Safeguarding with Kani: CASS 15 Software for Payments Firms

Daily safeguarding for payments and e-money firms, built for the FCA’s CASS 15 regime

Safeguarding is no longer something payments and e-money firms can patch together with spreadsheets, workarounds and end-of-month explanations. Under the FCA’s CASS 15 regime, firms are expected to calculate, reconcile, evidence and sign off their safeguarding position as a daily, repeatable control — not a monthly reconstruction.

Our free solutions guide shows how Kani runs safeguarding in practice, from ingesting bank, processor and ledger data through to tabular reconciliation, daily sign-off and the monthly FCA return. It’s completely ungated: no form or email required 👇

Read Kani’s safeguarding guide here

Short on time? This page covers what CASS 15 asks of payments firms and how Kani handles each part day to day. The guide goes deeper.

What CASS 15 asks of payments firms

CASS 15 raises the bar for how API and EMI firms safeguard relevant funds. In practice, the regime expects firms to:

• Calculate resource and requirement correctly, including unallocated receipts and the correct treatment of payments, redemptions, fees and timing
• Reconcile daily, keeping an evidential record of what was run, when, by whom, and how discrepancies were resolved
• Identify relevant funds end-to-end, including funds in transit that are segregated but not yet in a relevant-funds account
• Segregate and protect client money, with clear account classification and naming
• Allocate receipts promptly, before the end of the next business day, and control unallocated funds until they’re allocated
• Maintain governance and oversight, with a named accountable senior manager and documented policies, methodology and third-party arrangements
• Report and stay audit-ready, producing the monthly safeguarding return, supporting the annual audit, and logging notifiable issues for FCA notification without delay

Most firms can meet some of these on a good month. CASS 15 expects all of them, every working day.

How Kani runs safeguarding

Kani gives payment and e-money firms a structured way to calculate, review, evidence and sign off their safeguarding position every working day. Rather than bolt reconciliation onto a spreadsheet, Kani brings fragmented payments data, controls, reconciliations and evidence into one daily workflow, configured around how each business actually operates.

It’s built on eight core control layers:

1. Bank data pipelines — daily ingestion of bank, processor, scheme, ledger and custom file data
2. Bank data model — a single view of accounts, balances and transactions, whatever the source or provider
3. Account classification — designation of accounts as client funds, own funds or other, with multi-tenanted handling
4. Rules-based transaction treatment — classification by fund type, flow type and CASS 15 treatment, using configurable label sets
5. Tabular reconciliation — the configurable reconciliations that underpin every safeguarding position
6. Flexible record matching — one-to-one through many-to-many matching, with exceptions surfaced for review
7. Daily safeguarding dashboard — D+1 resource versus requirement by currency, with warnings, validations and drill-down
8. Compliance, sign-off and evidence — the monthly FCA return, remedial action capture, irreversible sign-off and a full audit trail

Everything starts with the tabular reconciliations. Kani works with each firm to configure these to fit its model, setting out resource, requirement and balances by account, currency and provider. That structure then feeds every position on the dashboard.

One control centre for every safeguarding view

Firms don’t run one reconciliation. They run as many as their currencies, clients and products demand. Kani supports as many dashboards, currencies, reconciliations and sign-off processes as a firm needs, while keeping the structure consistent and controlled.

From a single dashboard, teams calculate the daily position, validate it against bank balances, see exactly which reconciliations drive each difference, and show shortfalls and excesses side by side. Once reviewed, a CASS 15-aligned position can be signed off in minutes and locked as the audit-grade record for that date and currency.

Your monthly FCA safeguarding return (REP027)

CASS 15 introduces a monthly safeguarding return, REP027 (Annex 29B), that firms must produce, evidence and file. Kani builds the return directly from the positions you’ve already calculated and signed off, calculating the figures it can prove and aggregating them across your selected dashboards into a single GBP position.

You complete the rest, your answers carry forward month to month where appropriate, and you stay the accountable party throughout. When the return’s complete, you export it as an XML in the FCA’s own format, then save and upload it to the FCA portal yourself. Kani builds and formats the return; it never files on your behalf.

Kani strengthens safeguarding across three fronts

The full solutions guide walks through how Kani handles safeguarding end to end:

• The eight control layers behind every safeguarding calculation
• How tabular reconciliation is configured and feeds the daily dashboard
• How the daily position is calculated, reviewed and signed off
• How the monthly FCA return (REP027) is built and filed
• A full CASS 15 control mapping, principle by principle

It’s written for compliance, finance and operations teams at APIs and EMIs preparing for CASS 15, and it’s completely ungated.

The full solutions guide walks through how Kani handles safeguarding end to end:

• The eight control layers behind every safeguarding calculation
• How tabular reconciliation is configured and feeds the daily dashboard
• How the daily position is calculated, reviewed and signed off
• How the monthly FCA return (REP027) is built and filed
• A full CASS 15 control mapping, principle by principle

It’s written for compliance, finance and operations teams at APIs and EMIs preparing for CASS 15, and it’s completely ungated.