Mr. John Palmer:

We set out the criteria. The Minister will have regard to the position at the end of December 2022 in setting the initial ones. Mr. Gilvarry outlined the various review provisions in his opening statement. When the review is being done, a range of factors have to be taken into account. The first is cash demand, which basically recognises that it is highly likely that the use of cash will continue to decline. We do not know the rate or what will drive it, but the pre- and post-Covid-19 pandemic figures are clear; €20 billion was taken out per year in the years before Covid-19 and that is down to approximately €13 billion now. That is the first figure to look at. This is one of the matters those preparing the national payments strategy are being asked to look at and see whether they can shed any light on it. What would be the impact if cash demand dropped by 50% from today's levels so that only €6 billion or €7 billion was being taken out each year? How would that translate? Would the same number of ATMs be needed? Could we do with half the number? Would it be a straight line or would we end up with a situation where we need to keep three quarters of the ATMs to ensure people have what the Minister considers to be reasonable access to cash?

Population change is another criterion. We see more and more huge developments where the population in relatively small areas is increasingly dramatically, when several thousand apartments are built. That is probably something that would be taken account of, in the first instance, in a local deficiency protection, but when we look at the overall criteria, the way the population is being settled and developments are happening, it is highly likely that the overall criteria will need to change, certainly as regards the number of machines per 100,000 people in different areas.

Financial inclusion is the third criterion. At the very least, we would say that future changes should not worsen financial inclusion. Ideally we would like to increase it.