The group of Australian banks fighting it out with Apple for access to the iPhone's near-field communication function say that it is "unrealistic" to expect them to settle for Android Pay and non-NFC alternatives.
The four banks - Commonwealth Bank of Australia, Westpac Banking Corporation, National Australia Bank, and Bendigo and Adelaide Bank - went to Australia's competition watchdog last summer seeking permission to engage in collective negotiation with Apple in relation to the roll out of Apple Pay in Australia.
The banks later narrowed their case, focussing purely on access to the NFC function on iPhones so that they can offer their own wallets on the handsets in the same way they can with Android phones.
In their latest submission to the Australian Competition and Consumer Commission (ACCC), the group says that it is unrealistic for it to follow the lead of banks in places such as the UK and US and accede to Apple's demands.
Australia, they say, has the world's highest adoption of contactless NFC card payments and one of the world's biggest iPhone market shares, meaning that "potential mobile wallet providers other than Apple are locked out of the established payment infrastructure in respect of the clear majority of relevant customers".
The submission argues that if competing wallets had access to the iPhone's NFC function there would be more opportunities for cashback and other promotions. This is because, by encouraging a customer to use an issuer mobile wallet rather than the Apple one, an issuer would avoid the Apple Pay transaction fee and "therefore have an incentive to share some or all of that saving with the customer in the form of discounts, cashbacks or promotions".
In addition, the banks would have "an incentive to invest that saving in developing new functions and features to encourage customers to use its mobile wallet and to compete more effectively with the Apple Wallet".
The submission also says that Apple's refusal to provide access to hardware is inconsistent, noting that third-party apps can use the iPhone's camera, microphone and speaker, leading to a "proliferation of innovation".
"There is no reason why the NFC function should be treated differently, and the Android platform shows that multiple applications can use the NFC function as seamlessly as they can use any other hardware feature."
This emphasis on innovation and competition comes after the Commission issued its provisional ruling in December, coming down in support of Apple and expressing concerns that a ruling in favour of the banks could reduce or distort competition in a number of markets.
The ACCC is expected to issue its final ruling on the dispute later this month.