Back in August 2011 I blogged that it was time for Europe to establish proper interchange or set up a structure for direct charging. Well, it comes as no big surprise that since then we have not seen any upward movement in ATM interchange. And it is significant to note that in the UK, one of Europe's most developed markets, rates fell again in January 2013 with the most noticeable drop on balance enquiries.
So it seems to me that it has become more urgent to campaign for the commercial freedom for all ATM operators to consider direct charging as an alternative route to the economic viability of their ATMs.
As we all know, security and compliance costs have risen for ATM operators during recent years. A good example is France, which last year introduced mandatory cash security in all ATMs.
The next big one in terms of operational costs for Europe's ATM operators is the proposed European regulation on data protection. And we are also eagerly awaiting the draft proposals on access to basic bank account services where ATMs seem to have been designated as the main provider of these services by the Europe's Parliamentarians. "At whose expense?," one must ask.
How will Europe's commercial banks, savings banks, credit unions and independent ATM deployers develop the economic model to meet the demands of regulators without the facility to charge non-customers direct if interchange is a paltry amount?
I would like to remind you that in some European countries, direct charging at ATMs is not permitted under the transposition of the Payment Service Directive, but in others where it is not banned by the regulators, Visa Europe's internal rule book is preventing it.
In Germany, direct charging at ATMs, with the blessing of the competition authorities and the department of consumer affairs, is now two years old. Despite the early upheaval for some ATM operators and the continued gremlins of cross-border euro ATM transactions and Visa's continued block, it seems to have settled in well with the industry and the consumer.
Europe's 8,000 banks need of the right to direct charge so that they can start to fund, manage and develop the ATM channel more effectively.
This will be of equal benefit to the consumer who is starting to see the elimination of ATMs from typical low-transaction locations — primarily areas that are rural, sparsely or seasonally populated, and/or socially-deprived.
There is a glimmer of hope on the horizon as we await the outcome of the Polish parliamentary debate on direct charging. This is the country where, due to interchange decline of 65 percent in 2010, ATMs disappeared or their planned deployment didn't go ahead.
So almost three years on, the government is no longer prepared to tolerate the lack of access to cash for consumers outside of high-traffic urban locations. A victory in Warsaw's parliament will be a great turning point for ATMIA Europe's campaign to secure direct charging for ATM operators across the region.
Flora Hamilton joined the ATM Industry Association (ATMIA) with responsibility for Europe in October 2009. Trained in business science, Flora has previously worked for the Public Relations Consultants Association, BBC Worldwide, the Press Association and Association for Measurement & Evaluation of Communication.