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FCA Safeguarding Reconciliations 2026: Internal and External Reconciliation Requirements Explained

Published 21 July 2026 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. What a safeguarding reconciliation is
  2. Internal and external reconciliations at a glance
  3. The internal safeguarding reconciliation
  4. The external safeguarding reconciliation
  5. How often reconciliations must be performed
  6. Calculating the safeguarding requirement correctly
  7. Separate reconciliations for e-money and payment services
  8. What happens when a reconciliation shows a shortfall
  9. Handling reconciliation discrepancies
  10. Controlling timing differences
  11. Manual and automated reconciliations
  12. Connecting reconciliations to REP027, the audit and the resolution pack
  13. Common reconciliation weaknesses
  14. What firms should test now
  15. Why reconciliations matter more to the FCA now
  16. Frequently asked questions
Key takeaways
  • CASS 15 requires internal and external safeguarding reconciliations as often as necessary and at least once on each reconciliation day.
  • The internal reconciliation must use the firm's own records, not bank statements; the external one compares balances currency by currency with each bank's latest statement.
  • A shortfall must be paid in as soon as possible and in any case by the end of the day the reconciliation is performed, from the firm's own funds if needed (CASS 15.8.50R and 15.8.51R).
  • EMIs with unrelated payment services must reconcile the e-money pool and the payment services pool separately.
  • CASS 15.8.60R lists six events that must be notified to the FCA in writing without delay, including a material safeguarding difference in the preceding 12 months.
  • Each reconciliation's time, date, actions and outcome must be recorded and kept for five years.

What a safeguarding reconciliation is

A safeguarding reconciliation is the daily check by which a payment institution or e-money institution proves that the customer money it must protect is correctly recorded and actually held in protected form. Safeguarding means keeping customer money separate from the firm's own money so it can be returned if the firm becomes insolvent. Since 7 May 2026, CASS 15 of the FCA Handbook has set detailed rules for how that check is done.

CASS 15 requires two separate processes. The internal reconciliation tests the firm's own records and calculations. The external reconciliation compares those records with what the banks, custodians and other third parties that hold the money say they hold. They serve different purposes and one cannot stand in for the other. Together they reveal shortfalls, excesses, record-keeping errors and gaps between what the firm believes it holds and what is really there. The detailed rules are in CASS 15.8 of the FCA Handbook.

Internal and external reconciliations at a glance

PointInternal reconciliationExternal reconciliation
Question it answersDoes the safeguarding resource match the safeguarding requirement?Do the firm's records agree with what banks and custodians hold?
Data usedThe firm's own ledgers, payment records and accountsBank statements, custodian statements and confirmations
Minimum frequencyAt least once each reconciliation day (CASS 15.8.19R)As often as necessary and at least once each reconciliation day (CASS 15.8.42R)
What is comparedRequirement and resource; D+1 segregation requirement and resourceBalances currency by currency; asset quantities investment by investment
On a differenceFind the reason; pay in a shortfall by the end of the day; withdraw an excess (CASS 15.8.50R)Investigate and resolve without undue delay (CASS 15.8.56R)

The central point is independence. A firm cannot prove its arrangements are right by looking at its safeguarding bank balance alone. It must first work out, from its own records, how much it should be holding, and then check that figure against independent third-party data.

The internal safeguarding reconciliation

The internal reconciliation tests whether the firm's own records show the correct amount of customer money protected. The firm calculates its safeguarding requirement, meaning the relevant funds it should be safeguarding, and compares it with its safeguarding resource, the amount its records show as held in safeguarding accounts or relevant assets. Relevant funds are the sums received in exchange for e-money and the sums received from or for customers, or from other payment providers, to carry out payment transactions.

CASS 15.8.15R requires the calculation to use the firm's internal records, not the figures in bank statements. Using the bank balance both to calculate the requirement and to confirm what is held removes the independence of the check and can hide record-keeping errors. The firm needs records showing what each customer is owed and how those individual balances add up to the total requirement.

