CASS 15 reconciliation and safeguarding control for payments and e-money firms
CASS 15 isn’t a reporting update. It’s an operating-model challenge and Imperium(L)'s Prism is built for it.
Since 7 May 2026, the FCA’s safeguarding Supplementary Regime requires payments and e-money firms to keep stronger books and records, reconcile safeguarding positions regularly, find discrepancies early, maintain a resolution pack, support a safeguarding audit and produce a monthly safeguarding return. If your team still runs this through spreadsheets, the work has fundamentally changed.
Prism gives firms a single operational control layer for relevant funds: see what you owe customers against what you hold in safeguarding, reconcile both sides daily, surface breaks as they happen and evidence every action taken.
What CASS 15 actually asks of firms
Under the FCA’s safeguarding regime, payments and e-money firms are expected to do the following, Prism is designed to support each one
- Maintain accurate books and records that distinguish relevant funds from other funds at any time, without delay.
- Reconcile regularly — internal reconciliations of what you owe against what you should hold, and external reconciliations against bank and third-party records, on each reconciliation day.
- Identify and remedy discrepancies early, topping up shortfalls so customer protection is maintained.
- Maintain a resolution pack so relevant funds can be returned to customers quickly if the firm fails.
- Support an annual safeguarding audit with the records and evidence an auditor needs.
- Produce a monthly safeguarding return for the FCA.
Most teams do not have a data problem in theory. The data exists. It is just spread across customer ledgers, bank portals, PSP exports, spreadsheets and the head of whoever ran the last reconciliation. Prism brings it together.
How Prism supports CASS 15
1. See relevant funds and safeguarding positions in one view
Prism gives teams a consolidated view of balances, customer records, safeguarded amounts, deposits, claims, refunds, banked funds and outstanding positions. Safeguarding control starts with visibility: knowing what you owe, what you hold and whether the two match.
2. Run internal and external reconciliation, daily
Prism reconciles both sides. Your customer ledger against safeguarding accounts (the internal reconciliation), and your internal records against bank statements and third-party data (the external reconciliation). Records can be ingested by file upload, structured templates or API. Breaks surface the same day, not three weeks later when someone opens the file.
3. Detect anomalies and work the exceptions that matter
Manual checking is slow, inconsistent and dependent on individual knowledge. Prism builds anomaly detection into the process, flagging issues such as negative funds in trust, movement of funds between bookings, claim-timing issues, duplicate records, agent-balance issues, multi-currency bookings and claims that breach configured thresholds the moment they appear.
4. Configure rules around the way your firm operates
No two payments firms operate the same way. Prism lets you configure business rules. This allows you to match key materiality thresholds, escalation logic and service-level expectations, around your own entities, currencies, banks and policies. Your control environment lives in the platform, not in someone’s head.
5. Generate monthly safeguarding return data and give leadership oversight
Prism generates the data behind the monthly safeguarding return from controlled reconciliation, supports internal review, approval and attestation, and exports it in a structured format. (Prism prepares and exports return data; it does not submit to the FCA on your behalf unless that is separately configured). Senior managers get a current view of safeguarding exposure through dashboards without waiting for the month-end pack.
6. Produce audit-ready evidence and sign-off
When an auditor, board member or the FCA asks how a break was handled, a folder of emails will not carry the weight. Prism records the trail automatically: every reconciliation, investigation, action and sign-off are captured, timestamped and attributable, with role-based access and multi-tier sign-off. When evidence is asked for, it is already there.
7. Resolve breaks with ownership and evidence
Finding a break is only half the job. Prism wraps each break in a structured resolution workflow — owner, severity, deadline, investigation, evidence gathering and sign-off — and tracks resolution-pack completeness against a mandatory-document checklist, so you can see at a glance what is still needed to make the pack whole.
Why a specialist platform, not a generic finance software
Generic finance tools help you reconcile a bank account. They are not built for the regulatory work that sits behind safeguarding — relevant funds, segregation, resolution packs, the safeguarding audit and the monthly return. Prism is. And it is built for the small and mid-sized firms that do not want the cost or procurement of an enterprise platform.
Latest CASS 15 Insights
CASS 15 isn't a reporting issue. It's an operational control challenge
The FCA’s new safeguarding regime comes with a deadline, a monthly return and an audit. Treat it as form-filling and you miss the point, and the risk.
May 2026 – Approx 8 minute read
CASS 15 created the deadline.
Prism is the control environment behind it.
If your firm still manages safeguarding through manual or semi-manual processes, see how Prism can strengthen reconciliation, evidence and reporting in a single view.
Frequently asked questions
What is CASS 15?
CASS 15 is the chapter of the FCA’s Client Assets Sourcebook that sets out the safeguarding rules for payments and e-money firms holding relevant funds. The supplementary safeguarding regime came into force on 7 May 2026 and requires stronger records, regular reconciliation, early discrepancy detection, a resolution pack, support for a safeguarding audit and a monthly safeguarding return.
What is CASS 15 reconciliation software?
It is software that helps payments or e-money firms reconcile what it owes customers against what it holds in safeguarding, both internally and against bank data, and evidence the result. Imperium(L) Prism does this daily, surfaces breaks as they happen and records an audit trail.
Does Prism support internal and external reconciliation?
Yes. Prism runs internal reconciliation of the customer ledger against safeguarding positions, and external reconciliation of internal records against bank statements and third-party data, on each reconciliation day.
Can Prism produce the monthly safeguarding return?
Prism generates the monthly safeguarding return data from controlled reconciliation, supports review, approval and attestation, and exports it in a structured format. It does not submit to the FCA on your behalf unless that is separately configured.
Does Prism help with the resolution pack and safeguarding audit?
Yes. Prism tracks resolution-pack completeness against a mandatory-document checklist and captures the timestamped evidence and sign-offs an auditor needs.
We are a small firm — is Prism too much?
Prism is designed for small to mid-sized firms. It can be tightly scoped to a firm with one or two safeguarding accounts and a single currency, and configured up as the firm grows.