Supervisor
National competent authority in each member state
Legal basis
PSD2 Art. 10 · EMD2 Art. 7
Methods
Segregation, or insurance and comparable guarantees
Next
PSD3 and the PSR, publication expected end of 2026
Applies to
Payment and e-money institutions
PSD2 Art. 10
Segregation
Keep client funds apart from the funds of anyone else, and protected from other creditors in insolvency.
✓
Client funds reconciled daily against segregated accounts, with own-fund movements flagged.
PSD2 Art. 10
Timely safeguarding
Funds still held at the end of the business day after receipt go to a separate account or into secure, liquid, low-risk assets.
✓
Funds received but not yet safeguarded, aged by business day until they are.
PSD2 Art. 10
Insurance or guarantee
As an alternative to segregation, cover the funds with an insurance policy or comparable guarantee.
✓
Segregated and insured funds in one position, with cover limits and expiry dates tracked.
EMD2 Art. 7
E-money funds
Funds received for e-money are safeguarded the same way. Card-funded e-money has up to five business days.
✓
Card-funded and other e-money tracked against their own deadlines.
National rules
Supervisory evidence
Show your national competent authority how funds are safeguarded and reconciled.
✓
Daily positions, breaks and approvals kept and exportable per entity and member state.
PSD3
Concentration risk
Consider concentration risk rather than holding every safeguarded euro with one institution.
✓
Safeguarded funds shown per institution and method, so concentration is visible.
Summary for orientation, not legal advice. Rule references as of November 2026.
07:00
Statements in
Statements from every safeguarding bank and partner, per entity.
08:00
Funds reconciled
Client balances against segregated accounts and cover.
09:00
Deadlines checked
Funds not yet safeguarded checked against their business-day deadline.
10:00
Transfers approved
Transfers into safeguarding accounts prepared and approved.
11:00
Signed off
The day stored for supervisors and auditors.
Daily position
Client funds, safeguarded funds and items in transit, per entity.
Daily
Per entity
Safeguarding description
How funds are safeguarded, matching your actual accounts.
Supervisor
Authorisation
Concentration view
Safeguarded funds per institution and method.
PSD3
Per bank
Audit file
Positions, breaks and approvals for auditors.
Annual
Export
From the field
The details that turn a clean month into a finding. Valurec handles each of them by rule.
Counting business days
The deadline runs from the business day after receipt, and holidays differ across member states.
Card-funded e-money
Card payments have a longer window, which is easy to mix up with other flows.
One bank for everything
Holding all safeguarded funds with a single bank becomes a formal concentration risk under PSD3.
One regime
PSD2 and EMD2 safeguarding rules merge into one regime for payment and e-money institutions.
Next business day
E-money institutions also safeguard by the end of the business day after receipt.
More methods
Central bank deposits and settlement accounts in designated payment systems can count as safeguarding.
Disclosure
Users are told how their funds are safeguarded.
UK
FCA CASS 15
Daily reconciliations, the monthly REP027 return, the resolution pack and the annual audit.
Learn more
›
TR
CBRT · Law No. 6493
Separate safeguarding accounts, daily customer-level reconciliation and collateral at the CBRT.
Learn more
›
ALL
Safeguarding Reconciliation
The overview across every regime and entity.
See the overview
›
