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FCA Compliance for UK Payment Institutions 2026: Complete Guide

Published 8 August 2026 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. What ongoing FCA compliance means for a payment institution
  2. The compliance framework at a glance
  3. How obligations differ for APIs and SPIs
  4. Safeguarding under CASS 15
  5. The monthly safeguarding return and the annual audit
  6. Capital, liquidity and wind-down planning
  7. Governance and accountability
  8. Financial crime and fraud controls
  9. Consumer Duty and pricing transparency
  10. Payment conduct rules and strong customer authentication
  11. Operational resilience, incidents and outsourcing
  12. Complaints and the Financial Ombudsman Service
  13. Agents and distributors
  14. Regulatory reporting and notifications
  15. An annual compliance calendar
  16. Compliance monitoring that tests how the firm operates
  17. What the FCA looks for in supervision
  18. The reform agenda for payment institutions
  19. How Buckingham Capital Consulting helps
  20. Frequently asked questions
Key takeaways
  • CASS 15 safeguarding has applied since 7 May 2026: reconciliations at least once each reconciliation day and a REP027 return within 15 business days of each month end.
  • Authorised payment institutions holding customer funds need an annual safeguarding audit unless they have not safeguarded more than £100,000 in at least 53 weeks.
  • The FCA's March 2026 payments priorities replace more than 40 portfolio letters and focus on innovation, the Consumer Duty, financial system integrity and customers' money.
  • Own funds must stay at or above the higher of €20,000 to €125,000 initial capital and the Method A, B or C requirement.
  • New FCA operational incident and third-party reporting rules under PS26/2 apply from 18 March 2027.

What ongoing FCA compliance means for a payment institution

Authorisation is the start of supervision, not the end of the project. An authorised payment institution (API) must keep meeting the conditions it was authorised on, every day, under the Payment Services Regulations 2017 (the PSRs) and the FCA rules that apply to its status and services. A small payment institution (SPI) works under a lighter registration regime but must still meet the rules for the services it provides.

Three changes define 2026. The FCA's supplementary safeguarding rules in CASS 15 have applied since 7 May 2026, bringing a monthly safeguarding return and an annual safeguarding audit. The FCA's first annual Regulatory Priorities report for payments, published in March 2026, replaced more than 40 portfolio letters and sets four priorities for boards. And HM Treasury's consultation on modernising payment services regulation closed on 6 October 2026, opening the way for the detailed rules to move into the FCA Handbook.

The FCA's four priorities for payment firms in 2026 are:

  1. preparing for the future, to support competition, innovation and growth;
  2. implementing the Consumer Duty effectively;
  3. protecting the integrity of the financial system, including financial crime and operational resilience; and
  4. keeping customers' money safe, through safeguarding and financial resilience.

The compliance framework at a glance

Compliance mapping starts with the PSRs and the FCA's Payment Services and Electronic Money Approach Document, which was updated alongside the safeguarding rules on 7 May 2026. Not every Handbook sourcebook applies to a payment institution as it would to an investment firm, so each obligation should be traced to its legal source.

AreaMain sourceWhat it requires
Authorisation conditions and conductPSRs 2017Governance, controls, capital, safeguarding, information and execution rules
SafeguardingPSRs regulation 23, CASS 15, CASS 10ASegregation, reconciliations, records, resolution pack
Safeguarding auditSUP 3AAnnual external audit above £100,000 safeguarded
Regulatory returnsSUP 16Capital, fraud, operational risk and monthly safeguarding returns
Consumer outcomesConsumer Duty (PRIN 2A)Good outcomes for retail customers, annual board report
Financial crimeMoney Laundering Regulations 2017Risk-based anti-money laundering, sanctions and fraud controls
Operational resilienceSYSC 15AImportant business services, impact tolerances, testing
ComplaintsDISPPayment services deadlines and Financial Ombudsman Service access
Authentication and securityPSRs and FCA technical standardsStrong customer authentication and incident reporting

How obligations differ for APIs and SPIs

Most of this guide applies to both authorised and small payment institutions, but the prudential and safeguarding obligations differ. A small payment institution that grows towards the €3 million monthly average must apply for authorisation within 30 days of becoming aware it no longer meets the conditions, so its compliance programme should be built with the authorised regime in view.

