Wholesale cash supervision

Overview

Wholesale cash distribution is a key part of protecting public access to cash. It supplies banknotes and coin to bank branches, ATMs and retailers and ensures that cash deposits are processed and recirculated into the public domain. The wholesale cash system therefore plays an important role in allowing the public to use notes and coins as they choose.

Although cash use is declining, many still prefer it. A January 2025 Bank of England survey found that about one in five consider cash to be their preferred payment method and use it day to day. We are committed to supporting cash as a viable means of payment.

The Bank has regulatory powers to ensure that the UK's cash distribution infrastructure remains effective, resilient and sustainable.

How does the UK cash cycle work?

NCS Notes Circulation Scheme diagram March 2024 v3

The wholesale cash industry is responsible for distributing banknotes and coins in the UK.

When required, new notes and coins are collected by the wholesale cash industry participants from a UK cash issuer – the Bank of England, the Royal Mint and Scotland and Northern Ireland commercial banknote issuers.

Banknotes and coins are held at a network of cash centres across the UK and withdrawn when needed to meet customer demand. The wholesale cash industry supplies operators of ATMs, bank, building society and Post Office branches, retailers and foreign exchange companies. In the UK, most cash enters circulation via ATMs.

The public use banknotes to pay for goods and services, deposit money into a financial institution or retain them as a store of value.

Retailers, bank branches and post offices return deposits to a cash centre using a cash-in-transit provider. At the centre, notes and coins are authenticated, reconciled and sorted. Old or damaged ones are separated and returned to the respective issuer for destruction.

Ensuring effective, resilient and sustainable wholesale cash distribution

In May 2019, the Bank of England established the Wholesale Distribution Steering Group (WDSG), which brought together industry stakeholders to explore the resilience and sustainability of the UK's wholesale cash distribution model. WDSG participants decided not to proceed with a proposed consolidated utility model, opting instead for industry-wide and individual firm actions to support cash infrastructure in early 2022.

In June 2023, the Financial Services and Markets Act 2023 was passed into law, giving the Bank market and prudential oversight powers over the wholesale cash distribution industry, under part 5A of the Banking Act 2009. The Financial Conduct Authority also received powers in relation to retail access to cash under part 8B of the Financial Services and Markets Act 2000 (FSMA).

The Bank held several consultations on its Supervisory Approach and Codes of Practice for wholesale cash distribution, starting in December 2022. The Codes of Practice set the minimum standards that recognised firms must meet. The final Codes of Practice, supporting guidance, Data Catalogue and Reporting Form were published on 31 March 2025. The codes are outcomes-based and aim to ensure an effective, resilient and sustainable wholesale cash infrastructure.

To allow the Bank to apply its oversight powers, firms identified to have significance in the wholesale cash distribution market were recognised by HM Treasury on the 12 June 2025.

Further details on the implementation and operation of the Wholesale Cash Distribution Market Oversight (WCDMO) regime can be found below.

Wholesale Cash Distribution Market Oversight regime

See below for materials and updates relating to the Wholesale Cash Distribution Market Oversight (WCDMO) regime. Its objective is to manage risks to the effectiveness, resilience and sustainability of UK wholesale cash distribution market, helping to protect access to cash.

As of 12 June 2025, the following firms are subject to Wholesale Cash Distribution Market Oversight Orders, as designated by HM Treasury under Part 5A of the Banking Act 2009 - introduced by the Financial Services and Markets Act 2023. For more information, see the ministerial statement published by HM Treasury.
- Barclays Bank UK plc and Barclays Bank plc
- G4S Cash Centres (UK) Limited
- HSBC Bank UK plc and HSBC Bank plc
- Lloyds Bank plc and Bank of Scotland plc (Lloyds Banking Group)
- National Westminster Bank plc and Royal Bank of Scotland plc (NatWest Group)
- Post Office Limited
- Santander UK plc
- Vaultex UK Limited
- Statement of Policy on Bank’s approach to Wholesale Cash Market Oversight
- Codes of Practice (March 2025)
- Guidance to Codes of Practice (March 2025)
- WCDMO Data Catalogue (March 2025)
- Reporting Form (March 2025)
- Instructions for uploading Reporting Form in XML Format
- XSD Schema file (March 2025) - For recognised persons to develop their own reporting methodology whilst adhering to Bank information gathering requirements)