Access to Banking Services - A Consumer Perspective
This is the second article in our series on access to banking services, this time exploring the issue from a consumer advocacy perspective. If you missed the first article, you can access it here.
In this guest contribution, Citizens Advice Scotland outlines its concerns about the impact of declining in-person banking services, particularly for rural communities and those at risk of financial exclusion, and highlights areas it believes should be considered as part of the ongoing review of access to banking services. The views expressed are those of the author and organisation and do not necessarily represent the views of the Chartered Banker Institute.
Access to Banking Services: A Consumer Advocacy Perspective
In May 2026, the UK Government commissioned a review of access to banking services, recognising that whilst cash access is protected by legislation there are no existing protections for the provision of access to in-person banking services.
With dwindling physical banking infrastructure causing severe detriment, not only to individuals but equally to local communities and the wider economy, this independent review will seek to gather evidence on the impact of bank branch closures, understand who is most affected and what further action is needed to protect access to face-to-face banking.
Recommendations and a final report are due in October 2026. In preparation, Sir Richard Lloyd (the independent chair of the review) launched a Call for Evidence. Citizens Advice Scotland (CAS) responded to this important piece of work highlighting the systemic barriers and issues people accessing our network are experiencing when trying to bank in person.
CAS argued that there are multiple in-person banking services which remain essential, that extend beyond simply access to cash. Whether this is assistance to open a bank account, discuss other financial products and services, seek assistance with financial difficulties or even simply to pay bills and transfer money between different accounts.
Yet, when considering consumer needs and the use of in-person banking services, often the shift to online-only and digital by default solutions risk leaving those who are digitally excluded behind. Therefore, there is the belief that issues around access to banking services simply need to tackle digital exclusion and how these services can overcome the digital barrier, thus solving all banking issues. This is a false belief.
Many banking institutions affirm that the push to digital is because people prefer to bank online and physical footfall in branches has fallen. This is confirmation bias.
If digital is the only option being presented in terms of access to banking services, people have no other choice but to bank digitally. However, as demonstrated by many of our clients, some simply prefer to bank in branch but with ever-increasing closures, they are being forced to either switch to another bank or are having to figure out how to bank digitally.
Access to in-person banking services is particularly acute for rural communities where poor or limited connectivity can prevent these communities from participating in the digital and financial economy.
Whilst the issue of a lack of in-person banking services for rural communities is not exclusive to Scotland, there are specific factors, mainly the Scottish topography, which add a level of complexity that cannot be ignored or overlooked.
People in Scotland living in remote or rural areas can find digital access difficult due to lack of reliable broadband or mobile phone coverage. For people and communities who rely on cash, such as those on a low income, in ill health or with low digital capability, it can be even harder to cope with a lack of access to in-person banking or financial services.
Poor transport links can make it harder for people in rural areas to access branches for any banking service, not just access to cash. Often, they are unable to afford travel to their nearest bank because their public transport can have a high financial, resource and time cost.
When it comes to consumer harm and financial detriment, not having access to in-person banking can come at a significant cost for people, local communities and even the wider economy. One example of this cost is the inability to open or have access to a bank account. Many people struggle to open bank accounts because they do not have physical access to in-person services.
Virgin Money’s 2025 report on Tackling the Barriers to Financial and Digital Inclusion estimated that the annual costs of higher bills for those who do not have a bank account are an additional £645 million per year. That is the equivalent of an extra £598 per unbanked household per year. That is on top of any other premium they may have such as the Poverty Premium, the Mental Health Premium, Disability Price Tag or even the Rural Poverty Premium, all of which can come at a significant cost to the poorest in our society.
When it comes to tackling the rapid decline of bank branch closures and ensuring fair access to cash, the current solution is banking hubs. At CAS, we argue that these simply do not go far enough.
Whilst banking hubs should be an opportunity to keep people financially included, we found numerous limitations in how they are being implemented which means their impact and potential for good are also limited. This is also the case with other alternatives such as banking vans or deposit taking ATMs.
Many of our CABs (Citizen Advice Bureaux) reported having no contact with their local banking hubs so are unaware of what facilities are offered and what support can be provided to people in their area in trying to use them.
This is an extension of other issues reported by our network including limited staff, low staff knowledge and infrequent opening hours. But this isn’t the fault of community bankers who are often left trying to do their best in the worst of circumstances.
Many community bankers are often faced with questions beyond their own capability and in the past, as branch staff they would have had the local knowledge of where to refer people to for additional support. With branches now receding, these connections are lost and with banking hubs limited in terms of implementation, often the banking needs of local communities are overlooked.
It should be noted that “community banker” is a term not fully defined and as such it is unclear what responsibilities, key skills and required knowledge such a member of staff needs to have to fulfil their role. This is causing inconsistency and even leaving bank staff unable to support their clients, even when they desperately want to.
As stated, it is often rural areas who are most affected by the inadequacy of these so-called alternative solutions with many reporting community bankers only being available every second week, or only open during hours in which many people, particularly those who are working are unable to use. Again, it is not the individual staff who make these decisions but rather the institutions they work for.
It is worth noting that people and communities need access to in-person banking services but as long as it is left to CASH Access UK and LINK to determine where a hub is placed via a desktop evaluation that only considers access to cash needs, other banking needs will never be reflected and impact will always be limited.
There are several new developments that could potentially offer solutions to these abandoned communities including more collaboration between banking institutions and local communities.
This includes the development and design of more localised community hubs which can envelop multiple elements of financial inclusion from council and social services, library services, employability and Adult Education, health and much more. These Hubs would have the potential to become more than just about access to banking and cash but rather a hub of activity that embodies the diverse needs of local communities.
Since 2010, UK Government and the financial sector have taken strides to tackle financial inclusion but until there is a universal protection for access to banking, including in-person provisions as there is for access to cash, we will never truly overcome the barriers to financial inclusion.
However, if the current trajectory of reduced in-person access continues and alternatives such as banking hubs are not used to their full potential, the danger is clear. People and local communities, particularly those in rural areas will be completely cut off from banking and therefore risk becoming financially excluded. The cost of such is well-known and is not only significant to the individual but the wider economy and society. This is a risk none of us can afford.
Sarah-Jayne Dunn is Manager of Citizens Advice Scotland's Financial Health team. You can find out more about their work here: Citizens Advice Scotland