ObligationAuthorised payment institutionSmall payment institution
Initial capital and own fundsRequiredNot required
Safeguarding under CASS 15Mandatory where it holds customer fundsOptional; full rules apply once elected
Safeguarding auditAnnual, above £100,000Only if it safeguards and is above the threshold
Fraud return (REP017)Half-yearlyTwo half-year reports, filed annually
Transactions reportCapital adequacy return (FSA056)FSA057, by the end of January
Financial crime, Consumer Duty, complaintsApply in fullApply in full

Safeguarding under CASS 15

Safeguarding protects customers if a payment firm becomes insolvent, and it is the FCA's fourth priority for 2026. The FCA estimates that payment institutions safeguarded around £6 billion a day in 2024. An API that receives funds for payment transactions must comply with regulation 23 of the PSRs and CASS 15; an SPI may elect to safeguard and then follows the same rules.

What the rules require

  • Relevant funds identified correctly. Safeguarding starts when the firm receives the funds, often when they are credited to an account in its name, and the methodology should trace each money flow from receipt to the point the firm's obligation ends.
  • Segregation or insurance. Funds are held in a designated safeguarding account, invested in secure liquid assets, or covered by an insurance policy or guarantee, with acknowledgement letters from each bank.
  • Reconciliations. Internal and external reconciliations at least once each reconciliation day, which excludes weekends, bank holidays and days when the relevant foreign markets are closed.
  • Third-party due diligence. Documented assessment of each bank, custodian or insurer that holds or protects relevant funds, repeated periodically.
  • Resolution pack. Up-to-date records that would let an insolvency practitioner return funds quickly, kept under CASS 10A.
  • Responsibility. A single director or senior manager of sufficient skill and authority is responsible for safeguarding compliance and reports to the board.

Safeguarding governance

The board approves the safeguarding policy and the choice of safeguarding banks and auditor, and receives regular management information: the safeguarding requirement against funds held, reconciliation breaks and how long they took to clear, unidentified receipts, and any breach. Material breaches are notified to the FCA promptly, and a small payment institution that starts or stops safeguarding notifies the FCA using the SUP 15 form.

Reconciliations that stand up to audit

A reconciliation should establish independently what the firm owes customers and compare it with what is held in safeguarding. Any shortfall is investigated, corrected and documented, never adjusted manually to force agreement. Recurring breaks and their root causes go to the board. Safeheld, the firm's own safeguarding platform, is built to run these reconciliations and prepare the monthly return for payment and e-money firms.

Our article on what payment firms must be doing now that CASS 15 is in force sets out the operating model in detail.

The monthly safeguarding return and the annual audit

Monthly safeguarding return (REP027)

Every safeguarding institution submits the REP027 safeguarding return through the FCA's reporting system within 15 business days of the end of each calendar month, under SUP 16.14A. A firm does not file for the month in which it first becomes a safeguarding institution. Each data item should be traceable to the same records used for daily reconciliations, with an owner, a documented derivation and review before submission.

Annual safeguarding audit (SUP 3A)

Authorised payment institutions that hold customer funds appoint an external auditor to report to the FCA each year on their safeguarding. The audit is a reasonable assurance engagement: the auditor reports on whether the firm's systems were adequate throughout the period and whether it complied at the period end, and lists individual breaches.

PointRule
Who must be auditedAPIs holding relevant funds and all EMIs, unless exempt
ExemptionNot required to safeguard more than £100,000 at any time in at least 53 weeks
Period coveredEnds no more than 53 weeks after the previous period
First report dueWithin 6 months of the end of the first audit period
Later reports dueWithin 4 months of each period end

The safeguarding audit is separate from the statutory accounts audit, although the same firm can carry out both. Senior management must check on a continuing basis whether an exempt firm has moved above the threshold. The FCA said in its 2026 priorities that it expects a short-term rise in adverse audit opinions as the new rules bed in, so findings should be tracked, remediated and retested.

