Solutions
Safeguarding for payments & e-money
An end-to-end safeguarding control system aligned to the FCA’s CASS 15 regime
Key Benefits
Safeguarding, under control
One clear position
Bring every reconciliation into one daily safeguarding position, with visibility into what’s changed and why
Built for daily control
Run safeguarding as a structured, repeatable process—not a spreadsheet exercise
CASS-aligned
Apply the FCA’s safeguarding rules as intended, with daily reconciliation and D+1 comparison built in
No data gaps
See safeguarding differences instantly, clear visibility into what’s driving each movement
Flexible reconciliation
Model safeguarding around your actual flows, with flexible structures that still enforce consistency and control
Audit-ready evidence
Maintain a complete, attributable record of reconciliations, actions and approvals ready for audits or regulatory review
Compliance that finally feels manageable
Key features
Daily control
One position. No ambiguity
Bring fragmented reconciliations and bank feeds into one safeguarding position you can see clearly, explain fully and rely on every day
- Aggregate safeguarding resource and requirement by currency
- Validate the safeguarding position against bank balances
- See exactly which reconciliations drive each difference
- Show shortfalls and excesses clearly, side by side
100% traceability
Explain every flow
Classify funds and track movements end-to-end, so every transaction is understood, correctly treated and fully explainable
- Designate accounts as client funds, own funds or other
- Apply rules-based classification with manual control
- Handle funds in transit and sweep flows with clear treatment
- Attest completeness of in-scope accounts and flows
Built your way
Reconciliations to fit your model
Build safeguarding reconciliations that reflect your business model, while keeping the structure consistent, controlled and aligned with CASS 15
- Match records across datasets to identify differences and exceptions
- Use structured reconciliation templates with required safeguarding fields
- Maintain separate internal and external safeguarding reconciliations
- Schedule daily runs for consistent, repeatable reconciliation
Source of truth
Bank data without gaps
Unify bank data into a single, trusted view of accounts, balances and transactions—so safeguarding starts from a position you can trust
- Ingest bank data from all accounts and providers
- Normalise balances and transactions into one model
- View positions clearly by currency and account
- Automatically flag new accounts and coverage gaps
- Surface missing feeds and potential double-counting early
Audit-ready
Sign off with confidence
Stay audit-ready, with every decision, action and sign-off recorded alongside your safeguarding position
- Role-based sign-off and approvals with full accountability
- Complete audit trail of runs, actions and changes
- Central repository for safeguarding documentation and evidence
- Produce monthly returns and annual audit outputs
Powering payments & banking leaders
Let’s talk
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See for yourself
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FAQs
What are the CASS 15 safeguarding regulations?
CASS 15 is the FCA’s new handbook chapter for payments and e-money safeguarding. It supplements the safeguarding requirements in the Payment Services Regulations 2017 and the Electronic Money Regulations 2011 by setting more detailed rules on how firms must protect relevant funds, including governance, record keeping, reconciliations, segregation, third-party oversight, reporting and audit requirements. It forms part of the FCA’s new Supplementary Regime.
Who does safeguarding apply to?
The FCA says the new rules apply to authorised payment institutions (APIs), authorised e-money institutions (EMIs), small e-money institutions, and credit unions that issue e-money in the UK. Small payment institutions can opt in voluntarily, and certain firms can also opt in for unrelated payment services.
What are “relevant funds” under CASS 15?
Relevant funds are funds received in exchange for issued e-money, sums received from or for a payment service user to execute a payment transaction, and sums received from another payment service provider for the execution of a payment transaction on behalf of a payment service user. In other words, they are the customer funds that fall within the safeguarding regime.
How often do firms need to perform safeguarding reconciliations?
Under the final rules, firms must perform safeguarding reconciliations at least once each reconciliation day. A reconciliation day excludes weekends, UK bank holidays, and certain days when relevant foreign markets are closed. The FCA also makes clear that reconciliations are there to check the accuracy of books and records, not to replace proper record keeping.
What new reporting and audit obligations are involved?
The Supplementary Regime introduces a new monthly safeguarding return to the FCA and, for many firms, an annual safeguarding audit by a qualified auditor. The FCA also introduced an exemption from the audit requirement where a firm has not been required to safeguard more than £100,000 of relevant funds at any time over at least 53 weeks.
When do safeguarding rules come into force?
The FCA’s Supplementary Regime comes into force on 7 May 2026. Before then, in-scope firms need to familiarise themselves with the new rules in CASS 10A, CASS 15, SUP 3A and SUP 16.14A, and establish the systems and controls needed to comply.
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