Agendas and Minutes of Payments System Board Meetings for 2024 Onwards
Dear Reserve Bank of Australia,
This is a Freedom of Information Request for the purposes of the Freedom of Information Act 1982.
I seek access to the agendas and minutes generated for the meetings of the following Payments System Board Meetings:
a. 29 February 2024
b. 23 May 2024
c. 15 August 2024
d. 21 November 2024
e. 6 March 2025
f. 5 June 2025
Please exclude duplicates and documents already publicly released,
including media releases, reports, articles and statements to the media.
Please limit emails to the final message in the chain as long as previous
messages are captured.
I agree to having the names and direct contact details of non-senior staff removed, however I request that redactions do not include non-personally identifying information. For example, please leave the domain and job titles when redacting email addresses or signature blocks on emails.
I preemptively agree to requests for third party consultation if necessary, but would prefer that my information about my identity is not shared with those consulted.’
Yours faithfully,
Glenn Hamiltonshire
Sent request to Reserve Bank of Australia again.
Dear Mr Hamiltonshire
In terms of the FOI Act 1982 I confirm receipt on Wednesday 6 August 2025 of your request below and advise that processing of it commenced on 7 August 2025.
Please be advised that, consistent with the provisions of the Information Publication Scheme, the Bank’s policy is to release all documents provided to applicants under the FOI Act 1982 on the Bank’s FOI disclosure log close to the same time they are provided to the applicant. The publication of any FOI related documents on our website will also be notified to the Bank’s RSS feed subscriber list.
We note your agreement to redact (in terms of section 22) the names and/or identifying material of junior officers (below Deputy Head of Department level) and further advise that for all our requests, we typically also redact email and phone contact details for senior staff from any documents designated for release in relation to your request. These intentions do not include position titles (except in very rare cases where release of a title would facilitate identification of a junior officer) but in any case, we doubt very many (if any) junior officer details will be captured.
Yours sincerely
Phil Lomas | Manager, FOI
RESERVE BANK OF AUSTRALIA | 8 Chifley Square, Sydney NSW 2000
p: +61 2 9551 9744 | e: [RBA request email] | w: www.rba.gov.au
Dear Mr Hamiltonshire, Glenn Hamiltonshire <[FOI #13460 email]>
I refer to your recent request seeking access to the agendas and minutes generated for the following Payments System Board meetings:
a. 29 February 2024
b. 23 May 2024
c. 15 August 2024
d. 21 November 2024
e. 6 March 2025
f. 5 June 2025
I advise that we have identified the 12 documents relevant to your request (one agenda and one set of minutes per meeting).
I have considered your request and have decided to deny access to the documents in terms of the following conditional exemptions within the Freedom of Information Act 1982 (Cth).
Section 47C(1) Public interest conditional exemptions — deliberative processes (in relation to the six sets of minutes)
General rule
(1) A document is conditionally exempt if its disclosure under this Act would disclose matter (deliberative matter) in the nature of, or relating to, opinion, advice or recommendation obtained, prepared or recorded, or consultation or deliberation that has taken place, in the course of, or for the purposes of, the deliberative processes involved in the functions of an agency or Minister or of the Government of the Commonwealth.
Exceptions
(2) Deliberative matter does not include either of the following:
(a) operational information (see section 8A);
(b) purely factual material.
Note: An agency must publish its operational information (see section 8).
(3) This section does not apply to any of the following:
(a) reports (including reports concerning the results of studies, surveys or tests) of scientific or technical experts, whether employed within an agency or not, including reports expressing the opinions of such experts on scientific or technical matters;
(b) reports of a body or organisation, prescribed by the regulations, that is established within an agency;
(c) the record of, or a formal statement of the reasons for, a final decision given in the exercise of a power or of an adjudicative function.
Denial of access under this part is appropriate because the minutes contain summary analysis and interpretations and assessments of relevant data and other information considered by the Payments Systems Board at each referenced meeting. The documents therefore constitute deliberative matter in terms of the Act.
