Insights

CASS 15, introduced by FCA Policy Statement PS25/12 and in force since 7 May 2026, is not just a reporting requirement. It makes safeguarding a daily operational control discipline for payments and e-money firms, requiring regular internal and external reconciliation, comparison of the segregation requirement against the segregation resource, prompt correction of shortfalls, a resolution […]

Under the FCA’s CASS 15 safeguarding regime, in force since 7 May 2026, payments and e-money firms must identify relevant funds at any time without delay, reconcile what is owed to customers against what is held in safeguarding on each reconciliation day, and maintain a resolution pack. A unified ledger is the operational layer that