CASS 15
CASS 15 is the chapter of the FCA Client Assets Sourcebook that sets detailed safeguarding rules for UK payment and e-money institutions. It came into force on 7 May 2026 under Policy Statement PS25/12.
This page explains the rules in general terms and is not legal or regulatory advice. Check the primary source and take advice on how the rules apply to your firm.
UK: FCA Handbook CASS 15, introduced by Policy Statement PS25/12 (2025) and in force from 7 May 2026.
How it works
CASS 15 supplements the safeguarding duties in the Payment Services Regulations and Electronic Money Regulations. It applies to authorised payment institutions, e-money institutions and credit unions that issue e-money. Firms offering only account information or payment initiation are excluded. Small payment institutions that choose to safeguard are treated as authorised for CASS 15.
Key duties include internal and external reconciliations each reconciliation day and a monthly safeguarding return. Most firms also need an annual safeguarding audit. Firms that have not been required to safeguard more than £100,000 of relevant funds at any time during a period of at least 53 weeks are exempt. The first audit report is due six months after the period ends; later ones within four months.
Firms must keep a resolution pack showing where funds are held and how they would be returned. Insurance or guarantee cover must pay out on certification of insolvency alone. The FCA has not adopted its proposed statutory trust. It plans to review the regime after a full audit period.
Example
Illustrative example: A payment institution's first audit period ends on 31 December 2026. Its first safeguarding audit report is due by 30 June 2027, six months later. The report for the period ending 31 December 2027 is due by 30 April 2028, four months later.
Frequently asked questions
Does CASS 15 apply to small payment institutions?
Only if they choose to safeguard. A small payment institution that opts in is treated as an authorised institution for CASS 15 purposes. Small e-money institutions are within scope.
What is the monthly safeguarding return?
A new regulatory return that replaces earlier safeguarding questions in other returns. Firms submit it through My FCA within 15 business days of each month end. It confirms the required reconciliations were done on each reconciliation day.
Related terms
Sources
- PS25/12: Changes to the safeguarding regime for payments and e-money firms · Financial Conduct Authority
- CASS 15.1 Purpose and application · FCA Handbook
- Safeguarding requirements for payment and e-money institutions · Financial Conduct Authority
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