Free rider on the fintech train? – Revolut may be exempt from ATM installation obligations

Revolut would have to install 826 ATMs if it were a Hungarian bank

According to current regulations, financial institutions issuing bank cards are responsible for ensuring that every settlement with a population of over 2,000 has an ATM. In 2022, there were 775 such settlements in Hungary, of which 166 did not have an ATM. Based on the MNB decree, Hungarian banks have already started the development: 279 new ATMs were deployed by 2024, thus expanding the network by 5.7%, reaching 5,140 units.

Revolut – although it already has more than 2 million Hungarian customers – is not considered a Hungarian financial institution. It provides cross-border services as a bank registered in Lithuania, so it is not obliged to participate in the infrastructure construction. However, based on bank card issuances, if it were a Hungarian bank, it would have to install 826 ATMs, of which more than 500 would be in rural settlements.

The issue of fair competition

According to experts, this situation represents a serious competitive advantage for Revolut, which thus avoids the costs of ATM operation and installation, while serving the same customer segments as domestic banks. In addition, the banks also bear the transaction fee for free cash withdrawals twice a month – this is 1,350 forints for a cash withdrawal of 150,000 forints. This also means that the ATM network can only be profitable if at least 5,000–8,000 people use each machine regularly – this is not possible in smaller settlements, but the system still needs to be built there.