FCA Safeguarding Reform 2026: What Payment & E-Money Firms Need to Know

Introduction

The Financial Conduct Authority has introduced a new safeguarding framework for payment and e-money firms through Policy Statement PS25/12.

For the first time, safeguarding requirements are being consolidated into a structured regulatory regime under CASS 15, introducing clearer expectations around governance, reconciliations, reporting and audit assurance.

From 7 May 2026, firms subject to the Supplementary Regime will need to operate enhanced safeguarding controls. These include safeguarding reconciliations, a Safeguarding Resolution Pack, independent safeguarding audits and new regulatory reporting obligations.

This session explains the regulatory changes introduced by the FCA, how the new framework differs from the existing safeguarding regime and what compliance and senior management teams should consider as firms prepare for implementation.

What you will learn

This live and interactive course will cover the following:

• Understanding the FCA’s safeguarding reform
• Why the FCA introduced the new safeguarding framework
• Key outcomes of Policy Statement PS25/12
• How the new regime differs from existing safeguarding requirements under the Payment Services Regulations and E-Money Regulations
• Firms in scope and the implementation timeline
• Introduction to the new CASS 15 framework
• Structure and purpose of CASS 15
• Core safeguarding principles and regulatory expectations
• How the safeguarding regime aligns with the wider CASS framework
• Interaction with payments regulation
• Relationship between safeguarding requirements and the Payment Services Regulations
• Relationship with the Electronic Money Regulations
• How the new framework aligns with existing regulatory obligations
• Governance and senior management accountability
• Board oversight of safeguarding arrangements
• Allocating responsibility within senior management
• Interaction with the Senior Managers and Certification Regime
• Designing management information to support oversight
• Reporting, notifications and regulatory oversight
• New safeguarding reporting requirements
• Regulatory notification obligations
• The independent safeguarding audit
• Supervisory expectations and common regulatory concerns
• Preparing for implementation
• Key implementation challenges for payment firms
• Designing an internal implementation roadmap
• Common pitfalls and supervisory risks

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.