Department of Business and Trade Green Paper: Future of Post Office

2. For the Post Office network to be made up mostly of permanent and ‘full hours’ branches offering a wide range of services alongside a retail offering as these branches provide the most benefit to communities.

Agree.

We recognise the importance of permanent and ‘full hours’ Post Office branches which provide a wide range of services. Full time permanent branches are crucial in maintaining consumer access to postal and banking services. The Green Paper has noted that the Post Office is often the ‘last shop in the village’ providing vital community services. We welcome this recognition of the social and community value that the Post Office can provide for consumers. 

However, there are issues that require specific consideration for consumers in Scotland who live in rural areas. In particular, we would welcome the UK Government providing further clarification on any implications of the prioritisation of permanent and full-time branches for more rural areas where more targeted and frequently required services (mainly postal services and cash access) are provided locally. The provision of rural services may require different models that provide the most appropriate services for each area including outreach, limited automated services or outreach services. 

Whatever service approaches are adopted in future, the preferences, needs, and priorities of local consumers should play a central role in determining the nature of Post Office provision in their communities. More broadly, it is essential that any changes to network configuration does not result in any diminution of service to remote and rural consumers, where Post Office services are often vital. 

Rural and remote Post Office consumers

Across priorities and options consulted on, there are significant uncertainties that arise for rural and remote consumers from any potential changes. Due to the stage of consultation, it is unclear exactly what the risks will be to rural consumers.

Around 18% of Scotland’s total population is classified as living rurally in 2025 which equates to 930,000 people.[6] The geography is also different to the rest of the UK with a higher level of ‘remoteness’; 6% of people in Scotland live in ‘remote rural areas’, defined as being more than 30 minutes’ drive from a settlement with over 10,000 people. Remote areas include 94 inhabited Scottish islands – many of which require ferries or flights to reach.

These areas can be more reliant on Post Office access due to the more limited number of other services that can be easily accessed locally. Remote rural consumers are also more likely to be older, with correspondingly higher levels of digital exclusion and a greater reliance on physical postal and other service infrastructure.[7] Additionally, while the gap between urban and rural broadband provision is narrowing, there is still a lower availability of broadband (especially higher speed) and 4G services in rural areas which can increase reliance on physical infrastructure for all consumers in these areas.[8]

There is lower accessibility to certain key services via public transport within rural areas in Scotland with only 22% of the population in accessible rural and 29% of remote rural being within a 15-minute drive of a shopping centre by public transport.[9] In contrast, Post Offices are significantly more accessible via private vehicle for rural consumers in Scotland, with:

• 63% of those in remote rural areas being within a 15-minute drive to a Post Office by public transport.
• 68% of those in accessible rural areas being within a 15-minute drive to a Post Office by public transport (2022 data).[10]

Despite the relatively high level of access to Post Offices in rural areas compared to many other services, access to Post Offices in remote and rural Scotland is significantly lower than the rest of Scotland, where 96% of the population have access to a Post Office within 15 minutes by public transport. Additionally accessible rural areas have seen a 10% decrease in Post Office access between 2006 and 2020.[11]

Forthcoming Consumer Scotland research has also identified increased challenges for disabled consumers in rural areas in accessing services due to issues with public transport provision, which compounds accessibility issues for the Post Offices in some areas. The issues identified for disabled consumers in our forthcoming research include barriers to accessing public transport due to its physical inaccessibility, poor information, limited travel staff support or difficulty moving between stopping places. Access to transport underpinned nearly every challenge in accessing goods and services for disabled consumers in rural areas who took part in the research. We would wish to highlight therefore, that any changes which reduce locally provided services, including Post Offices, risk creating additional disadvantage for rural disabled consumers. 

Additionally, 16% of Post Office network are provided as part-time outreach branches (for example, a Post Office van travelling to a village for a few hours per week).[12] These models have grown by 87% since 2012.[13] Previous research by Citizens Advice has shown that these challenges can be significant and potentially lead to harm for consumers.[14] These harms include: increased amount of time to access services; people posting less, loss of community connection; health impacts; local business impacts; poor accessibility or reliability. However, consumers may have different preferences for how services are delivered – for example, they may prefer balancing further full-time services with restricted offerings that are delivered via different service models.

Consumer Scotland survey data: current time travelled:

• 60% of respondents reported that it takes up to 10 minutes to travel to the Post Office branch that they use the most.
• For 25% of respondents, it takes between 11-20 minutes to reach the Post Office branch they use the most.
• 9% reported that travelling to the Post Office branch they use the most takes between 21-30 minutes.
• Those living in rural areas (46%) are statistically significantly more likely to say it takes over 10 minutes to get to their most used Post Office branch, compared to those in urban areas (34%)

Consumer Scotland published qualitative research in June 2025 exploring low-income rural consumers experience of postal services. While the research primarily focused on the proposed changes to the Universal Service Obligation for letters, the research also highlighted a range of consumer perspectives on rural post office provision. These are illustrated by some of the quotes from research participants, provided below:

These quotes from our research are provided to illustrate Post Office access in rural areas.

Resident of very remote rural area, 19, said: "So we live in a village just outside of the main town [in an island area] which means I have to get a lift to town to post things… As a wheelchair user, we've not got fully accessible transport in Shetland yet. So, I have to take a car ride up to [the main town] in order to send something special delivery. So that adds to the cost further for fuel.”

Resident of remote rural area, 28, said: "In terms of like the economy, there's a lot of good jobs that keep people in a local area through the Post Office. So, I wouldn't want to... to see them go."

Resident of remote rural area, 73, said: I mean, I'm lucky, I've got [a post office] one 12 and a half miles away. Some people who I know haven't got a post office for 50 miles. We’ve already had all our banks closed and once post offices go, we'll have nowhere to bank our money or anything… I'm fairly happy with the affordability, but it's accessibility to people who are not as mobile or as well off as I am.”