Capital, liquidity and wind-down planning

An API must hold own funds at all times at or above the higher of its initial capital (€20,000, €50,000 or €125,000 depending on its services) and the requirement calculated under Method A, B or C of Schedule 3 to the PSRs. The FCA can direct an amount up to 20% higher or lower. Firms that provide only payment initiation or account information services hold their initial capital only.

The FCA expects more than a capital formula. Its good and poor practice findings on risk management and wind-down planning, and its 2026 priorities, note that some firms have underdeveloped risk frameworks and wind-down plans. Boards should know which events could make the firm unviable, how much capital and cash it would need to keep operating or to close in an orderly way, and which early warning indicators trigger action.

  • Monitor own funds against the requirement monthly, with escalation triggers set in advance.
  • Link forecasts to capital and liquidity, including scenarios such as the loss of a banking partner.
  • Maintain a wind-down plan that shows how customer funds are returned and critical services handed over.

Governance and accountability

Payment institutions are not under the senior managers and certification regime (SM&CR), which applies to firms with permissions under the Financial Services and Markets Act 2000 (FSMA). A payment institution that also holds FSMA permissions, such as consumer credit, follows SM&CR for that business. The FCA assesses the directors and managers of a payment institution through the PSD Individual form, and they must remain of good repute and suitably experienced.

The absence of SM&CR does not reduce what the FCA expects. Clear individual ownership of compliance, safeguarding, financial crime, risk and operations should be written down, and board minutes and management information should show real oversight, challenge and follow-through. HM Treasury's July 2026 consultation asked whether enhanced senior manager accountability should be introduced at payment and e-money firms, so firms should expect this area to develop.

  • Allocate safeguarding responsibility to one director or senior manager, as CASS 15 requires.
  • Assess the fitness and propriety of key individuals at least annually.
  • Give the MLRO and compliance officer the authority, time and resources the role needs.
  • Notify the FCA of changes to directors, managers and controllers, and obtain approval before anyone acquires 10% or more.

Financial crime and fraud controls

Payment institutions sit in the movement of funds, so they face money laundering, fraud, sanctions evasion and money mule risk. The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (the MLRs) apply in full, and protecting the integrity of the financial system is the FCA's third priority for 2026. The FCA also reports that payment firm applications it did not approve most often showed gaps in senior manager competence and in systems and controls, including financial crime controls.

The core framework

  • A business-wide risk assessment covering customers, products, countries, channels and flows, refreshed when the business changes.
  • Customer due diligence, beneficial ownership checks and enhanced due diligence for higher-risk customers and countries.
  • Sanctions screening of customers and payments.
  • Transaction monitoring calibrated to the firm's own flows: remittance corridors, merchant acquiring, payment accounts and business payments each need different scenarios and thresholds.
  • Suspicious activity reporting through the money laundering reporting officer (MLRO) to the National Crime Agency, and an annual MLRO report to the board.
  • Payer and payee information carried with transfers, as the funds transfer rules require.

Fraud and money mules

Fraud and anti-money laundering overlap in payments: an account that receives the proceeds of authorised push payment (APP) fraud becomes a money laundering concern as soon as the funds move on. Fraud and financial crime teams should share intelligence, and onboarding data, device data, linked beneficiaries and transaction velocity should feed mule detection. Firms that send Faster Payments reimburse APP fraud victims under the mandatory scheme in force since 7 October 2024, up to £85,000 per claim, with the cost shared between the sending and receiving firms. The law also allows a firm to delay an outbound payment by up to 72 hours where it has reasonable grounds to suspect APP fraud.

Our guide to payment institution financial crime controls covers transaction monitoring in depth.

Consumer Duty and pricing transparency

The Consumer Duty applies to payment services provided to retail customers. It requires good outcomes in four areas: products and services, price and value, consumer understanding and consumer support. The FCA's 2026 priorities focus on two Duty topics for payment firms: transparency of international payment pricing and the treatment of customers in vulnerable circumstances.

