A playbook in CASS 15 implementation for the finance, operations and compliance teams running safeguarding every day.
Where daily safeguarding breaks down
CASS 15 came into force on 7 May 2026. Most firms arrived with policies reviewed and responsibilities assigned. The harder work starts once safeguarding has to run every reconciliation day and hold up under scrutiny, whoever is at the desk.
A weekly or monthly cycle leaves time to chase late files, investigate discrepancies and prepare data before sign-off. A daily cycle takes most of that time away. Unreliable balances, inconsistent source data, unclear ownership and evidence scattered across spreadsheets and email all surface faster.
The playbook draws on Kani’s CASS 15 implementation work with UK payment and e-money firms. It covers the five areas that most often decide whether a daily control holds up.
What the playbook covers
Inside, we cover five lessons drawn from Kani’s work on CASS 15 implementations in 2026
Prove the balances before you build the reconciliation
Reconciliation can’t fix a wrong balance upstream. Establish the system of record for each balance and trace how it reaches the calculation.
Build data for safeguarding, rather than relying on source files
Bank, processor, scheme and ledger files each describe the same transaction differently. A data model built around the calculation cuts false exceptions and keeps every result traceable.
Map the operating model before configuring the control
Missing files, timing differences and shortfalls each need an agreed treatment, owner and escalation path before the first exception appears.
Produce evidence as part of the process
Auditors need to follow how each position was reached. Keep source data, exceptions and approvals linked to the position as the work happens.
Control the points where the safeguarding position can be altered
Every manual change to data, formulas or balances needs a record of what changed, why and who approved it. Spreadsheets make that hard to guarantee.
Read the safeguarding playbook
Each lesson ends with actionable steps your team can apply to its own daily control. It’s free, ungated and ready to read below 👇