Within this qualitative research a number of consumers reported the closure of their local Post Office which resulted in greater travel and greater cost to access what they need.[15] 

In this context, it is important to examine whether alternative options are available to consumers, particularly in rural and remote areas, if they do not have easy access to a Post Office.

82% of respondents stated that it was important or very important that the Post Office was nearby and convenient.

After convenience and nearness, the most important aspects were that it provided a range of services (79%) and was available when you need it, even if you rarely use it (79%).

Some aspects of the Post Office were more important for rural respondents than their urban counterparts.

87% of rural respondents reported it was important the Post Office was available when you need it, even if you rarely use it, whereas it was 77% for urban respondents.

It was more important to rural respondents (75%) that the Post Office provide services which other providers cannot or will not provide. This was important to 65% of urban respondents. 

Although the Post Office as a hub for the local community was the least important across all respondents (rated as important by around half of respondents); almost two-thirds (63%) of remote rural consumers reported that it was important, vs 47% of urban respondents.

Consumer Scotland’s research on Post Offices found that for a number of consumers there is a lack of alternative services if Post Office is not available:

• One in five (23%) people reported that there were no alternatives to at least one of the services they used at the Post Office
• This was higher for consumers in rural areas, with 28% reporting not having alternatives
• Over a quarter of disabled people or those with a health condition (26-30%) reported a lack of alternatives for at least one services
• 3 in 10 (29%) of those earning under £19,999 reported a lack of alternative for at least one service

Around a third of respondents said that there are convenient alternatives to the Post Office for the service they use. This was generally lower for government services (25%), and higher for non-post-related services:

• 41% for foreign currency exchange
• 42% for withdrawing cash
• 63% for other services

Another third of respondents said that there are inconvenient alternatives to access the service, for example 38-40% of those who send or collect parcels.

Around 10% of consumers said that there are costly alternatives to the service. For example, 8% reported this for stamps and postage, 12% for government services, and 14% for foreign currency exchange.

And another almost 10% of users reported that there were no alternatives, ranging from 8% (for collecting parcels), to 15% (for accessing government services) of users.

Consumer Scotland’s consideration of the policy objective for permanent and full hours branches is that it is likely to better meet the needs of the majority of the population. However, it is important to note from our testing of different scenarios (outlined on page 26-27) that many consumers preferred postal and banking services to be closer to their location which may require additional provision using a range of service models, in situations where full time, permanent Post Offices are not feasible or available.

As noted in our evidence set out above, any closure or reductions in Post Office service for rural and remote consumers in Scotland would risk significantly restricting access to essential services such as cash and postal services, exacerbating the existing challenges that many consumers in these areas experience. We would welcome further assurance and detail from the Government on the following points:

• That Post Office provision in rural and remote communities will remain a key priority and will be sufficient to meet consumer needs
• That there is a clear strategy to ensure that an objective for full-time, permanent branches aligns with commercial realities in rural and remote locations and that there is no diminution in rural and remote provision resulting from this objective
• That the objective of full time, permanent branches will be achieved without compromising the existing access criteria
  

Post Office’s work on the social and economic value of the Post Office highlights the role that branches play in unlocking further economic value for the UK. This work also demonstrates the importance of the Post Office for supporting remote and rural economies in Scotland. The Post Office generated an average of £53 of economic impact per person which was considerably higher for the rural and remote areas of Scotland with more than £100 per person generated in the Highland region, £80-100 in North Scotland, Orkney and Shetland, and in Argyll and Bute.[16]

Given the range of evidence presented above, it can be concluded that the Post Office plays very significant and specific role in rural and remote communities. The range of potential future directions for Post Office outlined in the paper creates uncertainty for the sustainable provision of Post Office. These include prioritisation of full time and permanent post offices; changes to access criteria; changes to postcode access criteria; what counts as a post office and moves to a more commercial model.

On this basis, Consumer Scotland recommends that in taking forward the Green Paper, the Government should considered developing a targeted Rural Strategy for Post Office which assesses the impact of all decisions on rural areas and rural consumer access and outlines a plan for providing sufficient and appropriate provision of Post Office for rural areas.

3.      To support high streets, acting as a stimulant and visible sign of incremental economic activity

Agree.

Consumer Scotland agrees with the priority of recognising the importance of the high street as a locus of economic and social activity, which should deliver a range of services and products for consumers. While consumer needs for retail and services have diversified, the high street still plays an important social and economic role. This includes small businesses who play a vital role in serving local communities and as consumers themselves of local businesses.[17]

We recognise that the Post Office has estimated that consumer spending in nearby outlets when visiting a post office branch amounts to as much as £3.1 billion a year and, as such, the Post Office can offer a consumer ‘anchor’ in the local high street.[18] Consumer Scotland acknowledges that this stimulates the local economy and can help small businesses based on and around the high street. In addition, Market Financial Solutions research into consumer preferences for a post-pandemic high street found that 91% of those surveyed said that the Post Office was an essential/important service for any high street - the highest score attributed to any high street establishment in the study.[19]

4.      For Post Office to be an organisation with a positive culture, that is run in an accountable and transparent way, and delivers benefits for and represents the interests of postmasters, partners, their customers, employees and communities.

Strongly agree.

Representing the consumer voice in Post Office governance 

It is crucial that the future of the Post Office includes a strong representation of the consumer voice within its governance or accountability arrangements, to ensures the Post Office works for consumers now and in future. 

The Principles of Community Engagement remain an important mechanism for ensuring sufficient community engagement when there are changes to the Post Office. Consumer bodies play an oversight role in monitoring these changes and whether Post Office have followed the Principles of Community Engagement. 

In taking forward the Green Paper, Consumer Scotland recommends that the Government considers how the consumer voice can play an enhanced role in helping to shape the future of Post Office service delivery. The postal sector will see widespread transformation in the coming years as the market evolves to shifting consumer needs and priorities. 

