In Sweden, the county administrative boards have the task of ensuring that the possibility to use basic payment services corresponds to the needs of society. Their assessment is that access to basic payment services for private persons is in general satisfactory. This is mainly because many people can and want to use digital payment services. However, elderly people, those born abroad, and persons with functional variations experience greater difficulty making payments. For instance, it is expensive to get help to pay bills at a bank branch. It can cost up to SEK 150 per bill, and be even more expensive if you are not a customer of the bank. Moreover, it may be difficult to find a bank office that still accepts cash for those who want to pay their bills in cash.

The banks have been given a clearer responsibility for cash management

As of January this year, some of the larger banks are obliged to offer cash services for withdrawals and deposits. The purpose of the legislation is to slow down the development towards a cashless society. A minimum level is determined here with regard to the number of places in the country where one can withdraw cash and deposit daily takings, and large banks are responsible for meeting this level. In autumn 2020, Bankomat made twelve new establishments in areas that previously lacked an ATM, to comply with the new legislation’s requirement for accessibility. In total, the number of ATMs in Sweden is largely unchanged in relation to 2020.

Some risk exclusion when manual cash management disappears

The access to manual cash services, that is, the possibility to deposit and withdraw cash over the counter and to receive help paying bills, has continued to decline in 2021 as the banks have continued closing down offices. At present, Handelsbanken is the only major bank offering cash services, at six bank branches. The savings banks are continuing to offer this type of service at their branches. The savings banks offer the possibility to withdraw cash over-the-counter at 140 branches, and the possibility to pay bills in cash over-the-counter at 128 branches.

Number of bank offices with cash

Figure: Bank offices with cash have declined drastically in recent years

Manual cash services fulfil important functions that cannot be replaced by the automatic services the banks currently offer through Bankomat ATMs. This applies in particular to withdrawals and deposits of larger sums, deposits of coins, help in paying bills over the counter and secure places for withdrawals. As there is no legislative protection for these services, they risk gradually disappearing altogether. This means that groups in society that for various reasons need to use manual cash services to manage their finances, will find it increasingly difficult to do so.

Right to payment accounts with basic features

Access to payment accounts and payment services is a necessity to manage one’s finances. Consumers need to be able to receive transfers, for instance, salary or study support, and to be able to make transfers of their own and execute payments, such as paying their rent and their electricity bills. They also need bank cards, to be able to buy things in shops in a society that is increasingly abandoning cash, or to be able to withdraw cash from ATMs. Within the EU, the Payment Accounts Directive gives all consumers who are legally resident in the European Economic Area (EEA) the right to open a payment account with basic functions.

Finansinspektionen notes that the banks have on the whole introduced routines to live up to the requirements in the payment services directive regarding the right to payment accounts and are aware of their obligations under the directive. At the same time, there are indications of shortcomings in the application of the regulations. Complaints from consumers show, for instance, that banks sometimes deny consumers payment accounts because the customer lacks a personal identity number or Swedish ID documentation, that a credit assessment has been made or that the bank does not accept passports from countries that are a part of the EEA. A large number of the refusals are made with reference to the anti-money laundering regulations and their far-reaching requirements regarding identification and KYC. Finansinspektionen considers that in a future review of the Payment Accounts Directive, it will be important to clarify how the regulation relates to the anti-money laundering regulation to make it easier to apply the regulations.

Future legal requirement improves accessibility for people with disabilities

In April 2019, the European Parliament and the Council issued a directive with an accessibility requirement for products and services, what is known as the accessibility directive. This means, for instance, that bank services, including ATMs and card readers, shall be more accessible to people with functional variations or disabilities. A public inquiry has investigated how the directive can be implemented in Sweden, and proposes that the Riksdag shall require that the products and services covered by the directive can be perceived with more than one sense. Texts and other visual information shown in the products or services must also be easy for the intended target groups to understand. The inquiry proposes that the legislative amendments enter into force in June 2025.

Infrastructure for cash becoming increasingly vulnerable

The use of cash is now so low in Sweden that it is beginning to be difficult to maintain the underlying infrastructure needed for households, banks and retailers to be able to obtain cash. An increasing number of Swedes are choosing to pay digitally (see Cash used less and less frequently in Sweden and abroad), but at the same time there are groups who need to use cash to be able to manage their payments. Moreover, it is important that we can use cash as a back-up alternative if the electricity grid or internet are not working. MSB, the Swedish Civil Contingencies Agency, encourages private persons to have a sum of cash in low denominations at home, so that they can manage in the event of a longer disruption in the payment system.

However, it is important to remember that cash management is also dependent on, for instance, electricity, telecommunications, transport and personnel, which means that cash management would also be affected by disruptions to these functions. The only cash one can be sure of having access to in a disruption is what one has at home in one’s own crisis box. Moreover, cash can only replace some types of payment needed by society, for instance, payments to retailers and private persons. Cash is not a possible contingency plan for large electronic payment flows, for instance, salary payments, pension payments and payments of invoices.

Being able to use cash requires an underlying infrastructure that is dependent on cooperation between public authorities and private actors. The infrastructure is based on the Riksbank issuing new cash and destroying worn out cash, on the banks giving the general public access to cash and on the cash-in-transit companies ensuring it is transported and counted.

There are several fixed costs in maintaining the infrastructure for cash. To enable the private actors in the distribution of cash to cover the fixed costs, they must raise the prices of their services in line with the decline in the use of cash. This in turn means it becomes less profitable for shops to accept cash.

As of 2020, Loomis is the only nationwide cash-in-transit company on the Swedish market. Unlike the banks, Loomis has no obligation to continue to provide its services. As the distribution of cash is dependent on the existence of cash-in-transit companies, the infrastructure is very sensitive to changes in Loomis’ operations.