As section 47C is a public interest conditional exemption, I am required to consider factors in favour of disclosure against whether access to the documents would, on balance, be contrary to the public interest (s11A(5)). In applying the public interest test, I have considered the public interest factors in favour of disclosure, being the factors set out in section 11B(3) of the FOI Act:
a. whether disclosure would promote the objects of the FOI Act (including whether disclosing the documents would increase public participation in RBA processes, with a view to promoting better-informed decision-making and/or increase scrutiny, discussion, comment and review of the RBA’s activities); in relation to this factor I have noted the characteristics and content of the documents and have formed the view that disclosure of the documents would not promote those objects, and in fact could reasonably be expected to have the opposite effect of curtailing the Board’s ability to access and consider information pertinent to its responsibilities. I further note that the Bank publishes updates of the meetings after each one that are consistent with our obligations to protect deliberative or sensitive matters from inappropriate disclosure. These updates satisfy the Bank's obligations to share information with the public as appropriate. The Right to Know website does not permit inclusion of links, so I cannot paste a link here, but if you visit the Bank's webpage and search for 'Payments System Board', then click on the first link that appears (currently dated 28 August 2025) at the bottom of that page you will locate a heading 'Related Information' and the first link under that heading "Payments System Board Meetings" will take you to those summaries;
b. whether disclosure would inform debate on a matter of public importance; for the same reasons as given in a. above, I have formed the view that disclosure of the documents would not inform debate on a matter of public importance, and also by reason that the Bank’s numerous public discussions and releases of information outline the Payments System Board’s thinking in relation to the matters it considers;
c. whether disclosure would promote effective oversight of public expenditure; given the nature and content of the documents, this factor is not relevant; and
d. whether disclosure would allow a person to access his or her own personal information; given the nature and content of the documents, this factor is also not relevant.
In this instance the factors in section 11B(3) of the FOI Act (as detailed above), when applied to the documents, do not favour disclosure, with the result that release of the documents would, on balance, be contrary to the public interest. I have therefore determined that release of the documents would not be in the public interest and deny access to them.
Section 47E(d) Public interest conditional exemptions—certain operations of agencies (in relation to both the six agendas and six sets of minutes)
A document is conditionally exempt if its disclosure under this Act would, or could reasonably be expected to, do any of the following:
(a) prejudice the effectiveness of procedures or methods for the conduct of tests, examinations or audits by an agency;
(b) prejudice the attainment of the objects of particular tests, examinations or audits conducted or to be conducted by an agency;
(c) have a substantial adverse effect on the management or assessment of personnel by the Commonwealth, by Norfolk Island or by an agency;
(d) have a substantial adverse effect on the proper and efficient conduct of the operations of an agency.
Denial of access under this part is appropriate because disclosure of the documents would, or could reasonably be expected to, have a substantial adverse effect on the proper and efficient conduct of the operations of the Bank (in this case, the operation and carrying out of the responsibilities of the Payments System Board). The documents detail the matters presented to the Payments System Board for their consideration and intended to take into account a wide range of available information. That information can be sensitive, and it also needs to be as full and frank as possible so that the Board is presented with the most complete picture available in relation to the matters it is considering and, that following their considerations, the considerations and actions recorded in the minutes are sufficiently detailed. It is my view that the ability of the Bank to appropriately record the considerations of the Board as fully and frankly as is necessary for the ongoing consideration of various matters would be curtailed by disclosure of these documents, with a resultant substantial adverse effect on the proper and efficient conduct of the operations of the Bank.
As section 47E(d) is a public interest conditional exemption, I am required to consider factors in favour of disclosure against whether access to the documents would, on balance, be contrary to the public interest (s11A(5)). In applying the public interest test, I have considered the public interest factors in favour of disclosure, being the factors set out in section 11B(3) of the FOI Act:
a. whether disclosure would promote the objects of the FOI Act (including whether disclosing the documents would increase public participation in RBA processes, with a view to promoting better-informed decision-making and/or increase scrutiny, discussion, comment and review of the RBA’s activities); in relation to this factor I have noted the characteristics and content of the documents and have formed the view that disclosure of the documents would not promote those objects, and in fact could reasonably be expected to have the opposite effect of curtailing the Board’s ability to access and consider information pertinent to its responsibilities. I further note that the Bank publishes updates of the meetings after each one that are consistent with our obligations to protect sensitive matters from inappropriate disclosure. These updates satisfy the Bank's obligations to share information with the public as appropriate. The Right to Know website does not permit inclusion of links, so I cannot paste a link here, but if you visit the Bank's webpage and search for 'Payments System Board', then click on the first link that appears (currently dated 28 August 2025) at the bottom of that page you will locate a heading 'Related Information' and the first link under that heading "Payments System Board Meetings" will take you to those summaries;
b. whether disclosure would inform debate on a matter of public importance; for the same reasons as given in a. above, I have formed the view that disclosure of the documents would not inform debate on a matter of public importance, and also by reason that the Bank’s numerous public discussions and releases of information outline the Payments System Board’s thinking in relation to the matters it considers;
c. whether disclosure would promote effective oversight of public expenditure; given the nature and content of the documents, this factor is not relevant; and
d. whether disclosure would allow a person to access his or her own personal information; given the nature and content of the documents, this factor is also not relevant.
In this instance the factors in section 11B(3) of the FOI Act (as detailed above), when applied to the documents, do not favour disclosure, with the result that release of the documents would, on balance, be contrary to the public interest. I have therefore determined that release of the documents would not be in the public interest and deny access to them.
Accordingly, in terms of the FOI Act 1982 Cht, I advise that I have decided to deny access to the documents relevant to your request. In terms of the FOI Act, I advise that you have rights to review of my decision if you are dissatisfied with it. You may apply as detailed below for review of my decision.