These changes are likely to include:

• Decarbonisation of the postal sector
• Further reduction in letters volumes, which impacts disproportionately on those consumers still heavily reliant on post, including those in vulnerable circumstances
• Further increase in the importance of parcels market – with an increasing role of parcels lockers and drop and collect services for accessing e-commerce
• Further reductions in the provision of wider physical infrastructure services in local communities, such as access to banking facilities and cash access points, which may place greater emphasis on the need for consumers to access such services through the Post Office

In order to maximise potential benefits for consumers during these changes, and mitigate the risks, it is critical that consumer interests are sufficiently represented in policy and regulatory decision-making processes across all areas of the postal sector. For Post Offices, consumer bodies have an important role in promoting a positive accountable and transparent culture that understands and recognises the diverse range of consumer needs and provides a high-quality service for consumers and communities. The ongoing and meaningful engagement of consumer bodies will be vital to helping to achieve these goals. 

Consumer Scotland, alongside Citizens Advice and Consumer Council for Northern Ireland, has a statutory remit to represent consumer interests in postal services. We also undertake policy and advocacy work on other sectors that are relevant to Post Office service provision, including utility markets, financial services, and government services. 

In taking forward the Green Paper, Consumer Scotland recommends that the Government considers how the role of consumer representation bodies might be further strengthened within Post Office governance and accountability arrangements to ensure consumer interests – especially those of vulnerable groups – have a central role in shaping any future reform. 

There are a range of examples from other markets that provide examples of how the consumer voice can be embedded within governance or accountability arrangements: 

• Consumer panels – provide insight from an appointed panel of consumer experts. An example is the Communications Consumer Panel
• Customer groups – provide direct insight from consumers about key issues to inform governance. Examples include the Customer Engagement Groups used for price setting in energy (RIIO) and water (in Scotland – Strategic Review of Charges)
• Statutory advocates – levies are used as charges on bills to fund a consumer representation function such as those seen for the wider postal sector, gas and electricity markets, water, and heat networks
• A dedicated programme of customer research – to track and inform governance and accountability through research on consumer priorities and experiences of the Post Office

A holistic approach to the postal sector 

The postal sector includes letters, parcel services and Post Offices which are all interdependent, in different ways, on each other. The UK has an unusual model of postal services – with a division between the distribution of postal services via private operators and a publicly owned Post Office. This can present risks for consumers that different aspects of the postal sector may be considered in distinct siloes, with no clear route to assessing and prioritising the overall consumer experience. 

Post Office’s response to Ofcom’s consultation Phase 1 Reform of Universal Service Obligation for postal services highlights the importance of joined up and strategic consideration across the postal sector.[20] 

We also note that Consumer Scotland’s research with consumers, along with research from other consumer bodies, highlights that consumers do not always understand the difference between Post Office and Royal Mail – often seeing them as the same publicly-owned company or Royal Mail as a publicly owned company. [21] [22]

The financial sustainability of the Post Office is important to ensuring consumer access to a range of essential services, as evidenced in this response. However, changes within the broader postal sector, which could impact the revenue that post office branches generate through the supply of postal products, may have implications for the provision of these wider services to consumers. For example, declining letter volumes may impact on Post Office revenue from the sale of stamps, while increasing volumes of parcels through diverse carriers provides opportunities for Post Office engagement with wider parts of the parcel sector. At the same time, an increase in the provision of drop and collect services by private parcels operators may reduce demand for these services through Post Office. 

Our research demonstrates that at present, one of the primary reasons that consumers visit Post Office is to use postal services. As such, the future of the Post Office is closely linked to its role in the provision of services across the broader postal sector – including both USO and non-USO products. 

In that regard, we note that there have been a number of important recent developments within broader postal markets that may impact on the consumer experience of Post Office services. These include:

• Changes to the Universal Service Obligation for letters, including a shift to an alternating day model for second class post and reductions in Quality of Service targets, all of which could have implications for Post Office branches’ commercial viability. Post offices are reliant on the sale of mail services. The Post Office response to the future of the USO consultation outlined concerns about the impact of USO reforms on Post Office business and consumer need and the affordability of postal products having an impact on both. Post Office concluded both consumers and industry would be disproportionately impacted by the USO reform.[23]
• Royal Mail’s recent announcement of a high street presence selling and returning parcels and postage at Collect+ points - which could reduce consumer demand for purchasing, dropping off and picking up at Post Office branches, with potential implications for the financial sustainability of some branches and therefore potential risk to the wider set of consumer services that such branches might offer.[24]
• The rollout of ‘post boxes of the future’ which are able to receive parcels which may reduce the need for consumers to use Post Offices services for some parcel services.[25] This may bring some consumer benefits in terms of efficiency and choice, but as above, may pose risks to the viability of the wider range of services that consumers currently access through post offices.

Given this context, Consumer Scotland recommends that in taking forward the Green Paper, the Government considers how to achieve its goals for the Post Office within a more strategic and joined up vision for the future of postal services more broadly. A strategic sector vision can help to deliver the best possible consumer outcomes across the various components of the system and ensure that the postal sector is able to make the most effective contribution possible to wider policy goals, such as delivering sustained economic growth. 

5.      For Post Office to become an organisation that adapts to changing markets with lower reliance on government funding.

Disagree

Consumer Scotland recognises the need for the Post Office to evolve if it is to effectively meet consumer needs in a more digital and competitive market environment. However, we are concerned that a reduction in government funding at this stage could risk disproportionately negative impacts for consumers in vulnerable circumstances, including those on low incomes, in rural areas, and those who are digitally excluded.

The Post Office plays a critical role beyond mail delivery. It is a trusted access point for essential services such as cash and banking, bill payments, and government and identity services. These functions are particularly important for consumers who face barriers to digital access or who rely on in-person support.

