I thank the committee for the opportunity to speak on the access to cash Bill. Access to cash is about social inclusion. It is about being able to buy something in a shop or café, to buy a bottle of water on a train journey or to attend a sporting match without being discriminated against or having your autonomy eroded. However, there are places in Ireland now where you cannot do any of those things if you want to pay with cash because it is cashless payments only.
Over 1 million people in Ireland are aged 60 and older, representing one in four adults. They are disproportionately likely to experience digital and social exclusion due to cashless payment models. They benefit from using cash, as has been recognised by the Minister for Finance. Rushing to embrace new payment technologies will deepen ageism and age discrimination. We know this at Age Action because three in ten older persons do not use the Internet at all. Another three in ten older persons use the Internet but with below basic digital skills, meaning they might not be able to manage their financial affairs online with confidence or safety. People are asked to tap with their cards to pay but if you are not on the Internet, you cannot check your balance and manage your money digitally, so people prefer cash.
There are six in ten older persons who experience some level of digital exclusion, for whom cash is therefore preferable. It is also the case that more than seven in ten older persons get most of their income from the Department of Social Protection, including three in ten who get more than 90% of their income from the Department of Social Protection. There are many older persons who are on a low fixed income who manage their financial affairs through cash, and have done so for all their lives. Many older persons do not have digital devices for online banking or cannot afford them, and many older people did not or do not have the opportunity to develop digital skills, especially in the absence at the moment of any State scheme that would support them to do that.
There is going to be a large cohort of older persons who are digitally excluded and who will prefer to use cash for at least the next 20 years. Some of the reasons for digital exclusion, such as physical disabilities and cognitive decline, will not disappear over time. Consequently, we need robust infrastructure and regulations to guarantee easy access to and acceptance of cash for at least 20 years, with the expectation that the need for this may continue beyond that time.
While the access to cash Bill is helpful, it is not comprehensive enough to prevent financial exclusion. We would like to see a requirement where all publicly-funded services and all consumer-facing retail would be required by law to accept cash, which would mean ending the all-too-common practice of putting up a sign to say “cashless payments only”. Also, no consumer should pay more just because they choose to pay in cash, which can happen in a number of cases. Access to cash and acceptance of cash needs to be actively monitored and the rules enforced. People will need a phone number that they can ring to register an issue, and there should be timelines for remedial action if, for example, cash machines are removed or are out of order.
The general scheme of the Bill talks about the metrics of how many cash points there are per 100,000 people in the population but it allows for local deficiencies, and inadequate public transport must be included in that definition of local deficiencies. On average, people aged 66 or older live 2.7 km away from their nearest public transport stop. Nearly half of women and 28% of men over the age of 65 have unmet transport needs, and half of women over the age of 75 do not have a driving licence. People need to be able to access cash and so when we are looking at a geographical area with 100,000 people and cash points in it, we have to make sure that people actually have public transport links to access those points, otherwise it is no good to them.
It is also important that the Bill should recognise that not all cash service points are open 24-7. Counter services obviously will not be but an increasing number of ATMs are inside shops and shopping centres and therefore, there are limited opening hours when people can access their cash. The law needs to take account of when they are available, as well as how many.
It is also the case that not all access to cash points are equal in quality. We know from surveys, including those by the Department of Finance, that older persons are least likely to use cashback from a retailer or ATMs. They prefer to withdraw or lodge money over a counter, which is equally important, in a bank or post office. For some people, ATM screens can be difficult to read, and as some older persons fear being robbed while using an ATM in certain places, there are issues there as well. We have heard a lot about older persons' dissatisfaction with bank branches that lack a traditional counter service and as members know, when AIB recently announced that 70 bank branches were to go cashless, there was outcry about that and the decision was reversed. It is exactly that which concerns people - that traditional branch services may be withdrawn, leaving them without the services they are used to, to both deposit cash and to withdraw it.
As ATMs are being regulated for the first time, the law should perhaps consider regulating some other aspects of their operation, like ensuring transparency on any charges or banning fees for using ATMs, certainly to withdraw your own money in an Irish context. Banks should limit what kind of charges are allowed for others. They must also provide clear contact details in cases of difficulties, making sure there is a time limit for how long a cash machine can remain empty. There is no point in having a network of cash machines if they are all empty half the time. They must also ensure they are located in safe, clean, well-lit areas. There may be a role for the Bill to mandate the Central Bank to produce guidelines and to enforce those.
The other point I want to make is that Age Action deals with a lot of cases of financial abuse through our information service. Forcing older persons to use services and rely on skill sets with which they are not comfortable can increase risk. Age Action has heard from older persons who have handed over their personal details to allow others to manage their financial affairs because they cannot do it themselves as a result of being pushed online. This creates vulnerabilities for abuse, and even where this does not occur, it creates relationships of dependency that weakens an older person’s autonomy and control over their own life. This is also the case where they are forced to rely on others for transport to get to and from ATMs or banks.
Access to cash supports - and the widest possible access to cash, making it easier for people - supports social inclusion, safety and autonomy, and gives people choice and control in managing their own financial affairs. That is really the central point from Age Action's perspective.
