FCA’s new CASS 15 rules take effect in May 2026, strengthening safeguarding for payment and e-money firms with a CASS-style framework.
The FCA has recently published its final policy statement (PS25/12), setting out a new safeguarding regime for payment and e-money institutions. The new CASS 15 rules will come into effect from 7 May 2026 and mark a significant step in strengthening consumer protection, operational resilience, and market integrity across the sector.
The changes address long-standing concerns about weak safeguarding practices by aligning payments and e-money firms more closely with the existing standards for investment firms under CASS.
The good news for firms
The FCA has shown a commitment to balancing regulatory objectives with real-world operational challenges.
The FCA has also clarified its cautious approach to the proposed Post-Repeal Regime, which would move towards a statutory trust model. Importantly, the regulator has confirmed that these changes will not be implemented without further consultation. Instead, the effectiveness of the Supplementary Regime will be reviewed after a full audit period before any decision is made.
Why this matters
The payments and e-money sector continues to grow rapidly, with £26bn of relevant funds safeguarded by e-money institutions in 2024. Weak safeguarding practices can put both consumers and the wider market at risk, with past failures resulting in average shortfalls of 65% of client funds. By moving to a more robust, CASS-style framework, the FCA aims to build trust, protect consumers, and create a level playing field across the sector.
For firms, this is more than just a compliance exercise. Early preparation for CASS 15 is an opportunity to strengthen governance, improve resilience, and demonstrate leadership in safeguarding best practice.
How Pangea Can Help
At Pangea Consulting, we specialise in helping firms translate regulatory change into effective operational practice. To support the industry in preparing for CASS 15, we are hosting a full-day, interactive workshop tailored for payment and e-money firms.
Date: 9th October 2025
Time: 9:30 AM – 4:30 PM
Location: City of London
Final thoughts
The transition to CASS 15 will require careful planning and investment in systems and controls, but with the FCA’s proportionate adjustments, firms now have the time and flexibility to get this right.
At Pangea, we believe the new regime is not just about compliance; it’s about embedding safeguarding as a foundation for growth, resilience, and consumer trust.
Join our workshop to ensure your firm is ready for the new safeguarding regime.