Additionally, it is not clear what the implications of a reduction in government funding would be for the ability of the Post Office network to maintaining its adherence to the existing access criteria (regardless of whether to maintain the 11,500 branches requirement). Post Office is fulfilling a public service which may not always be commercially viable in all communities Therefore, there is a need for clarity on how this priority can be delivered without negatively impacting on the access criteria. 

Given the proposals discussed below regarding banking hubs and drop and collect, some of this tension may be resolved through a reconsideration of ‘what counts as a Post Office’ which is outlined within the Green Paper. Part of the future of the Post Office may be to consider what the minimum threshold of service delivery is needed for a recognised Post Office to deliver. 

In addition to provision of essential services, the Post Office network also provides benefit for consumers through helping to address social and financial exclusion.[26] According to research from the National Federation of Sub-Postmasters, based on a survey of 500 sub-postmasters, Post Offices may act as an informal support mechanism for around 300,000 vulnerable people across the UK.[27] This includes supporting the prevention of scams and offering general support to consumers who need help. 

We recommend that key areas for consideration as the Government takes forward this objective should include:

1.      How to continue to support and protect less commercially successful branches (particularly those in remote and rural areas) which provide important social and economic benefits and access to a range of essential services for consumers.

2.      How to ensure the needs of consumers in vulnerable circumstances, who have greater reliance on the Post Office, continue to be met following any changes to the arrangements for how the Post Office is funded. 

Additional comments:

Consumer Scotland encourages the Government to achieve a balanced approach when taking forward the Green Paper, to support innovation, improved consumer outcomes and financial sustainability while preserving the Post Office’s vital role in the provision of essential services and delivering wider benefits to consumers. 

In this context, we recommend an additional strategic priority which centres on delivering a modern Post Office with relevant consumer offerings and a high-quality consumer experience. 

We recommend the addition of a new strategic priority that explicitly focuses on delivering relevant, accessible, and high-quality services that meet the evolving needs of consumers. The addition of this priority would place the consumer experience at the heart of Post Office reform, ensuring that services are not only fit for purpose but also delivered with consistency and provide an excellent consumer experience. 

A strategic focus on consumer outcomes could help to:

• Reinforce consumer trust and confidence in the Post Office as a vital community service
• Drive improvements in service design and delivery based on consumer feedback and defined customer experience metrics
• Ensure that digital and in-person channels are inclusive, responsive to changing consumer need and aligned with consumer expectations
• Support frontline staff with the tools and training needed to provide outstanding customer care

Embedding this priority within the strategic framework will help ensure that consumer needs are not only acknowledged but actively shape the future of the Post Office.

Summary of key points from question 1-6

1.      Consumer Scotland fully support government priorities that Post Offices should continue to provide postal and critical services. It is in the consumer interest to ensure that any policy costs are appropriately funded.

2.      Further clarification and assurance is required on any implications for remote and rural services in Scotland, which emerge as a result of the prioritisation of full time and permanent Post Office branches. The interests of consumers in remote and rural communities, where it may be less commercially viable to provide full time services, must be protected. In particular, more clarity is required about how the goal of full hours and permanent branches would be met under the existing access criteria. 

3.      The UK Government should develop a Rural Post Office Strategy to safeguard access in rural communities and ensure that outreach and alternative service models are adequately resourced.

4.      It is crucial that the consumer voice is included in future Post Office governance and accountability mechanisms. The Post Office delivers for consumers, and it is vital that future provision has the right systems in place to ensure that it understands and is responsive to consumer needs. 

5.      The postal sector in the UK is fragmented in how it is structured, but interdependent in its operation. A holistic vision for the postal sector can help to maximise the delivery of positive consumer outcomes and help to tackle any potential consumer harm. 

6.      Post Office remains a key offline provider of vital services for many consumers. Therefore, it is integral that there is appropriate funding for the delivery of these services, particularly in those areas where a commercial post office operation may not be viable, otherwise there is a risk of considerable consumer detriment. 

7.      Recognising that the core function of the Post Office is to deliver for consumers, we recommend an additional strategic priority which centres on delivering a modern Post Office with relevant consumer offerings and a high-quality consumer experiences.

Question 7: Do you agree with this assessment of how Post Office’s role in postal services, cash and banking services, and government services will change over the next 5 to 10 years?

Consumer Scotland agrees that the Post Office’s role will continue to evolve over the next decade, and that its relevance will remain important across postal, financial, and civic services, particularly for consumers in vulnerable circumstances. There remains a need for Government to enable access to essential public, financial and postal services in a physical setting that can be accessed by digitally excluded consumers. Post Offices are a vital part of this landscape.[28] Digital exclusion, uneven internet rollout in Scotland, and demographic shifts in rural areas mean that the Post Office is particularly important as a service provider for consumers in these communities.

Younger people and Post Office use 

Consumer Scotland’s survey data highlighted high usage of Post Office by younger people. Our research showed that for monthly Post Office use:

• the leading group are 18–24-year-olds, with 70% of them using a service at the Post Office at least once a month in the last year
• 60% of 25–34-year-olds and 51% of 75+ year olds reported using the Post Office monthly
• These age groups were generally frequent users of the Post Office, for financial and administrative services as well as postal services

The relatively high level of use by younger people of Post Office shows that Post Office remains relevant to the younger generation. Ensuring that the Post Office meets younger people’s needs and responds to thee appropriately is important to ensuring the future of the Post Office. 

1.      Postal Services:

We anticipate that the Post Office will remain a key access point for postal services, especially as consumer preferences shift toward more flexible delivery and collection options. 

A strategic and holistic approach to the postal sector 

As noted above, it is crucial that there is a plan for long-term, joined up thinking about the interaction between the Post Office and other parts of the postal system. There are significant interdependencies between Post Office and the letters and parcels markets, and the financial sustainability of the Post Office will require it to continue playing a key role in the wider postal infrastructure. From a consumer perspective, the ongoing role of the Post Office in this regard is important not only in terms of providing access to mail products, but also to ensure that consumers have continued physical access to other essential services.