Internal review
Under section 54 of the FOI Act, you may apply in writing to the Reserve Bank of Australia for an internal review of my decision. The internal review application must be made within 30 days of the date of this email, and be lodged in one of the following ways:
email: [RBA request email]
post: Attn FOI Officer, SD, Reserve Bank of Australia, GPO Box 3947, Sydney NSW 2001
Where possible, please attach reasons why you believe review of the decision is necessary. The internal review will be carried out by another officer within 30 days.
Information Commissioner review
Under section 54L of the FOI Act, you may apply to the Australian Information Commissioner to review my decision. An application for review by the Information Commissioner must be made in writing within 60 days of the date of this email, and be lodged in one of the following ways:
online: https://forms.business.gov.au/smartforms...
email: [email address]
Yours sincerely
David Norman
Acting Secretary
e: [RBA request email] p: 02 9551 8111
Dear FOI,
I write to indicate that I seek an internal review of the decision to deny access uniformly to the requested documents, as per the previous email, to the ends of trying to have the 12 documents identified for the purposes of this request released.
Noting the previous email, I seek to challenge the original decision to consider the 'minutes' and 'agendas' of the Payment Systems Board (PSB) for the purposes of the FOI Act 1982. However, should my challenge fail on that grounds, I seek to assert that it would be in the public interest to release the minutes, at the very least, of the Minutes of the PSB to uphold the overarching objectives and principles of the FOI Act 1982, and that, at the very least, those should be released.
In relation to the question of deliberative processes, as per previous decisions reached by the Australian Information Commissioner, the deliberative processes exemption relied on by the RBA is far narrower than the exemption claimed. While the deliberative processes exemption (as provided by S47C(1), it is important to recognise that such exemptions have their limits within the act, including to 'factual materials' and other such details. I quote the FOI guidelines which discuss this clause as follows:
"The action of deliberating, in common understanding, involves the weighing up or evaluation of the competing arguments or considerations that may have a bearing upon one’s course of action. In short, the deliberative processes involved in the functions of an agency are its thinking processes – the processes of reflection, for example, upon the wisdom and expediency of a proposal, a particular decision or a course of action."
The problem with identifying parts of this request as part of the Deliberative Processes exemption, particularly the agenda, is that some of these documents, such as the agendas of the PSB is developed *before* the actual meetings of the PSB, which is to say, *before* the thinking and discursive process that such a meeting might entail. I understand and acknowledge that the minutes may very well within the S47C(1) definition of "deliberative" matters, but to claim that something produced prior to the deliberative process is part of the exemption is a stretch of the intent and purpose of the S47C(1) exemptions. As a result, I believe the agendas should not be exempt from FOI.
However, under the assumption that they may be exempt, I challenge that the release of these agendas and minutes clearly fall within the public interest.
The content of the requested document goes to a matter of considerable national interest – the functioning, operation, and continued oversight of payments systems within Australia. Already, public discussion and attention has been drawn to areas which impact businesses, consumers, and the general public at large, with the case of Merchant Card Payment Costs and Surcharges. Similarly, strong levels of public debate have been held over the question of cash's continued role in the payments system, how it is governed and overseen, and how financial regulators see the future of cash and cash delivery. This can be noted in the various articles and discussions that have been published regarding the ongoing role and situation of Armaguard as a cash in transit deliverer to the vast majority of cash reliant businesses and services.
Noting the earlier reply, highlighting that the RBA does attempt to provide a degree of transparency in this area for the PSB, notably though the publishing of updates of when the board meets (as can be found at this link here: https://www.rba.gov.au/payments-and-infr... Noting this however, this does not achieve the level of transparency and accountability that is within the public interest of RBA boards, and is unaligned with the approach the RBA takes with other board decision making, most notably, the decision of the Monetary Policy Board (MPB). While a short statement on Monetary Policy is released and a press conference is held at the same time, several weeks later, the minutes of the MPB meeting are released, revealing the details and thinking that went into reaching the monetary decision of the RBA. One can see the latest minutes of the MPB meeting here https://www.rba.gov.au/monetary-policy/r...
While this is, in part, a result of the Statement on the Conduct of Monetary Policy signed between the RBA and Treasurer, this principle of transparency through the meetings of the RBA's boards does is not, or rather, should not, be limited to monetary decisions.
To quote from the recent RBA Review: "Increasing transparency and inviting more external scrutiny and challenge will help the RBA to publicly demonstrate its accountability, improve its policy deliberations and be a source of ideas on how to improve the organisation".
I don't think I could have put it better myself.
As such, I believe that, even if these documents were exempt under deliberative processes (which I disagree with), then I content it is strongly within the Public Interest to release these 12 documents.
Yours sincerely,
Glenn Hamiltonshire