As the FCA’s new CASS 15 safeguarding rules come into force on 7 May 2026, Electronic Money Institutions (EMIs) are entering a period of enhanced regulatory scrutiny.
The changes reflect the FCA’s response to years of shortfalls in Anti Money Laundering and safeguarding procedures across authorised payments and e‑money firms, which could put customers at risk of suffering a material loss.
For CEOs, this transition is not simply a compliance uplift. It’s a board‑level transformation in governance processes and operational resilience placing customer protection firmly on the agenda.
Based on our specialist experience of working with EMIs, and our insight into CASS 15, here are the top five questions that CEOs should be asking at board level.
Governance & Strategic Readiness
The FCA has highlighted recurring weaknesses in governance frameworks via PS25/12, leading to the setting of new expectations around leadership accountability. Under CASS 15, EMIs must be able to evidence compliance and not simply comply: not documented means not done!
Key board question #1:
Have we completed a formal CASS 15 gap analysis, and have we made a roadmap + timeline to ensure we’re ready by May?
Firms are expected to perform a full and comprehensive gap assessment immediately and ensure that team members understand their responsibilities.
Books, Records & the New Standard of Daily Reconciliations
One of the most fundamental operational shifts under CASS 15 is the requirement for daily reconciliations, both internal and external. EMIs must also maintain stronger books and records. This will ensure that safeguarding liabilities and funds can immediately be identified at any point in time, as well as allowing effective completion of regulatory returns.
Key board question #2:
Are our systems capable of producing complete, accurate daily reconciliations that minimise manual intervention, and can we show evidence of consistent accuracy?
Alongside accurate data, there is a focus on people and processes: how much of the process is automated, and where are manual tasks within this that could be prone to human error.
Safeguarding Under a Statutory Trust
CASS 15 introduces the requirement for statutory trust arrangements over all relevant funds. This is to clearly and legally ringfence client accounts, protecting them from insolvency procedures or lengthy court procedures.
Key board question #3:
Have all safeguarding arrangements been put in place over all relevant funds that meet statutory trust requirements?
The statutory trust represents more than a mere legal technicality: it’s the cornerstone for faster, more predictable customer recoveries.
People, Training & Culture
CASS 15 isn’t only operational: it covers finance, treasury, risk, technology, customer service, legal, and compliance monitoring. All relevant staff are expected to be able to demonstrate an understanding of your firm’s safeguarding processes.
Key board question #4:
Have we set aside enough budget to train and hire the right calibre of staff to ensure understanding of the new safeguarding rules, escalation procedures, and their personal responsibilities?
The FCA’s direction is clear: safeguarding must become part of your organisational culture, not just a compliance checklist.
Operational Resilience & Failure Scenario Preparedness
Under the principles of CASS 15, safeguarding isn’t about preventing failure: it’s for ensuring an orderly return of customer funds if failure occurs. Insolvencies in the past have shown that a lack of documentation, unclear processes, and defective reconciliations can turn the return of customer funds into a years-long process.
Key board question #5:
If our firm failed tomorrow, could we, or a liquidator, identify and return customer funds quickly without undue delay in accordance with CASS 15?
Your board should challenge relevant management to conduct “reverse stress tests” of your wind‑down plans. This is not theoretical and should be fully documented and concluded on.
Getting ahead between now and May
CASS 15 is the most significant change to safeguarding rules in the UK payments and electronic money sector in more than a decade. Over that period, both volume of transactions and funds safeguarded by relevant firms have increased dramatically. These new rules aim to reduce the risk of insolvency‑related harm to customers and impose the governance standards already seen elsewhere in other areas of the financial services industry.
Over the next several weeks, CEOs have a narrow window to make sure that their safeguarding frameworks will be in a position to meet the FCA’s new level of expectations.
The firms that will thrive in this new environment are those whose boards are asking the right questions now, well before the rules come into action.