Parcel lockers 

These types of services play an important role in the postal infrastructure of a digital age which increasingly provides more flexibility, choice, and convenience for consumers. Recent research by InPost locker delivery service and Retail economics showed the more than half of UK consumers used parcel lockers – rising to 71% for 18-28 year olds and 68% for 29-44 year olds.[29] Therefore, Post Office’s ability to adapt to changing trends in the postal sector is vital to ensuring its ongoing value, particularly for younger consumers. There may be a role for the Post Office in expanding to parcel locker provision – particularly if they are multi-carrier lockers. However, these services need to be balanced with the wider benefits of other services (i.e., banking, bill payment and wider postal products) when making strategic decisions about local service offerings.

Diversifying consumer choice in parcel offering

Consumer Scotland supports the vision of the Post Office as a convenient hub for a wide range of postal services across different parcel carriers. Consumer choice is a key principle for good consumer outcomes and the Post Office being able to engage with the parcel market as a whole can help to enable this, while also supporting the broader government objective of developing the financial sustainability and independence of Post Office. 

2.      Cash and banking services.

Consumer Scotland welcomes the government’s ongoing commitment to ensuring cash remains a viable payment method for consumers. Access to cash remains essential for many consumers with approximately 1 in 10 (500,000 Scottish consumers) depending on cash access.[30] Despite the overall decline in cash usage, over 3 million people in the UK still rely heavily on cash, including older adults, low-income households, and those in rural areas.

Research from Age UK shows that 4 in 10 older people with a bank account do not manage money online, and 75% want to carry out at least one banking task in person.[31] Meanwhile, Scotland’s geography presents distinct barriers to accessing essential services for some consumers. With a higher proportion of remote, rural, and island communities than the rest of the UK, the impact of bank branch closures and reductions in cash access services can be disproportionately severe. In some areas, accessing alternative sources of cash may require ferry travel or access to a private vehicle.

Scotland has experienced the highest rate of bank branch closures in the UK in recent years: a 53% reduction between 2015 and 2022.[32] Consumers have also endured a 20% decline in the provision of free-to-use ATMs since 2018.[33] These closures have significantly reduced the availability of cash withdrawal services, particularly in communities where digital alternatives are not viable. 

In this context, the Post Office has a particularly important role in ensuring access to banking and cash services for consumers, particularly in remote and rural areas and in locations affected by bank branch closures. We fully support the government’s priority related to financial services.

Consumer Scotland research on access to financial services 

In our survey data, 41% of all respondents had withdrawn cash from the Post Office in the last year.

Some groups were more likely to have accessed banking and financial services from the Post Office:

• 58% of 25–34-year-olds and 57% of 18–24-year-olds reported that they had used the Post Office to withdraw cash in the last year
• For withdrawing cash, 50% of disabled people (limited a little), and 47% of disabled people (limited a lot), had done so, compared to 37% of non-disabled people
• 71% of rural respondents accessed the post office for any financial and administrative services in the last year, compared to 61% of urban respondents
  

Given this data, while we recognise the evolving role of the Post Office, we recommend that the role of the Post Office as a reliable and accessible provider of cash and banking services, especially in areas where wider market provision has declined, should remain a key focus for the network during the coming decade.

3.      Government services

Consumer Scotland recognises the Post Office’s critical role in enabling access to government services, particularly for consumers who are digitally excluded or living in rural areas. We recognise the Government’s ongoing ambition that Post Office is the ‘front office of government.’ However, it is crucial that Post Office is properly resourced to fulfil this function with clear understanding of the public benefit that can result in enabling physical access to Government services.

Consumer Scotland research on government services

In our survey, 63% of respondents reported they had used post offices at least once in the last year for financial or administrative services, including accessing government services.

Of those surveyed who had used the Post Office for government services, 18% had used them at least monthly (including 8% weekly).

Younger consumers are the group of consumers who are most likely to access government services at the Post Office:

• 52% of 18–24-year-olds had done so in last year
• 54% of 25–34-year-olds had done so in last year

Those with an income of £60,000+ are also common users, with 45% doing so at least once in the last year.

The Post Office provides a trusted and secure environment for accessing identity verification services, such as passport applications and driving licence renewals, essential consumer services that can often require in-person support, particularly for consumers in vulnerable circumstances.

Consumer Scotland also recognises the challenges of lack of standardisation of government service provision and funding across Post Offices. This can create uncertainty for consumers in accessing and relying on Post Office for the provision of these services. In developing the future strategy for the Post Office, we recommend that the Government examines what action can be taken to improve the predictability and consistency of government service delivery across the post office network. There is also a need to ensure that consumers are provided with clear, targeted information about the availability of these services through post offices.

Key points from question 7

 1.      Consumer Scotland partially agree with the assessment of Post Office’s role in the indicated services over the next 5-10 years.

2.      There remains a vital need for Government to ensure access to essential public, financial and postal services through Post Offices.

3.      Our research suggests a relatively high level of usage of Post Office among younger people; therefore, consideration of how to continue to make Post Office relevant for younger people is vital to the future of the network.

4.      Diversifying and adapting parcel offerings presents an important opportunity for the Post Office to respond to changing consumer needs.

5.      There remains an important role for Post Office in provision of access to cash and banking services. Scotland has seen a significant decline in bank branches and cash machines and Post Office is a vital mechanism in continued provision.

6.      Post Office plays a critical role in enabling access to government services – especially for those consumers who are offline or rural. We recognise the ambition for Post Office to be the front office of Government, but action is required for this to be delivered as effectively as possible for consumers.

Question 9: Which of the following policy options for what a future Post Office network could look like do you prefer:

Maintain existing requirements for access criteria and 11,500 branch minimum.

Question 10: Please explain your preference.

