Armaguard cash-service pricing: retailers can respond by 16 October

A small retailer paying to have cash collected or delivered has a chance to tell the Australian Competition and Consumer Commission what an interim Armaguard arrangement needs to cover. Submissions close on 16 October 2026. This is a consultation, so the useful job is to check the proposal against the shop’s actual costs and service needs.

The ACCC’s 29 September announcement explicitly invites both small and large retailers, along with banks and other interested parties. It is considering an undertaking proposed by Linfox Armaguard covering interim prices, its service offering and national coverage, and third-party access to cash centres.

The proposal also includes complaints handling, dispute resolution and independent audits. The ACCC has not accepted the undertaking. If accepted, it would operate while the regulator assesses longer-term cash-distribution prices and service levels.

What the proposed prices would cover

The ACCC’s consultation letter describes several pricing categories rather than one price for every customer. Current contracted prices would continue under the proposal.

For an existing customer whose contract ends during the proposed term and whose annual cash-in-transit services bought from Linfox Armaguard are below A$100,000, the proposed renewed price would be the current contracted price, with annual increases no greater than CPI.

That threshold measures annual cash-in-transit services bought from Linfox Armaguard. It is not the retailer’s turnover. A small shop should check its service agreement and bills before assuming which category would apply.

Other proposed categories use open-book pricing. They include existing customers buying annual cash-in-transit services worth at least A$100,000 from Linfox Armaguard whose contracts end during the proposed term, existing customers without current contracted prices, and new customers. The letter describes annual escalation capped at CPI plus 7.5%, with pricing based on direct costs, reasonable indirect costs and overheads, and a pre-tax margin no greater than 10%. Those inputs would be disclosed confidentially to the customer.

These are proposed terms, not accepted caps or guaranteed savings. The letter does not give a specific cash-service price. Our recommendation is to ask the provider which proposed category would apply to the business and use the existing agreement as the starting point for any response.

Service coverage belongs in the response too

The consultation covers more than the invoice. Proposed national coverage would maintain currently serviced postcodes and provide for offers at reasonably serviceable new locations. Third-party cash-centre access and the handling of complaints and disputes are also part of the proposed undertaking.

A retailer’s response can therefore focus on whether the proposed arrangements address its service needs as well as its cost. Our recommendation is to gather the relevant agreement, recent charges and a record of the service the business needs before commenting. Keep the response specific to the issue the ACCC is asking about.

The ACCC is also seeking views on using its interim direction powers. Such directions can address risks to cash availability or critical cash-distribution services by requiring specified services or facility access on specified terms. The regulator is considering directions while it assesses the undertaking, or instead of or alongside it.

How to make a submission

The official consultation page gives the documents and submission address: [email protected]. Responses on the undertaking close at 4 pm AEDT on Friday 16 October 2026.

For Perth readers, that is 1 pm AWST, converting the stated AEDT deadline to Perth time. Use the ACCC page to check the submission details before sending the business’s response.

For comments about interim directions, the consultation letter asks for views as soon as possible: the ACCC may issue a direction without notice. Do not assume the undertaking deadline is the timetable for that feedback.

The ACCC intends to publish submissions. If a response includes confidential information, identify that material and substantiate the confidentiality claim when submitting. Check this before including commercially sensitive agreement or charge details.

The Cash Distribution Framework and the cash acceptance mandate are separate regulatory schemes, according to the ACCC. This consultation concerns distribution services and access to facilities; it should not be read as a new instruction about which payments a shop must accept.

For the broader payment picture, our card-surcharge guide covers the separate card-payment change. The Square and Stripe fee comparison explains why comparing the full payment arrangement matters. More announcements affecting business costs are in Rules & costs.

Checklist

• Read the ACCC consultation letter with the owner or bookkeeper. Identify which proposed pricing and service provisions affect the shop’s cash collection or delivery.
• Check the cash-service agreement and recent bills. Ask the provider which proposed pricing category would apply, using annual cash-in-transit services bought from Linfox Armaguard rather than shop turnover.
• Record the service and coverage the business needs. Compare those needs with the proposal’s postcode coverage, access and complaint arrangements.
• Prepare a specific consultation response for the owner to review. Separate the business’s current agreement and experience from changes it wants the ACCC to consider.
• Check confidentiality before submitting. Have the owner identify commercial details needing confidential treatment and substantiate any claim when submitting, because the ACCC intends to publish responses.
• Send the approved response to [email protected]. Undertaking responses close on 16 October 2026 at 4 pm AEDT, equivalent to 1 pm Perth; send views on interim directions as soon as possible.