specifically banknotes and coins—to retail banks, cash machines and the wider retail market. This is a vital mechanism for ensuring the sustainable provision of and reliable public access to cash.

Under part 5A of the Banking Act 2009, the Bank of England is responsible for managing risks to the effectiveness, resilience, and sustainability of the WCD system. Specifically, the Act gives the Bank of England powers to “oversee” firms recognised by the Treasury in wholesale cash oversight orders as performing relevant WCD activities and as being market significant. The Bank of England can give directions, issue codes of practice, and supervise firms’ compliance. Further detail on the Bank of England’s supervisory approach can be found in its statement of policy. ¹

His Majesty’s Treasury’s decision on recognition

Today I am announcing which firms the Treasury has specified as recognised persons in wholesale cash oversight orders. As required under the Act, in making this decision the Treasury has: notified firms it considered for recognition; sought and considered any representations from these firms; and consulted relevant regulators, including the Bank of England.

Following this extensive process, I am announcing today that HM Treasury has made wholesale cash oversight orders to the following firms:

Barclays Bank UK PLC;

Barclays Bank PLC;

G4S Cash Centres (UK) Limited;

HSBC UK Bank PLC;

HSBC Bank PLC;

Lloyds Bank PLC;

Bank of Scotland PLC;

National Westminster Bank Public Limited Company;

The Royal Bank of Scotland Public Limited Company;

Post Office Limited;

Santander UK PLC;

Vaultex UK Limited.

These wholesale cash oversight orders have been made on 5 June 2025 and will come into force today, 12 June 2025.

In making these orders I have considered the requirements under section 28 of the Small Business, Enterprise, and Employment Act 2015. This requires Minsters to include in certain secondary legislation that regulates businesses and other bodies a provision for review or a statement as to why this is not appropriate.

I consider a provision for review inappropriate as it would be disproportionate relative to the economic impact. The impact on business is expected to be de minimis with annual fees that the Bank of England can charge recognised firms effectively capped by the Treasury, detailed in the Banking Act 2009 (Wholesale Cash Oversight Fees) Regulations 2024. The Bank of England can charge a maximum of £400,000 per firm per year for supervision fees and £150,000 for “special projects”. The current aggregate impact of making these orders is de minimis as defined in the better regulation framework.

Further, including a provision for review would be undesirable for particular policy reasons. The legislation contains provisions which necessitate ongoing review, meaning further provisions would be duplicative. Under section 206J of the Banking Act 2009, HM Treasury must revoke an order if it is no longer satisfied that the firm meets the relevant criteria. Section 206Z2 also requires the Bank of England to produce an annual report on the discharge of its functions and the extent to which risks in the WCD system have been managed. That report will subsequently be laid in Parliament. HM Treasury also plans routine engagement with the Bank of England that will monitor the implementation and impact of the regime.

¹ https://www.bankofengland.co.uk/paper/2023/sop/sop-on-the-banks-supervisory-approach-to-market-oversight-for-wholesale-cash-distribution

[HCWS698]