International payments and foreign exchange

Cross-border firms earn through explicit fees and through the margin within the exchange rate. The FCA's good and poor practice findings on international payment cost communication look at whether customers understand the total cost, not only whether fees appear somewhere in the terms. Reviews should cover how rates are presented, which reference rate is used for comparison and whether claims such as "zero fee" are accurate when revenue sits within the rate.

Evidence, not statements

Outcomes are affected by fees, exchange rates, rejected payments, fraud handling, account restrictions, complaints and support. Monitoring should use operational data, and the annual board assessment should show differences in outcomes by customer group, product or channel, and the action taken. Business customers outside the Duty are still covered by the PSRs' information and contract requirements. Our article on implementing the Consumer Duty in payment and e-money firms explains the evidence the FCA expects.

Payment conduct rules and strong customer authentication

The PSRs contain detailed conduct rules: information before and after a payment, consent, execution times, value dating, charges, refunds and liability for unauthorised and incorrectly executed payments. These should be mapped to the real customer journey so that each screen, notification and process can be traced to the rule it meets.

RulePSRs referenceWhat it requires
Execution timeRegulation 86Funds reach the payee's provider by the end of the next business day for sterling and euro payments in the UK
Unauthorised paymentsRegulation 76Refund by the end of the business day after the firm becomes aware, unless fraud is suspected
Customer liabilityRegulation 77Capped at £35 for lost or stolen instruments, unless the customer acted fraudulently or with gross negligence
Notification by the customerRegulation 74Within 13 months of the debit date for unauthorised or incorrect payments

Under the framework contract rules, a firm closing a payment account must give the customer at least 90 days' notice and explain the reason, subject to limited exceptions such as financial crime concerns. Account restrictions and closures are a frequent source of complaints, so the decision process and the customer communication should both be documented.

Strong customer authentication (two independent checks, such as a device and a fingerprint) applies to electronic payments and account access. Firms should understand when it applies and when an exemption, such as transaction risk analysis, is available, and use an exemption only where its conditions are met. The Government has committed to revoking the technical standards in the PSRs so the FCA can set outcomes-based authentication rules, but the current rules apply until they change.

Operational resilience, incidents and outsourcing

Payment services depend on banks, processors, card platforms, cloud providers and identity verification vendors. The FCA's operational resilience rules in SYSC 15A have applied in full since 31 March 2025: firms identify their important business services, set impact tolerances (the maximum disruption they will accept), map the people, processes and suppliers behind each service, and test severe but plausible scenarios.

Incident and third-party reporting from 18 March 2027

The FCA's PS26/2, published on 18 March 2026, introduces single operational incident reporting and material third-party reporting from 18 March 2027. Payment service providers fall within the incident regime, and authorised payment institutions within the third-party regime: they notify the FCA of new or significantly changed material third-party arrangements and submit an annual register. Until then, the existing PSRs duty to report major operational or security incidents continues, and 2026 is the year to map processes and data for the new regime.

Outsourcing

Outsourcing an important operational function does not transfer responsibility. Due diligence, contracts, oversight and exit plans should match the dependency, sub-outsourcing and concentration on one provider should be mapped, and contracts should give the firm, its auditors and the FCA access. A material change to an important outsourcing arrangement must be notified to the FCA in advance.

Complaints and the Financial Ombudsman Service

Payment institutions handle complaints under the FCA's dispute resolution rules (DISP). For payment services complaints, the firm sends a final response within 15 business days, or up to 35 business days in exceptional circumstances with a holding reply, and eligible complainants can refer the complaint to the Financial Ombudsman Service. The FCA reports that complaints to the Ombudsman about payment firms fell by 9% between 2024 and 2025.

Complaints are regulatory intelligence. Root-cause analysis should test whether one complaint reveals a process affecting many customers, and complaint data should be read alongside incident, fraud and Consumer Duty information. New FCA complaints reporting rules (PS25/19, published on 3 December 2025) apply from 1 January 2027, with the first reporting period running from 1 January to 30 June 2027.