Consumer Scotland’s analysis of each policy option, alongside the survey data we collected, supports the case for maintaining existing access requirements both in terms of postcode access requirements and maintaining 11,500 minimum branches. 

Consumer Scotland’s objective in this analysis is that all consumers have access to fair and equitable Post Office services. This means that there is regard to how services may be delivered to consumers where access to full time and permanent branches is not feasible or sustainable. Additionally, it may mean considering what services consumers see as essential to have within a local area and which services they are willing to travel further to access. 

Consumer Scotland research on Post Office preferences

Consumer Scotland’s survey explored consumers’ preferences on the future structure of the post office network: 66% of respondents preferred to access a Post Office branch which is close to their home or work but provides more automated services.

34% of respondents preferred access to a Post Office branch which provides more face-to-face support and advice but is further away.

However, preferences varied by demographics:

Younger people generally preferred a closer, more automated Post Office (70-78% of those age 18-54 compared with 47-58% of older age groups over 55). 

Older people (age over 55) were more likely to prefer a Post Office that was further away with more face-to-face advice and support. 

Those on lower incomes were more likely to prefer a Post Office that was further away but with more face-to-face services. 

There were no meaningful differences in preferences between rural, remote rural or urban consumers; and for all, the majority preferred closer but more automated Post Offices.

Question 11: If you have any alternative suggestions for how the network requirements should change, please set them out.

Based on the above analysis, Consumer Scotland supports option 1: maintaining existing requirements. This option would ensure that there is a still a robust network access criteria in place for all consumers. Additionally, we have identified that there is a need to ensure tailored access to rural areas, which may be enabled through the development of a specific Rural Strategy for Post Offices, focused on assessing the impact of any changes and ensuring ongoing sufficient provision of essential services to rural areas. 

A Rural strategy for Post Office 

There are number of components which we recommend any future Rural Strategy for Post Offices would need to consider:

1.      Funding for rural Post Offices

A dedicated Rural Post Office Strategy could consider how existing funding can be best used and targeted to help to improve the long-term viability of the rural post office network. Most effective use of funding could be considered in conjunction with action to support rural Post Offices to diversify to become more commercially viable.

2.      Minimum required service provision

A rural strategy would consider what the minimum required service provision is needed for rural areas. These may differ or be place-based. Consumer Scotland research suggests that there is a minimum requirement for postal, banking and bill payment services provided close to consumers while they are more willing to travel for less frequently used services.

For areas where a full time and permanent Post Office is not viable, then there is a need to identify what would be a minimum viable service that consumers need close to their location such as postal services, banking, and bill payment. Additionally, consideration of consumer needs around delivery methods (i.e., mobile services or home delivery) and requirements around frequency of opening hours and reliability need to be robustly assessed. 

In assessing what is needed for each area: 

Minimum required services (postal, banking and bills).

Minimum customer services standards (opening hours, frequency, reliability, accessibility).

Access to alternatives in local area.

Consumer needs assessment: evaluation of local demand and accessibility.

Most viable delivery model: Post Office, outreach, hosted or mobile services.

The table below outlines areas that may need consideration for rural service provision: 

Further research and community engagement may be needed to identify what delivery models would work best for consumers in remote and low-density areas. Consumer Scotland is currently undertaking research on postal services in island communities which may provide additional insight into place-based and bespoke solutions for postal services. We will be pleased to provide a copy of our research report to the Government when it is available.

Key points on response to question 11

1.      Our analysis and research have led us to conclude the best option is to maintain the existing requirement for access criteria and 11,500 branch minimum.

2.      Where full-time, permanent Post Office branches are not viable, it may be that there is a need to determine what is a minimum viable Post Office with the services that meet consumer needs. This may mean smaller ‘hubs’ which meet consumer needs around location and services (for example, stamp products, PUDO and banking hubs only).

3.      Consumers generally prefer to have services close to their home in a more automated way but may be willing to travel further for less frequently required services (such as government services). However, there is some demographic preferences – and older people preferred a Post Office that is further away with more face-to-face support.

4.      Provision of local automated service could be complemented by access to services at a greater distance with more support to ensure consumer needs are met.

5.      One of the biggest risks to any changes to access criteria and/or minimum branch requirements is to rural Post Offices. Therefore, we recommend that Government consider a rural Post Office strategy to consider how to assess any changes and how to meet the different needs of rural communities. We have outlined what the strategy could contain.

Question 12: Introduce customer service targets.

Strongly Agree 

Consumer Scotland would strongly support the introduction of customer service targets. We recommend that consumer bodies, including Citizens Advice, Consumer Council for NI and Consumer Scotland should have an active role in helping to determine what these standards should include. In line with regulatory approaches in other sectors, consideration should be given to the respective merits of a principles-based approach to standards, focussed on outcomes, and a prescriptive approach which focusses on a more fixed set of performance measures. 

Fixed and prescriptive measures can risk creating negative unintended consequences. For example, in the energy sector, some prescriptive performance measures have meant suppliers have been able to ‘game’ the system such as through time-based call answering times which result in call operators putting down the phone to prevent long call wait times. The customer service measures did not include due sufficient requirements to capture voided calls or repeat calls, which could have prevented such problems.[34] There are examples in other sectors of prescriptive approaches being balanced alongside more outcomes-based ethical regulation models. Examples of these include the implementation of ethical business regulation in the Scottish water industry or the Financial Conduct Authority’s implementation of the Consumer Duty.[35]

For post offices, issues which could be considered for customer service ratings may include:

• Waiting times
• Accessibility
• Customer service
• Customer reviews

As part of a future customer service approach, collecting demographic information, where possible, would also allow Post Office and/or UK Government to understand whether different consumer groups are experiencing positive outcomes in their use of post offices. This type of data collection could also enable Post Office to identify whether there are any systemic or structural issues faced by certain types of consumers. Additionally, providing Consumer Scotland, and the other statutory consumer advocates, with access to aggregated data, via strict data sharing agreements, would inform consumer advocacy activity, which may support further improvements in service provision.

