ComCom Authorises New Zealand Banking Association To Collectively Negotiate With Armourguard

The Commerce Commission has issued its final determination to authorise, with conditions, the New Zealand Banking Association’s application for it and a group of banks and other parties, to collectively negotiate with Evergreen International LLC (Armourguard) over cash-in-transit (CIT) services.

The arrangements will give the participants the ability to collectively bargain for cash-in-transit services provided by Armourguard, engage in discussions and exchange information to support the collective bargaining, enter into collective and/or separate agreements and give effect to any provisions collectively negotiated, for a period of eleven years.

“We are of the view that the public benefits that collective negotiation could achieve in this case outweigh the potential detriments,” Commerce Commission Chair Dr John Small says.

“Collective bargaining would likely deliver more efficient contract terms and operational efficiencies. Although the public benefits in this case may not be quantifiable, we ultimately consider collective bargaining over these important services is in the public interest,” Dr Small says.

The Commission is aware that there could be some detriment relating to the risk of coordination between the banks.

“We have included requirements for legal oversight and information-sharing conditions with our authorisation to reduce these risks. This oversight will ensure the banks stick to the terms of the authorisation and avoid any coordination on matters outside of cash-in-transit,” Dr Small says.

The Commission’s position has developed since it declined Interim Authorisation in November 2025, due to concerns that interim authorisation could lead to uncertainty and potential deferred investments by Armourguard. However, with further assessment and evidence the Commission has concluded that the public benefits of authorisation outweigh the detriments.

A copy of the Commission’s determination is available on the case register.

Background

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

Cash-in-transit 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.

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. Armourguard is now the only New Zealand supplier of certain cash-in-transit services following its merger with ACM.

Authorisation requirements

The Commission may grant authorisation under section 58 of the Commerce Act 1986 (the Act) for agreements that may 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 or which contain a cartel provision can be authorised under section 58 of the Act, and our process for determining applications.

A copy of the guidelines can be found on the Commission’swebsite.

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