Relevant funds
Relevant funds are the sums a UK payment or e-money institution receives from, or for, customers to execute payments or in exchange for e-money. They are the funds the firm must safeguard.
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: defined in regulation 23 of the Payment Services Regulations 2017 and in the Electronic Money Regulations 2011. FCA CASS 15 supplements these rules from 7 May 2026.
How it works
Regulation 23 of the Payment Services Regulations 2017 sets out two categories. The first is money received from, or for the benefit of, a payment service user to execute a payment. The second is money received from another payment service provider to execute a payment for a user. For e-money firms, the term also covers funds received in exchange for e-money issued.
Relevant funds set the safeguarding requirement that CASS 15 reconciliations test each reconciliation day. E-money funds and funds for unrelated payment services must be reconciled separately. Funds for transactions outside the regulations' scope are not relevant funds and must not be mixed with them.
Pitfalls include mixing own fees with customer money and missing funds received through agents. Another is failing to separate out-of-scope flows. Under CASS 15, a firm must use its own money to fix a shortfall when relevant funds cannot be used.
Example
Illustrative example: An e-money institution holds £8,000,000 for e-money issued and £1,500,000 received for unrelated payment services. Relevant funds total £9,500,000. CASS 15 requires the firm to reconcile them as two separate pools of £8,000,000 and £1,500,000.
Frequently asked questions
Are funds for non-UK payments relevant funds?
Not under CASS 15 where both payer and payee are served from outside the UK. The FCA says such funds should not be mixed with relevant funds, even if routed through a UK correspondent.
When must relevant funds be protected?
They must be kept apart from the firm's own funds. Funds still held at the end of the business day after receipt must then be protected. They go into a separate account at an authorised credit institution or the Bank of England, or into approved assets.
Related terms
Sources
- The Payment Services Regulations 2017, regulation 23 (Safeguarding requirements) · legislation.gov.uk (The National Archives)
- PS25/12: Changes to the safeguarding regime for payments and e-money firms · Financial Conduct Authority
- CASS 15.1 Purpose and application · FCA Handbook
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