I849 - Italian Competition Authority closes investigation on Bancomat project


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According to the Authority, the new remuneration model would result in a restriction of competition to the detriment of consumers. In addition, the data acquired in the investigation shows that there is no direct relationship between the current remuneration model and the decrease in the number of ATMs (-13.9% between 2015 and 2021), which is instead linked to the reduction in the number of bank branches (-28.4% between 2015 and 2021)

The Italian Competition Authority has closed its investigation into a project aimed at modifying the remuneration model for ATM withdrawals from banks other than one’s own using Bancomat network cards. The project had been submitted by the Bancomat S.p.A. consortium.

Under the current remuneration system, the bank that issues the card used for the withdrawal pays an interchange fee (MIF) to the bank that owns the branch at which the withdrawal takes place and may charge its customer a fee. The project presented by Bancomat S.p.A. instead envisages a new model under which the bank where the withdrawal is made charges a fee (DAF) directly to the cardholder.

At the end of a detailed investigation, the Authority found that the new project would constitute a restriction of competition insofar as it would establish a set of common rules resulting in anti-competitive effects, with a significant increase in average withdrawal commission fees for users by the member banks; the Authority also said that the proposed change would create obstacles to competition between banks in the provision of services to customers, since they would no longer be able to influence a competitive variable (the possibility of setting the withdrawal fee and of not charging it to customers) and that it would incentivise member banks to collude.

Moreover, Bancomat did not provide evidence, individually and in detail, that each of the four conditions set out in Article 101.3, which could have led to an exemption, had been fulfilled. In particular, the network operator did not demonstrate that there was a direct relationship between the decrease in ATMs and the current remuneration model and therefore that the new model would result in increased efficiency.

On the basis of the elements that emerged during the investigation, the Authority found that the main causes of the downsizing of the ATM network lay in the market's overall evolution, which is marked by several factors.

These include the rationalisation of the network as a result of bank mergers, corporate decisions by credit institutions and optimisation strategies that may not depend on mere withdrawal from ATMs of member banks. For example, having too large a number of bank branches may not be efficient even in areas with a high volume of withdrawals (e.g. shopping or tourist areas). This circumstance is reflected in the data acquired in the course of the investigation, according to which - against a contraction in the network (between 2015 and 2021 the number of branches fell by 28.4% and the number of ATMs by 13.9%) - there was an increase in the number of ATMs per branch: in the 2015-2021 period the average number of ATMs per branch rose from 1.44 to 1.73 with an increase of more than 20% (Bank of Italy data).

The evidence on the absence of a link between the decrease in the number of ATMs and the remuneration model used is, moreover, consistent with the findings of the investigation by the other national competition authorities.

Rome, 5 December 2022