The FCA’s updated safeguarding regime under CASS 15 marks the most significant change to payment and e-money compliance in years. From 7 May 2026, daily reconciliation, monthly safeguarding returns, annual safeguarding audits and resolution pack maintenance are mandatory.
For most UK payment institutions and EMIs, this represents a structural shift. Safeguarding moves from a periodic compliance obligation to a continuous operational control, with evidential standards firms must meet every day.
Is UK payments ready for CASS 15?
To answer that question, Kani Payments surveyed 75 compliance and finance professionals across FCA-regulated authorised payment institutions and electronic money institutions. The findings paint a clear picture of where the sector stands as the regime takes effect—and where the most significant gaps lie.
What we found:
- 32% of firms believe they are already compliant with the CASS 15 requirements, yet just 13% are performing daily safeguarding reconciliations
- Nearly 90% of firms are not yet operating at the daily reconciliation cadence required under the FCA’s new rules
- 64% of firms still rely on spreadsheets for monthly safeguarding returns, introducing structural risk under increased regulatory scrutiny
- Only 21% of firms can produce a complete safeguarding evidence pack in real time, against the FCA’s 48-hour resolution pack expectation
- 84% of respondents believe they could explain every calculation in their safeguarding reports to an auditor
The headline finding: there is a meaningful gap between how ready firms feel and how ready they actually are. With safeguarding requirements under CASS 15 now live, that gap has tangible consequences for compliance, audit outcomes and supervisory engagement.
Whether you’re preparing for your first safeguarding audit, refining your daily reconciliation process or assessing how your firm benchmarks against the wider industry, this report provides a direct view of where the UK payments sector stands at the start of the new safeguarding era.
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