Agents and distributors

A payment institution can provide services through agents registered with the FCA, and remains responsible for everything they do. Each agent needs due diligence on ownership, management, competence and financial crime risk before it is registered, and can act only within its registered scope.

  • Monitor complaints, transaction patterns, due diligence quality and financial promotions for each agent.
  • Train agents and keep access to the records they hold.
  • Match compliance resources to the size of the network, and restrict or end relationships where standards are not met.
  • Notify the FCA when agents are added or removed.

Regulatory reporting and notifications

The FCA uses regulatory data to target supervision, so late, inaccurate or repeatedly corrected returns draw attention. A regulatory obligations register should record every return, its owner, its source data and its internal review. Our guide to FCA regulatory reporting for payment and e-money firms covers each return in detail.

ReturnApplies toTiming
REP027 safeguarding returnSafeguarding institutionsMonthly, within 15 business days
REP017 payment fraud reportAPIsHalf-yearly, within 2 months of each period end
REP018 operational and security risk reportAll payment service providersAt least annually
FSA056 capital adequacy returnAPIsAnnually
Annual financial returnAPIs and SPIsAnnually
FSA057 payment transactions reportSPIsAnnually, by the end of January
Payment services complaints returnPayment service providersUnder DISP 1.10B

Event-driven notifications matter as much as scheduled returns: major incidents, safeguarding breaches, material changes to the business or to important outsourcing, and anything that could affect the authorisation conditions should be escalated and notified promptly.

An annual compliance calendar

ActivityFrequencyOwner
Safeguarding reconciliationsEach reconciliation dayFinance and operations
Own funds and liquidity monitoringMonthly, and continuouslyFinance lead
Safeguarding returnMonthlySafeguarding director
Board compliance and risk reportingQuarterlyCompliance officer
Fraud returnHalf-yearlyFraud lead
Safeguarding auditAnnually, unless exemptSafeguarding director
MLRO annual report and risk assessment reviewAnnuallyMLRO
Consumer Duty board reportAnnuallyBoard
Operational resilience self-assessment and testingAnnuallyOperations lead
Wind-down plan reviewAnnuallyBoard

Compliance monitoring that tests how the firm operates

An annual policy review does not show whether controls work. A monitoring programme should test the areas that matter most at a frequency matched to the risk: safeguarding, financial crime, Consumer Duty, payment conduct, complaints, agents, outsourcing, resilience, reporting and capital.

  • Re-perform a sample of safeguarding reconciliations from source data.
  • Sample transaction monitoring alerts and sanctions hits for quality and timeliness.
  • Trace complaints to root causes and check that fixes were made.
  • Reconcile a return to the systems it was built from.
  • Retest remediated findings and report to the board whether risk has reduced.

Firms that are growing should also test whether their permissions still match the business. Adding a service or a new type of payment flow may need a variation of permission before launch.

What the FCA looks for in supervision

Supervisory reviews of payment firms concentrate on a small number of areas, and the evidence the FCA asks for is predictable. A firm that can produce it on request is in a strong position.

  • Safeguarding: reconciliation records for any chosen day, acknowledgement letters for every safeguarding account, the relevant funds methodology and the current resolution pack.
  • Financial crime: a business-wide risk assessment dated within the last year, alert volumes and ageing, sanctions screening evidence and the MLRO's annual report.
  • Reporting: returns filed on time and reconciled to source systems, with few corrections.
  • Notifications: material changes, incidents and breaches notified when they happened, not discovered later.
  • Consumer Duty: outcome data, the annual board report and the action taken on it.
  • Financial resilience: own funds headroom, liquidity forecasts and a wind-down plan the board has reviewed.

Where the FCA has concerns it uses a graduated set of tools: written feedback with remediation expectations, information requests, requirements such as restrictions on onboarding higher-risk customers, and reviews by an independent skilled person at the firm's cost. Early, open engagement and a credible remediation plan, owned by a named director and tracked to completion, keep matters within normal supervision.

