CASS 15 - Safeguarding for Payment Services & E-Money Firms

Introduction

Following the FCA’s Policy Statement PS25/12 (August 2025), the new CASS 15 rules establish a strengthened safeguarding framework for Payment and E-Money Institutions. For the first time, the regulator is aligning safeguarding requirements with the CASS client money model, introducing explicit rules on reconciliations, record-keeping, governance, and audit reporting. The Supplementary Regime - coming into force on 7 May 2026 - requires daily internal and external reconciliations, independent safeguarding audits, new notification requirements, and formal resolution pack and monthly reporting obligations.

This virtual classroom seminar provides a practical roadmap for interpreting and implementing the final PS25/12 requirements, understanding how they differ from CP24/20, and ensuring firms are operationally ready for go-live. You will gain clear insight into supervisory expectations, implementation pitfalls, and how to evidence compliance across your safeguarding framework.

What You Will Learn

This live and interactive course will cover the following:

• Understand the key outcomes of FCA Policy Statement PS25/12 and how they differ from CP24/20
• The scope and application of CASS 15 under the Supplementary Regime - including which firms are in scope and the 7 May 2026 effective date
• How to structure internal and external reconciliations under the new rules and understand the concept of ‘reconciliation days’
• Notification and escalation duties under CASS 15.8.60, including when to report reconciliation failures or shortfalls to the FCA
• Design and maintenance of the new Safeguarding Resolution Pack (CASS 10A) - structure, content, and retrieval expectations
• Appointment and scope of the annual independent safeguarding audit (SUP 3A) - including the £100,000 exemption threshold
• Completion and submission of the new monthly safeguarding return (SUP 16.14A)
• Third-party risk management and diversification - how to perform due diligence and review frequency under CASS 15.6
• How to manage insurance or guarantee safeguarding methods - renewal timing, notification periods, and contingency planning
• Governance and oversight expectations - how to assign clear safeguarding responsibility to a senior manager (SMF16, SMF18 or equivalent), and evidence board-level ownership through MI and reporting
• How to plan and document an implementation roadmap covering gap analysis, change management, and transitional provisions
• Overview of the future Post-Repeal Regime and statutory trust model, and how firms can prepare for potential transition
• Common implementation pitfalls identified in PS25/12 and practical steps to evidence early compliance to the FCA

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.