The Financial Conduct Authority's CASS 15 safeguarding rules entered force on 7 May 2026. The new regime replaces high-level principles-based guidance with prescriptive operational requirements for all authorized payment institutions and e-money firms. Every authorized firm must now reconcile safeguarded customer funds on every business day, with no variation permitted.
Firms holding more than GBP 100,000 in relevant funds over a 53-week rolling period must commission an annual independent audit of their safeguarding arrangements. Institutions with existing third-party safeguarding appointments at banks or custodians must review those arrangements within three months of the rules taking effect. The regime also introduces mandatory resolution packs, requiring firms to maintain documentation sufficient for an insolvency practitioner to return customer funds within a reasonable period.
The first regulatory return under the new framework is due in July 2026. Small e-money institutions and credit unions issuing e-money fall within scope alongside larger authorized firms. The rules form part of the broader consolidation of UK payment regulation under the FCA, following HM Treasury's April 2026 confirmation that the Payment Systems Regulator will be absorbed into the FCA.