The reform agenda for payment institutions

HM Treasury consulted from 14 July to 6 October 2026 on modernising payment services regulation. It proposes moving detailed technical requirements from the PSRs and the Electronic Money Regulations into FCA rules, restructuring the list of payment activities, bringing UK-issued stablecoins used for payments into the payments regime, and asking how authentication and liability should work for payments made by AI agents. The changes will be made through secondary legislation, with implementation details to follow the consultation.

The Payment Systems Regulator's functions are also being consolidated into the FCA, ahead of legislation where possible. Until the new framework is in place, the current PSRs and FCA rules apply in full, and compliance teams should keep proposals separate from live obligations in their regulatory change log.

How Buckingham Capital Consulting helps

The firm supports authorised and small payment institutions across the full compliance programme: CASS 15 safeguarding and audit readiness, regulatory returns, financial crime frameworks, Consumer Duty evidence, operational resilience, governance and board reporting, agents and outsourcing. It also supports remediation after FCA engagement or audit findings, and advises when growth needs a variation of permission. Details are on our regulatory compliance page and our safeguarding page.

Frequently asked questions

What regulations apply to a UK payment institution?

The Payment Services Regulations 2017 are the core framework, supported by the FCA's Approach Document and the Handbook rules that apply to payment firms: CASS 15, SUP 3A, SUP 16, the Consumer Duty, DISP and SYSC 15A. The Money Laundering Regulations 2017 apply to financial crime.

What changed for payment institutions on 7 May 2026?

The CASS 15 safeguarding rules came into force. Firms now reconcile at least once each reconciliation day, file a monthly REP027 safeguarding return and, above £100,000 safeguarded, obtain an annual safeguarding audit.

Do payment institutions need an annual safeguarding audit?

Yes, where an authorised payment institution holds customer funds. A firm is exempt if it has not been required to safeguard more than £100,000 at any time in at least 53 weeks; the first report is due within 6 months of the period end and later reports within 4 months.

Are payment institutions under SM&CR?

No. The senior managers and certification regime applies to firms with FSMA permissions, not to payment institutions authorised under the PSRs. A payment institution that also holds FSMA permissions follows SM&CR for that business.

Does the Consumer Duty apply to payment institutions?

Yes, to payment services provided to retail customers. The FCA's 2026 focus for payment firms is the transparency of international payment pricing and the treatment of vulnerable customers.

How much capital must an authorised payment institution hold?

Own funds at all times at or above the higher of its initial capital (€20,000, €50,000 or €125,000 depending on services) and the amount calculated under Method A, B or C. The FCA can adjust the result by up to 20%.

How often should a payment institution review its compliance?

Continuously, through a risk-based monitoring programme, with annual reviews of the financial crime risk assessment, Consumer Duty outcomes, operational resilience and the wind-down plan. Testing should increase when products, volumes, agents or risks change.

When do the new incident and third-party reporting rules apply?

From 18 March 2027, under FCA PS26/2. Authorised payment institutions will notify material third-party arrangements and submit an annual register, alongside the new operational incident reports.

References

  1. FCA: Regulatory priorities, payments (March 2026)
  2. FCA: Safeguarding requirements for payment institutions and e-money institutions
  3. FCA Handbook SUP 3A: Safeguarding audit
  4. FCA Handbook SUP 16.14A: Safeguarding return
  5. The Payment Services Regulations 2017 (legislation.gov.uk)
  6. FCA PS26/2: Operational incident and third party reporting
  7. FCA PS25/12: Changes to the safeguarding regime for payments and e-money firms
  8. HM Treasury: Modernising payment services regulation (consultation, July 2026)

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained FCA payment institution licences for firms including Nexpay, Orbital, Oval and Global Send since 2013. It supports payment institutions after authorisation with CASS 15 safeguarding, regulatory reporting, financial crime controls and Consumer Duty evidence.

Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or info@buckinghamcapitalconsulting.co.uk.

This article is general information, reviewed against the regulator’s published requirements on the date shown. It is not legal advice; the regulator’s current publications take precedence.