Key points from question 12:

1.      Consumer Scotland strongly supports the introduction of customer service targets. Consumer bodies are well positioned to provide input into the development of these targets.

2.      Consideration should be given to the appropriate balance between rules-based and outcomes-based customer measures.

3.      Additional demographic information may be able to identify if there are systemic customer service issues faced by certain groups of consumers.

Question 13. Review the postcode Access Criteria.

Somewhat agree

Consumer Scotland welcomes the opportunity to contribute to the discussion on reforming the Post Office’s postcode district access criteria that ‘95% of the population live within 6 miles of their nearest Post Office’. 

Post Offices are vital local assets which can deliver significant social and economic value, support economic growth, and provide access to vital services for consumers. Any process to consider potential reforms to access criteria must reflect these multifaceted contributions, particularly in rural and island communities where alternative services are limited or non-existent.

The postcode district access criteria play a vital role in ensuring access to post office services in remote and rural areas. As noted previously in our response, Post Office access for these communities is particularly important for a number of reasons:

• Remote and rural consumers are likely to have access to few other in-person services offering a range of essential services. This is particularly so with the increasing withdrawal of other physical services from many communities, such as bank branch closures
• Lower availability of broadband and other digital technology can make consumers in remote and rural Scotland more reliant on in-person post office services
• Travel times in rural areas can be significant longer due to geography and topography; therefore, any relaxation of postcode district access criteria could result in very significantly increased journey times to the nearest post office for some consumers in Scotland
• This issue is exacerbated by the limited public transport options in many rural areas, which can be particularly challenging for some consumer groups, such as disabled consumers. In this context, and as noted above, any relaxation of postcode access criteria could risk particularly detrimental impacts for these consumers in terms of reducing their ability to access the nearest post office

For these reasons, we would have very significant concerns about any potential diminution of the postcode district access criteria. If the criteria were to be reviewed, then we would recommend that robust modelling would be essential to test the impact of any changes and the implications this may have for some consumers. A robust approach would be required to ensure that changes did not lead to significant consumer harm. 

‘As the crow flies’ approach

If the postcode district criteria are reviewed Consumer Scotland would suggest revisiting the current ‘as the crow flies’ approach to measuring access as part of this process. This method can underestimate actual travel distances and does not sufficiently account for the realities of rural infrastructure.

A road-based, journey-time approach would better reflect the on-the-ground reality and accessibility challenges faced by rural consumers.

Although previously discounted in the UK Government’s 2016 consultation, the Post Office Green Paper presents an opportunity to reconsider this decision.

If the ‘crow flies’ method is retained, this would strengthen the case for a dedicated Rural Post Office Strategy to mitigate potential disadvantages for remote communities.

Key points for question 13

1.      Consumer Scotland welcomes discussion on the access criteria, but we would have significant concerns about any reduction in the postcode district criteria. As previously outlined, we would recommend that dedicated work is required on rural Post Office provision to ensure that any changes to not adversely impact on rural populations.

2.      We additionally would suggest that Government could revisit the ‘as the crow flies’ element of the access criteria which does not sufficiently account for the challenges of rural infrastructure.

3.      We have outlined possible suggestions which could provide a more multi-faceted approach to access criteria including outreach services, and travel/journey time by road. 

Question 14. Review what counts as a Post Office branch.

Strongly Agree 

Consumer Scotland wants to see a modern Post Office network delivering a high-quality customer experience that reflects the evolving needs of consumers in Scotland. As the statutory consumer body, our assessment is that the definition of a Post Office under access criteria must consider what is the minimum range of service models that deliver core functions, particularly in rural, remote, and underserved communities. 

When considering what counts as a Post Office, we see that a Post Office location should be considered when it meets the following principles: 

• Access: Provides access to essential postal, financial and government services
• Functionality: Offer a defined minimum suite of services which include mail, parcels, banking, and government transactions
• Continuity and trust: Operates with predictable hours and service availability which meet consumer needs

When considering the potential offerings which could qualify as a “Post Office” – there are several models of Post Office service:

a.      Traditional standalone Post Offices and full-time permanent branches in a retail setting (offering a wide range of services including post, banking, bills, and government services).

b.      Banking hubs (offering access to cash, deposits, and basic banking especially in areas with bank closures and can use Post Office counters). Scotland has seen the highest rate of bank branch closures in the UK (53% since 2015), disproportionately affecting rural communities.

c.       Parcel Pick Up and Drop Off points (PUDO) (include parcel lockers, convenience stores or other hubs).

d.      Mobile and outreach services via van or temporary set ups on specific days for low density and remote environments. Our previous research with low income and rural postal consumers showed that reliable postal access is critical for financial, health, and social communication needs particularly for those who are digitally excluded.

e.      Hybrid models which provide a minimum combination of services that are tailored to local needs (for example Pick Up/Drop Off plus banking services in more remote areas). 

Consumers must have clear understanding of what their local provision can and cannot do – and the availability of alternative provision (such as less frequently used services) elsewhere. 

Including Pick Up and Drop off services.

Pick Up and Drop Off services provide increased consumer choice and flexibility and play an important role in a modern and consumer-centric Post Office service. Drop and Collect services make up 6% of the current network (as of March 2024).[36] Consumer Scotland agrees with the ongoing inclusion of Pick Up/Drop Off services within the 11,500 Post Office branches, with restrictions on the proportion of the network covered by PUDO. This would enable consumers to access essential postal services at a convenient and local location and mirror broader sector trends, such as the deployment of parcel lockers. 

However, the provision of PUDO services needs to be balanced against the need for minimum requirements for local services in different areas. Our research suggests these would be:

• expanded postal services (sale of postal products)
• banking and cash
• bill payment services

As part of further work on this issue, some consideration should be given by Government to what the upper limit should be to the number of post office branches across the network that are made up by PUDO services (i.e., what is the maximum percentage of the network that these should comprise). 

