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CASS 15 safeguarding audit and monthly safeguarding return

By Polynopsis team · Last updated

Since 7 May 2026, every UK safeguarding institution must send the FCA a monthly safeguarding return within 15 business days of each month end. Authorised payment institutions (other than those authorised only for payment initiation or account information services) and e-money institutions must also have an external auditor deliver a safeguarding report to the FCA for each audit period of no more than 53 weeks. An institution that has not been required to safeguard more than £100,000 of relevant funds at any time over a period of at least 53 weeks (until 14 May 2027, at any time since 7 May 2026) is exempt from the audit, while the monthly return applies to all safeguarding institutions.

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.

Jurisdiction: United Kingdom · Regulator: Financial Conduct Authority

Who is in scope

What the rule requires

RequirementHow oftenSource
Submit a safeguarding return to the FCA within 15 business days of the end of each calendar month, by the electronic means the FCA provides (SUP 16.14A.3R and 16.14A.4R). The FCA says returns are submitted through My FCA using form REP027.monthlysource
Appoint an external auditor, notify the FCA without delay of any actual or expected vacancy with the reason, fill any vacancy, and notify the FCA of each appointment with the auditor's name, business address and start date (SUP 3A.3.2R). The safeguarding auditor does not have to be the statutory auditor (SUP 3A.3.3G).ongoingsource
The auditor prepares a safeguarding report addressed to the FCA under a reasonable assurance engagement, giving an opinion on whether the firm maintained systems adequate to comply with the relevant funds regime throughout the period and whether it complied at the end of the period (SUP 3A.9.1R and 3A.9.2R).annualsource
The period covered by each safeguarding report must end not more than 53 weeks after the later of the date the firm became subject to SUP 3A, the date it stopped being exempt, or the end of the previous report's period (SUP 3A.9.6R).annualsource
The auditor gives the firm a draft report with enough time to comment and sends the firm a copy of the final report at the same time as the FCA (SUP 3A.9.10R). The firm should explain the circumstances of each breach in the draft and any remedial action, before the auditor's deadline (SUP 3A.10.1G).annualsource
The firm must report the final safeguarding report to its governing body (SUP 3A.10.2R).annualsource

Deadlines

Records and evidence

Inputs when money sits across banks, partners and wallets

InputWhat it feedsRule
Daily safeguarding requirement for every day of the month, converted to GBPHighest and lowest safeguarding requirement in the monthly return (questions 9 and 10)source
Results of the last internal reconciliation in the month: items A to D of the resource, individual balances and unallocated receipts, excess or shortfall and the adjustment madeMonthly return questions 16 to 21 (CASS 15.8.26R and 15.8.30R)source
Month-end balance per bank or other institution holding relevant funds, with legal name, account type, fixed term or notice period and country of incorporationMonthly return question 11source
Closing spot FX rate for the day before each relevant date or reconciliation, for every non-sterling currency heldGBP conversions required throughout the monthly returnsource
Account inventory: accounts opened and closed in the month and which are covered by a countersigned acknowledgement letterMonthly return question 28; CASS 15.7.3R requires an acknowledgement letter for each relevant funds bank accountsource
Log of each internal and external reconciliation performed, with time, actions and outcomeYes or no answers in return questions 26 and 27, and the auditor's assessment of compliance (CASS 15.8.9R)source
Register of breaches and FCA notifications during the audit periodThe auditor's breaches schedule must list each breach identified (SUP 3A.9.12R and 3A.9.14G)source
Peak amount the firm was required to safeguard at any time over the test periodDetermines whether the £100,000 audit exemption applies (SUP 3A.1.1R(2))source

Where Polynopsis fits

Polynopsis gives finance teams one read-only, timestamped position across every bank, payout partner, exchange and wallet, which is the balance data a safeguarding reconciliation starts from. It is not safeguarding or reconciliation software, and it works alongside the tools and processes firms use to meet these rules.

Frequently asked questions

When is the first CASS 15 safeguarding audit report due?

If the audit period ends within 53 weeks of 7 May 2026, the auditor must deliver the report within 6 months of the period end. Later reports are due within 4 months of the end of the period covered.

Does the £100,000 audit exemption also remove the monthly return?

No. The exemption in SUP 3A.1.1R(2) applies only to the safeguarding audit. The monthly return in SUP 16.14A applies to all safeguarding institutions, and question 2 of the return asks whether the firm is exempt from the audit.

Does the safeguarding auditor have to be our statutory auditor?

No. SUP 3A.3.3G says the auditor appointed for the safeguarding audit does not have to be, but can be, the same auditor appointed for the statutory audit.

Which exchange rate is used for non-sterling balances in the monthly return?

The closing spot exchange rate for the day before the relevant date or reconciliation, as set out in the footnotes to the safeguarding return form.

Other rules

Sources

  1. SUP 16.14A Safeguarding return: safeguarding institutions · FCA Handbook
  2. SUP 3A.1 Application · FCA Handbook
  3. SUP 3A.3 Appointment of auditors · FCA Handbook
  4. SUP 3A.9 Duties of auditors: notification and safeguarding report · FCA Handbook
  5. SUP 3A.10 Review of auditor's safeguarding report · FCA Handbook
  6. CASS 15.7 Acknowledgement letters · FCA Handbook
  7. CASS 15.8 Records, accounts and reconciliations · FCA Handbook
  8. PS25/12: Changes to the safeguarding regime for payments and e-money firms (August 2025) · Financial Conduct Authority
  9. Safeguarding requirements for payment institutions and electronic (e-money) institutions (updated 7 May 2026) · Financial Conduct Authority

Know where all your money is.

Polynopsis gives cross-border payment teams one live position across every bank, payout partner, exchange and wallet, including money in flight, and warns before a corridor runs dry.