The Australian Payments Clearing Association is reviewing its ATM Access Code to see whether it is still fit for purpose.APCA wrote the voluntary code in 2009, as a complement to the Reserve Bank's ATM Access Regime.The RBA was concerned about the ability of new entrants to get into a system that was made up of a complex network of bilateral interchange arrangements with little clarity on pricing.The RBA put a cap on the access fees incumbents could charge new entrants and it introduced direct charging at ATMs.APCA's code gave "access seekers" rights to connect to the network and establish clearing and settlement arrangements with members.It imposed an obligation on members to engage in interchange activities, so that cardholders could make cash withdrawals and balance inquiries.Since 2009 there have been a lot of changes in the ATM market. Many of the old bilateral arrangements have been superseded by network hubs, such as the Eftpos hub launched in 2014. Visa and MasterCard have similar infrastructure.The RBA has encouraged the move to a more modern type of hub architecture.The code is not mandatory. Access seekers can and do establish agreements with access providers outside the code.Over the same period the industry has been moving to an EMV chip standard. Since January 1,Visa and MasterCard have mandated the use of EMV. APCA issuers and acquirers will follow suit in January next year.While cards and ATMs are EMV enabled, many of the network links are not. The ATM Access Code is silent on this issue.Another factor in the re-evaluation is the change in ATM usage since 2009. Consumer use of ATMs has fallen significantly. There are not so many "access seekers" clamouring to get into the market as there once were.