From 7 May 2026, daily safeguarding reconciliation is no longer optional. It is a hard requirement under the FCA’s updated CASS 15 regime—one that applies every reconciliation day without exception.
Yet according to Kani’s research into safeguarding readiness across the UK payments sector, just 13% of firms currently reconcile daily. The majority operate weekly (53%), while 28% reconcile monthly and a further 5% do so less frequently.
In total, nearly 90% of in-scope firms are not operating at the daily cadence the FCA now expects.
Here, we explore why reconciliation frequency is a risk issue, not just a scheduling one.
The cost of weekly reconciliation under a daily regime
Safeguarding reconciliation is the process of comparing safeguarding requirement against safeguarding resource to confirm that customer funds are fully protected and any shortfall is identified without delay.
At first glance, the difference between daily and weekly reconciliation can feel administrative—a question of scheduling rather than control. It isn’t.
When reconciliation moves from periodic to daily, the risk profile changes in four material ways.
1. Shortfalls sit undetected for longer
Under a weekly cadence, a mismatch between safeguarding requirement and safeguarding resource can remain undetected for days. Daily reconciliation limits that window to hours. The longer a shortfall goes undetected, the greater the exposure and the harder it becomes to explain.
2. Root-cause analysis becomes reconstruction
Daily checks narrow the error window to a single day’s activity. Weekly reconciliation turns investigation into reconstruction. Teams must work backwards across multiple days of transactions, system updates and manual adjustments to isolate where a break originated—a process that is slower, less reliable and harder to document.
3. Evidence risk increases
Safeguarding reconciliation is intended to function as a check on the accuracy of books and records, not a substitute for them. When reconciliation happens infrequently, the evidential trail becomes harder to maintain—particularly around timestamped positions, version control and traceability between source data and reported outputs.
The FCA’s resolution-pack standard expects certain records (including recent reconciliations) to be immediately available. A weekly or monthly process makes that standard structurally more difficult to meet.
4. Supervisory obligations tighten
Monthly safeguarding returns under PS25/12 require firms to confirm whether reconciliations were performed every reconciliation day. Where reconciliations cannot be performed or discrepancies cannot be resolved, the FCA expects notification without delay.
Most safeguarding processes weren’t built for daily operation
Challenges arise because most reconciliation processes were designed for periodic execution. They were built around weekly or monthly rhythms, with manual touchpoints between systems, data that requires enrichment before it can be used and exception management that depends on individual knowledge of how figures move. Those workflows can produce a return. They cannot easily produce one every day.
It seems tempting to just run existing processes more frequently. But without redesigning them, the workload doesn’t reduce—it compresses. Tighter timeframes applied to manual, multi-step workflows typically erode the controls they’re meant to strengthen.
The spreadsheet constraint
Spreadsheets remain deeply embedded. While 36% now operate fully automated safeguarding workflows, the majority (64%) still depend on spreadsheets to some degree—either exclusively or in combination with other tools.
The distinction has a material impact on reconciliation frequency. Among spreadsheet-only firms, the largest group (66%) reconcile monthly or less frequently. Among fully automated firms, the largest group (53%) reconcile weekly. This gap reflects what manual, assembly-dependent processes can practically support.
Daily reconciliation and spreadsheet-dependent processes are difficult to square. The data preparation, manual enrichment and cross-system coordination required to run a reconciliation are simply too slow to support daily execution at any meaningful scale.
Beyond speed, spreadsheet-based processes present audit challenges that become more acute under increased frequency: undocumented formulas, version control risks and a dependency on specific individuals to interpret reconciliation breaks and maintain process continuity.
What automation does and doesn’t change
Even firms with fully automated safeguarding workflows haven’t cracked daily operation: just 15% reconcile daily, with 53% operating weekly and a further 33% monthly or less. The challenge, it turns out, is one of infrastructure rather than intent.
Although automation shifts firms out of the weakest cadence and into a more controlled weekly rhythm, it doesn’t on its own deliver the daily operation the FCA now expects. For automated firms still falling short, the question is whether daily reconciliation was ever a design requirement—or whether existing workflows were built for efficiency at weekly cadence and simply haven’t been re-engineered since.
Building for daily reconciliation
The firms best placed for the new CASS 15 regime are those that have re-engineered their safeguarding processes specifically for daily reconciliation, not those applying more effort to workflows that were never designed for it.
In practice, daily safeguarding requires:
- Predictable, automated data ingestion: source data from banks, processors and ledgers arrives clean and on time, without manual preparation before reconciliation
- Consistent reconciliation logic: matching rules are system-defined and applied uniformly, so outputs don’t vary based on who runs the process or when
- Automated exception management: breaks are surfaced and flagged immediately, not discovered at the point where weekly reporting is due
- Repeatable outputs: results are consistent and traceable back to source data, regardless of who is running the process
For a sector where nearly 90% of firms still have significant ground to cover as we approach go-live, the question is no longer whether daily reconciliation is required, but whether the infrastructure exists to support it.
🛡️Preparing for daily safeguarding?
* Kani’s safeguarding readiness research surveyed 75 professionals across FCA-regulated Authorised Payment Institutions and Electronic Money Institutions.
