Regulator
Financial Conduct Authority
Legal basis
PSRs 2017 reg. 23 · EMRs 2011 reg. 20
FCA rules
CASS 15 · CASS 10A · SUP 3A · SUP 16.14A
In force
7 May 2026 (PS25/12)
Applies to
Payment and e-money institutions
CASS 15.8
Internal safeguarding reconciliation
Compare the safeguarding requirement from your own records with the funds you hold, at least once each reconciliation day.
✓
Client balances from your ledger compared with safeguarded funds every reconciliation day.
CASS 15.8
External safeguarding reconciliation
Check your records of safeguarded funds against statements from banks and custodians.
✓
Bank and custodian statements ingested automatically and matched line by line to your records.
CASS 15.8
Shortfalls and excesses
Find any shortfall or excess through the daily segregation comparison and correct it.
✓
Every gap valued, explained and routed for top-up or release, with the approval on record.
CASS 15
Reconciliation days
Reconcile on every day other than weekends, UK public holidays and days when relevant foreign markets are closed.
✓
A reconciliation calendar per currency, so no required day is missed and no extra day is counted.
CASS 15
Non-standard methods
If you use a non-standard internal reconciliation method, document how it still meets your obligations.
✓
Your method configured, versioned and documented, so the rationale travels with every run.
SUP 16.14A
Monthly safeguarding return
Submit REP027 through My FCA within 15 business days of each month end.
✓
Return figures assembled from the same reconciled daily data: requirement, methods, reconciliations, shortfalls and breaches.
CASS 10A
Resolution pack
Keep a resolution pack current and retrievable within 48 hours.
✓
Account schedules, safeguarding records and reconciliations kept current and exportable on request.
SUP 3A
Annual safeguarding audit
Arrange an annual audit of safeguarding compliance by a qualified auditor, unless exempt.
✓
Positions, breaks, approvals and rule versions ready for the auditor in one export.
CASS 15
FCA notifications
Notify the FCA without delay of events such as reconciliation failures or material shortfalls.
✓
Breaches flagged as they happen, with the evidence a notification needs.
Summary for orientation, not legal advice. Rule references as of November 2026.
07:00
Statements in
Statements from every bank and custodian holding safeguarded funds.
08:00
Internal reconciliation
Safeguarding requirement compared with the funds you hold.
09:00
External reconciliation
Your records matched to the statements, line by line.
10:00
Gaps corrected
Shortfalls topped up and excesses released, with approval.
11:00
Signed off
The day recorded for REP027, the resolution pack and the audit.
REP027 return
Monthly return figures, built from the daily data.
Monthly
My FCA
Resolution pack
Master document, account schedules and records, kept current.
48 hours
CASS 10A
Audit file
Every position, break and approval for the annual audit.
Annual
SUP 3A
Breach log
Shortfalls, failures and notifications, with cause and owner.
As they happen
CASS 15
From the field
The details that turn a clean month into a finding. Valurec handles each of them by rule.
Days that do not count
Weekends, UK holidays and closed foreign markets change what counts as a reconciliation day, per currency.
Insurance running out
A contingency plan is needed at least three months before a safeguarding insurance policy or guarantee expires.
When the obligation starts
Safeguarding begins once you are entitled to the funds, for example when they reach an account in your name.
Before
Safeguarding under PSRs reg. 23 and EMRs reg. 20, supported by FCA guidance.
Since May 2026
CASS 15 adds rules for daily reconciliations, a monthly return, a resolution pack and annual audits.
Next
The FCA has not taken the planned post-repeal regime forward without further consultation.
EU
PSD2 / PSD3 · EMD2
Segregation, timely safeguarding and evidence for national supervisors, ready for PSD3.
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
›
