The FCA’s new CASS 15 regime will push payments and e-money firms toward stricter safeguarding controls, daily reconciliations, and fully auditable operations from May 2026.
Payments and e-money firms in the UK are entering a new phase of safeguarding under CASS 15, a significantly more structured and prescriptive regime introduced by the FCA. Effective from May 2026, the framework responds directly to past industry failures, where weak governance, poor reconciliations, and inadequate record-keeping led to major shortfalls and delays in returning customer funds. By introducing clearer accountability, daily reconciliations, enhanced segregation, and mandatory audits, CASS 15 shifts safeguarding from a principles-based exercise to a fully auditable operating model, aligning the sector more closely with investment firm standards.
While the transition will bring increased cost and operational pressure, it also represents a strategic opportunity for firms to strengthen trust, improve resilience, and mature their internal control environments. Firms that invest early in governance, systems, and data integrity will be better positioned not only for regulatory scrutiny but also for long-term growth in an increasingly regulated and competitive market.
👉 To explore the full regulatory context, key challenges, implementation roadmap, and a practical readiness framework, read the full whitepaper.
