New Zealand Banking Association seeks authorisation to collectively negotiate ov…

CIT services include the transport, management and processing of bulk cash for banks, the public sector, financial institutions and retail customers, as well as the replenishment of ATMs and bulk cash storage and management.

CIT services are important for banks and retailers to manage their use of cash. In seeking authorisation, the NZBA asserts that the proposed collective negotiation will result in significant benefits, including improved sustainability of CIT services, reduced transaction costs, and enhanced financial inclusion and resilience. The NZBA also asserts that the proposed arrangement will not result in any public detriment.

The NZBA has also applied for interim authorisation of the proposed arrangement. This would allow participants in the proposed arrangement to collectively negotiate with Armourguard to extend current terms while the substantive application is under consideration, plan and prepare for collective negotiation, and commence negotiations (but not to enter any agreements).

The Commission invites parties who have an interest in the proposed arrangements to provide comments on the likely benefits and detriments of the proposed arrangements, including any likely competitive effects. Public submissions on the application can be sent by email to registrar@comcom.govt.nz with the reference ‘NZBA Cash In Transit’ in the subject line. Any submissions should be received by close of business on 6 October 2025.

The Commission will shortly publish a statement of preliminary issues relating to this application. The statement outlines the key issues that the Commission considers important in deciding whether or not to grant authorisation for the NZBA’s proposed arrangements.

The statutory deadline for making a determination on this authorisation is 25 March 2026.

A public version of the application for authorisation is available on the Commission’s case register.

Background

In 2024, the Commission cleared the acquisition by Evergreen NZ Holdings (trading as Armourguard) of ACM New Zealand Limited (trading as Linfox Armaguard), on the basis that it was very likely that one of Armourguard or Linfox Armaguard would cease to operate without the acquisition.  

The NZBA is an industry representative organisation that represents and advocates for the interests of the New Zealand banking industry.

About authorisations

Competition law recognises some agreements that lessen competition or contain cartel provisions may have public benefits that outweigh the detriments arising from the agreement.

In such cases, firms can voluntarily apply to the Commission for authorisation.

The Commission may grant authorisation under section 58 of the Commerce Act 1986 (the Act) for agreements that may otherwise breach the Act if it is satisfied that the agreement will in all the circumstances result, or be likely to result, in such a benefit to the public that the conduct should be permitted.

The Commission’s Authorisation Guidelines explain when anti-competitive agreements that may lessen competition will be authorised under section 58 of the Act, and our process for determining such authorisation applications. A copy of the guidelines can be found on the Commission’s website.