Access to banking services review: what financial institutions need to know before the 20 July deadline

While access to cash is already covered by legislation and FCA oversight, there are currently no express protections for access to in-person banking services. The independent review was commissioned specifically to assess the impact of changes, over the last few years with the advent of extensive access to on-line banking, to in-person banking services in the UK and to identify any consumer detriment, meaning this process could directly lead to the first-ever statutory or regulatory framework governing branch and in-person service provision.

The Call for Evidence seeks responses from the widest possible range of stakeholders, including financial institutions, consumers and consumer groups, local authorities, SMEs, and trade bodies, with stakeholders from across the UK encouraged to provide evidence. Both quantitative and qualitative empirical data are welcome, along with evidence in the form of case studies, meaning firms can and should draw on their own internal data, customer insight, and branch network analytics to inform their responses. Submissions prepared to address access to cash analyses will be relevant and pertinent. There may also be particular product sets where banks have evidence that in-person support can provide better consumer outcomes.

The review is focused on those who require access to in-person banking services, including groups who are vulnerable or have specific needs, rather than simply those who prefer it. Specifically identified groups who may most require in-person access include vulnerable consumers, older or younger customers, digitally excluded people, and SMEs and cash-intensive businesses, all of whom should feature prominently in how firms frame evidence of their own service delivery decisions.

A key question the review is intended to answer is whether the decline in access is causing detriment to customers, and the extent and materiality of that detriment. The review will specifically examine impacts on financial inclusion, the ability of customers to manage their finances, and the effect on business operations, meaning firms' branch closure decisions, including their impact assessments and mitigation measures, will likely be scrutinised.

The review will assess what role alternative channels play in providing services and how effective they have been, specifically including banking hubs, Post Office branches, and mobile branches. It will also examine the role that digital, hybrid, and assisted digital models can play in the provision of in-person banking services, giving firms the chance to make a positive case for the investments they have already made in alternative access solutions.

The review is asking what the likely future of in-person banking services provision will be under current regulation, including looking 5–10 years and 10+ years ahead. It is also examining what the potential risks of further reductions to in-person access are, meaning firms should be prepared to provide forward looking evidence on anticipated evolution of delivery channels and products as well as more topical planned network changes, and the commercial pressures driving them.

The review is examining whether there is any geographic variation, including in rural, urban, and deprived areas, in dependency on in-person banking. It is also asking what evidence exists of detriment arising from any particular geographic distribution of closures or service reductions, so institutions with significant footprints in specific regions should consider the geographic granularity of any evidence they submit.

Cross-cutting themes for the review include the impacts on SMEs, interactions with wider financial services policy and regulation, and comparisons with other jurisdictions. The review also asks how competition can or should be maintained between different business models offering banking services, and whether there are different roles to be played by digital challenger banks and traditional retail banks, raising questions about competitive dynamics and market structure that could inform any responses.

The Government has previously stated that evidence collected by the review will inform future decisions on whether further action is needed. The review will use evidence received through the Call for Evidence to assess customer needs, the scale and materiality of detriment, market dynamics and mitigations, and to develop recommendations. Given the FCA’s focus on ensuring good customer outcomes and the government’s desire to continue to support an inclusive agenda, a new regulatory regime, potentially including obligations on firms to maintain minimum service levels, cannot be ruled out.

The Call for Evidence will close for input on 20 July. During the Call for Evidence period, the Chair will also seek to meet with industry, charities, and consumers to collect further evidence, with the Chair's report and recommendations due to be provided to the Government in October 2026. The short windows before the close of the call and the close of the call and the publication of recommendations means firms need to engage on this promptly to be able to provide clear evidence and to ensure their voices are heard.