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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FAQs
What is CASS 15?
CASS 15 is the FCA’s updated safeguarding regime for payment and e-money firms, introduced under policy statement PS25/12. It raises expectations around governance, record-keeping, reconciliation frequency and evidential readiness, taking effect from 7 May 2026.
What does CASS 15 require firms to do?
The regime introduces daily safeguarding reconciliation, monthly safeguarding returns to the FCA, annual safeguarding audits and resolution-pack maintenance. Together these shift safeguarding from a periodic compliance obligation to a continuous operational control.
What is a safeguarding reconciliation?
A safeguarding reconciliation compares the funds a firm is required to safeguard against the funds it holds in safeguarding, confirming the two match. Under CASS 15 this must be performed each reconciliation day and should explicitly test safeguarding requirement against safeguarding resource, including D+1 comparison mechanics.
Is the UK payments industry ready for safeguarding?
Kani’s 2026 research, based on a survey of 75 compliance and finance professionals, found an industry in transition. Awareness is high, but operating models lag. While 32% consider themselves compliant, only 13% reconcile daily and nearly 90% are not yet operating at the required daily cadence.
What percentage of payment firms are compliant with CASS 15?
In Kani’s survey, 32% of firms considered themselves already compliant with the updated requirements. A further 49% were implementing required changes, 13% were assessing the guidelines and 5% had not yet begun preparation. Notably, this is self-assessed compliance.
How many firms perform daily safeguarding reconciliation?
Only 13% of firms currently reconcile daily. The majority operate weekly (53%) or monthly (28%), with a further 5% reconciling less frequently. Taken together, nearly 90% are not yet at the daily cadence the FCA expects.
How many payment firms still use spreadsheets for safeguarding?
64% of firms still rely on spreadsheets to some degree for monthly safeguarding returns. 52% use a semi-automated mix of tools and spreadsheets, 12% use spreadsheets exclusively, and 36% have a fully automated solution.
Does automation improve safeguarding compliance?
It helps but doesn’t guarantee it. In Kani’s research, daily reconciliation remained low across all operating models (11–15%), so automation alone doesn’t deliver daily cadence. But it shifts firms out of the weakest, most infrequent posture: two-thirds of spreadsheet-only firms reconcile monthly or less, versus around a third of automated firms.
How confident are firms in their safeguarding audit readiness?
84% of respondents believe their team could explain every calculation in their reports to an auditor, but only 35% are very confident, with 49% only somewhat confident. Confidence is weakest among spreadsheet-only firms, 22% of whom lack confidence they could explain their calculations.
What’s the biggest gap in CASS 15 readiness?
The gap between perceived and actual readiness. Firms broadly understand the rules (43% say they understand what’s required but need more time and clarity to implement) but understanding the regulatory model is easier than re-engineering an operating model to meet it. The challenge concentrates in daily reconciliation, evidence readiness and audit explainability.
How many firms have fully automated their safeguarding?
36% have a fully automated solution in place. Among these firms, 44% have real-time evidence access and 88% can produce an evidence pack within one working day—substantially ahead of semi-automated and spreadsheet-based firms.
What should payment and e-money firms do now to stay ahead of CASS 15 requirements?
Firms best positioned for the regime treat safeguarding as infrastructure rather than obligation. In practice, that means moving reconciliation to a genuine daily cadence, embedding calculation logic in controlled systems rather than spreadsheets, and structuring workflows so evidence is generated automatically and held ready for retrieval rather than assembled on request.
