One Cash Withdrawal, Two Fees: The Real Cost of an Out-of-Network ATM

Two payees, one transaction

The structure has been documented by the U.S. regulator since 2013: "not provided by their financial institution (foreign ATMs) to withdraw money or check balances will typically pay two fees for a single transaction. First, the operator of the foreign ATM (which may or may not be a financial institution) will usually impose a charge. ... Second, the consumer's own financial institution also may impose a charge for using a foreign ATM."[20]

Only the label "foreign ATM" is dated; the mechanic is not. Bankrate's 2025 checking-account study puts current money on it: "The cost of an out-of-network ATM withdrawal (the surcharge assessed by the ATM owner and the fee your bank charges for going outside of the network) has reached a record high for the third consecutive year at $4.86, up 1.9% from $4.77 in 2024."[23] Of that $4.86, the owner's surcharge averages $3.22 and the account holder's own bank averages $1.64.[23]

Who must tell you the price, and when

The two fees sit under different disclosure rules. For the machine's owner, 12 CFR 1005.16(b) requires that an operator who imposes a fee "must provide a notice that a fee will be imposed for providing electronic fund transfer services or a balance inquiry that discloses the amount of the fee", and 1005.16(c) fixes the timing: the notice must be shown "on the screen of the automated teller machine or ... on paper, before the consumer is committed to paying a fee."[22] The fee may then be charged "only if" the consumer was given that notice and "elects to continue the transaction or inquiry after receiving such notice."[22]

Your own bank's charge is disclosed elsewhere. Regulation E's initial-disclosure section lists, under the heading "ATM fees", "A notice that a fee may be imposed by an automated teller machine operator ... and by any network used to complete the transaction."[21] Nothing in that rule puts your bank's own out-of-network amount on the screen while you decide — the machine-side amount is the one you can see before committing.

The 2025 numbers, and their methodology

Bankrate's press release of September 10, 2025 breaks the $4.86 into its parts: the average surcharge "reached a record high for the fourth consecutive year at $3.22, up 0.9% from $3.19 in 2024, and the average fee assessed by your bank for going outside of the network rose to $1.64, up 3.8% from 2024 and the highest since 2018."[23]

Metro variation is real: "Atlanta having the highest average ATM fee of $5.37 and Boston having the lowest of $4.37."[23] The methodology is published with the release: "10 banks and thrifts in each of 25 large U.S. markets; 1 interest and 1 non-interest checking account ... surveyed from 245 financial institutions ... between June 2 - July 3, 2025."[23] So these are averages across markets, not a quote for your bank or your street.

The same structure, priced in 2013

The 2013 rulemaking records its own survey figures so the direction of travel is visible: "the average ATM charge imposed by foreign ATMs is $2.40. ... That charge averages $1.40, according to the same survey. Thus, the average total charge for using a foreign ATM ... is $3.80."[20]

Those dollar figures belong to 2013 and are not presented as current. What carries forward is the rule itself: the document is a final rule "effective on March 26, 2013" that removed the on-or-at-the-machine placard requirement and left the on-screen or paper notice with the fee amount intact.[20] That is why an absence of a sticker tells you nothing, and the screen is the place to look.

Worked example: a year of cash at the 2025 average

Hypothetical arithmetic on a sourced average: if a household makes four out-of-network withdrawals a month and the 2025 average total of $4.86 applied to each, the cash-access cost would be $19.44 a month and $233.28 over twelve months. The withdrawal count is an assumption; the $4.86 is Bankrate's published 2025 average, not a forecast for 2026.[23]

The example also shows where the saving sits. At the same averages, the account-holder side is $1.64 of the $4.86 and the owner side is $3.22: moving to a bank that refunds surcharges or belongs to a wide network changes one line, while using the owner's own network changes the other. Whether your account reimburses either charge is a fact about your fee schedule, so read that schedule rather than a comparison table.

Before you withdraw: a four-question check

Ask: (1) Is this machine in my bank's network? (2) What surcharge does the screen quote, and does the amount shown cover only the operator's fee?[22] (3) What does my own account charge for going out of network, and does it refund surcharges?[21] (4) Am I being charged for a balance inquiry as well as the withdrawal — Regulation E's operator notice covers "an electronic fund transfer or a balance inquiry", so one visit can carry two operator fees.[22]

Scope and evidence limits: United States only; other countries have different surcharge regimes and are not covered. The $4.86 / $3.22 / $1.64 figures are Bankrate's 2025 averages across 25 markets, published September 10, 2025, not your bank's rate.[23] The $2.40 / $1.40 / $3.80 figures are from a 2013 Federal Register rule and are historical only.[20] Regulation E text was read on the CFPB and eCFR sites on September 24, 2026.[21][22] Nothing here is a live quote or personalised financial advice.