Increasingly, governments see cash access as a strategic necessity and essential legal right, as we discuss elsewhere. Meanwhile, new Bundeskriminalamt (BKA) reporting has refocused attention on ATM security, even though ATM attacks in Germany were down in 2025 compared to 2024.
These developments, coupled with the rising cost and complexity of regulation, have turned arguments about ATM Pooling from cost efficiency to a focus on maintaining secure, widespread access to cash. With the Euro Legal Tender Expert Group (ELTEG) recently confirming EU member states should monitor their own ATM Pooling, this blog examines how ATM Pooling is changing the business model – and how German banks should respond.
Making ATM Pooling work
Previously, ATM Pooling was seen as a means of improving the efficiency of cash delivery while maintaining visibility for bank branding via ATMs. However, the complexity of pooled ATM agreements led by a single bank became a deterrent. It can be hard to achieve consensus where one bank is perceived to be “in charge”, especially in a large market with diverse needs such as Germany.
Growing regulation adds more complexity, with Germany’s Girocard requiring not just its own rules, but its own hardware and software approval processes on top of regulations from Federal Authorities and the European Union. Meanwhile, the complex rules of any individual consortium cannot be ignored, either.
Banks want ATM Pooling to help them deliver broad-based, secure access to cash for all, ideally under their own brand. In our experience, the best way to deliver this is through an ATM Pool led by a bank-neutral player. The ATM network should be large enough to encourage banks to take part, with the bank-neutral leader responsible for managing relationships and negotiating any changes required to individual bank policies such as risk and security management or cash handling.
From Iceland to Amsterdam: ATM Pools in action
At Tieto Banktech, we have delivered the systems, solutions and infrastructure to enable successful ATM Pooling arrangements for leading banks across Europe. In Iceland, we led a consortium that modernised the country’s ATM network while reducing cost and maintaining access, even in rural areas. In the Netherlands, we rationalised ATM provision in Amsterdam such that the number of machines was reduced while access to cash remained unaffected.
Pooling will happen – time to prepare
As a first step, we recommend banks modernise existing ATM networks to make interoperability and networking with other banks easier. At Tieto Banktech, we offer a partner-agnostic solution with a flexible business model that requires minimal software and hardware investment thanks to MICOS, our continuously updated and modernised client interface software.
MICOS features in-built mechanisms for managing funding between banks, as well as accounting and reconciliation systems to ensure costs are distributed fairly, which is an important element in shared ATM infrastructures. As cost pressures continue and regulatory expectations continue to grow, ATM Pooling is a logical solution whose time is coming. Germany’s banks should prepare today to ensure they are ready for tomorrow.