Consumer Scotland’s research has shown stamps and parcel services as one of the most important services for consumers. From our survey:

The vast majority (90%) of respondents had used the Post Office to access services for sending parcels or letters (this includes buying stamps or paying for postage for a letter, sending parcels, collecting parcels, and returning online orders).

The most used service at the Post Office was sending parcels (not including returning online shopping or orders). 72% of respondents reported sending parcels in the last year.

The third most common service accessed was returning online orders, which 58% of consumers reported.

Postal services were one of the most frequently required services for consumers with reduced willingness to travel distance to use these services. This suggests that consumers would value closer access to postal services such as Pick Up and Drop Off but willing to travel for less frequent services such as government services.

Key points for question 14 

1.      Consumer Scotland advocates for a modern Post Office delivering a high quality customer experience that reflects the evolving needs of consumers in Scotland.

2.      Our view is that the definition of the Post Office must consider the minimum range of products and services that consumers need within their local areas.

3.      There are several models of what could qualify as a Post Office including traditional Post Office, banking hubs and PUDO and mobile and outreach service and hybrid models.

4.      Based on our evidence, Consumer Scotland would see a case for the continuation of PUDO being included within the 11,500-branch requirement to better meet most consumers who prefer postal access nearby their location.

5.     We recommend a dedicated rural strategy which assesses the impact of any changes (i.e., to access criteria, postcode access criteria, government funding or what counts as a post office) and outlines how rural Post Offices will be adequately and sustainably deliver sufficient rural services

Question 16: The existing governance structure have postmaster non-executive directors on the Post Office board alongside Post Office’s new Consultative Council and Postmaster panel. Do you believe that these existing governance structures are sufficient to achieving Post Office’s cultural transformation? 

Somewhat. 

Question 17: Please explain your answer.

Not answered.

Question 18: Postmaster engagement bodies should be set up to be permanent. 

Not answered

Question 19: Postmaster engagement bodies should be set up with a clear remit.

Not answered

Question 20: Postmaster engagement bodies should be set up independent of Post Office

Not answered

Question 21: Any governance measures should only be introduced if they do not slow down Post Office’s transformation plan. 

Disagree. 

Post Office should deliver for the consumers it serves, and governance and accountability measures should reflect the aim of a consumer-centred Post Office. 

Question 22: Postmasters should be able to Input more that they currently do into government’s decision on Post Office.

Not answered

Question 23: Engagement bodies should include more diverse membership which as consumer groups and special interests rather than just postmasters.

Strongly agree.

Question 24: Postmasters should be represented by an organisation not funded by Post Office.

Not answered

Question 25: Post Office should be free to consult a wide range of groups representing postmasters on issues such as remuneration and contractual issues. 

Not answered 

26. Which of these aspects of the governance model that could be changes is the most important to you? Please select one answer.

Engagement bodies should include more diverse membership including consumer groups and special interests rather than just postmasters. We have outlined the rationale for this approach on page 16.

Next steps on shorter and longer-term reforms

Question 27: Which of the following options for managing Post Office in the long term do you think government should pursue?

No answer selected. See text.

Consumer Scotland welcomes the UK Government’s consideration of alternative ownership and delivery models for Post Office and supports a national conversation on governance reform. Consumer Scotland would like to see a future model which supports and bolsters both consumer involvement and consumer confidence in the Post Office.

The Horizon scandal has exposed deep flaws in the current structure, and mutualisation presents an opportunity to rebuild trust, improve accountability, and ensure the Post Office serves consumer interests. Research and consumer polling data suggests that the Horizon Scandal has led to a decrease in consumer confidence and trust in the Post Office. Polling by Savanta found trust in Post Office fell from 83% to 69% following the Horizon Scandal. Additionally, they found that the Post Office fell from 6th to 135th of the most trusted financial, banking, and insurance brands.

We understand that Postmasters see benefits of shared ownership which recognises their historic contribution to Post Office. However, delivering positive consumer outcomes through high quality service delivery remains the key purpose of post offices, and shared ownership would need to also resolve persistent issues affecting the quality and accessibility of in-branch services. Research by Citizens Advice (2025) showed that participants felt that more should be done to provide a better in-branch experience at post offices particularly in relation to accessibility, opening hours and customer service.[37] For example, many participants felt the internal layout of branches were not accessible for disabled people with nearly 1 in 5 (17%) of visits finding obstacles that impede or prevent wheelchair access.[38] Additionally, Citizens Advice highlight issues with service standards and staff product knowledge.

The Green Paper provides an opportunity to deliver measurable improvements in the consumer experience of Post Offices. For this to be achieved, we recommend that consideration is given to how a stronger consumer focus can be embedded throughout the Post Office. This may include an increased strategic focus on consumer outcomes within the Post Office and in Government’s objectives for the network, the development of robust and meaningful consumer experience measures and strengthened consumer representation within Post Office governance and accountability arrangements. 

Question 28: In a potential mutual model, postmasters should not take on overall financial liabilities for the organisation.

Not answered

Question 29: Under mutualisation, Post Office should be completely independent from government. 

Not answered

Question 30: In a potential mutual model, only postmasters and strategic partners should be able to be members. 

Not answered

Question 31: Post Office should be given more independence from government once Post Office has achieved its cultural and financial policy objectives. 

Not answered

Question 32: Apart from the changes and options suggested in Q12-15, do you have any other suggestions for how governance arrangements should be changed in the short term or long term?

As outlined above, Consumer Scotland would recommend that consideration is given to a stronger consumer voice within governance and accountability arrangements (options outlined on pages 15-16). 

Question 33: Do you have any other views on the points raised in this consultation that you feel the government should consider regarding the future of the Post Office?

None