CASS 15: Strengthening Safeguarding for Payment & E-Money Firm
A practical guide to preparing for the FCA’s new safeguarding regime.
Summary
CASS 15 marks a major shift in how payment and e-money firms are expected to safeguard customer funds. Effective from 7 May 2026, the new regime introduces a more structured, auditable, and governance-driven framework, raising expectations across reconciliations, record-keeping, segregation, reporting, and oversight.
For firms, the challenge is not just understanding the rules. It is making sure safeguarding works in practice day to day, with clear ownership, reliable data, strong controls, and evidence that stands up to scrutiny. This whitepaper is designed to help firms understand what is changing, where the biggest risks sit, and how to prioritise readiness in a practical way.
Key Insights :
Readiness Framework:
Alongside the key regulatory and practical insights, the whitepaper also sets out a Practical CASS 15 Readiness Framework to make CASS 15 manageable, firms should avoid treating it as a disconnected list of rule changes. A more effective approach is to structure readiness around four pillars.