The D+1 segregation comparison

As part of the internal reconciliation, the firm compares its D+1 segregation requirement with its D+1 segregation resource. The requirement is the amount of relevant funds that should be held in safeguarding accounts, or as relevant assets, at that point; D+1 refers to the legal deadline of the end of the business day after receipt for placing funds in a safeguarding account. The resource is the amount actually held there. CASS 15.8.13R allows a firm to skip part of this test where all relevant funds were already in a safeguarding account or invested in relevant assets before the last internal reconciliation.

Firms using insurance or a guarantee

A firm whose relevant funds are covered by an insurance policy or guarantee that is unlimited in amount does not need to perform an internal reconciliation, but must calculate its safeguarding requirement daily (CASS 15.8.11R). Insurance policies and guarantees are not subject to the external reconciliation.

Non-standard methods

Where the standard internal method does not suit the business, a firm can use a non-standard method under CASS 15.8.36R to 15.8.38R. Before using it, the firm must document its reasons in writing and obtain a written report from an independent auditor, under a reasonable assurance engagement, confirming the method meets its obligations. A material change to the method needs fresh reasons and a new report.

The external safeguarding reconciliation

The external reconciliation compares the firm's internal records with information obtained from the institutions that hold relevant funds or assets. Under CASS 15.8.39R this covers every bank holding a relevant funds account, anyone holding any other account containing relevant funds, and every custodian or third party holding or managing relevant assets.

  • Bank accounts: the balance in the firm's records for each account is compared, currency by currency, with the latest statement or confirmation from the bank (CASS 15.8.47R).
  • Relevant assets: the quantity of each investment in the firm's records is compared with the custodian's statement. Quantities are reconciled, not values.

Differences can come from timing, incorrect booking, missing transactions, bank charges, bank errors or weaknesses in internal records. CASS 15.8.42R requires the external reconciliation as soon as reasonably practicable after the date it relates to. The third-party data should, as far as possible, relate to the same point in time as the internal reconciliation; where that is not possible, the firm's policy must explain how the reconciliation still achieves its purpose.

This matters most for firms working across time zones or with banks whose statements update at different times. Timing differences must be understood, documented and treated the same way every day, not left as a standing explanation for differences that are never resolved.

How often reconciliations must be performed

Both reconciliations must be performed as often as necessary and at least once each reconciliation day. A reconciliation day is any day other than a Saturday, a Sunday, a UK bank holiday or a day on which a relevant foreign market is closed. The FCA chose reconciliation days over business days in PS25/12 because firms working across several currencies cannot always get third-party data when an overseas market is shut.

The minimum is not always enough. A high-volume, multi-market or fast-moving business may need intraday controls, and the method should reflect the nature, scale and complexity of the business rather than the bare wording of the rule. The firm should fix its reconciliation points and calendar in advance, record which foreign markets it treats as relevant and why, and apply them consistently.

Changing cut-off times, data sources or calculation methods without a recorded reason creates unexplained movements and weakens the firm's position at audit. Any change should be approved, documented and dated.

Calculating the safeguarding requirement correctly

A reconciliation is only as good as the requirement it tests against. A simple remittance business may have a straightforward calculation. A larger EMI or payment institution may process millions of transactions across several accounts, card programmes, acquiring, refunds, chargebacks, agents, currencies and settlement cycles.

The firm needs a written method stating when funds enter and leave the calculation and how each transaction state is treated. A common issue is that operational systems and the safeguarding method develop separately: a platform marks a payment complete while the method still treats the funds as relevant, or the reverse. Fees, refunds and unsettled transactions cause recurring differences when their treatment is not the same in both places.

A worked example

The illustrative internal reconciliation below is for the e-money pool of an EMI, in sterling.

LineAmountNote
Customer e-money balances per ledger£4,850,000Sum of individual customer balances
Receipts not yet allocated to a customer£40,000Still relevant funds while allocation is resolved
Outgoing payments not yet settled to the payee's provider£110,000Duty ends only when funds reach the payee's provider
Safeguarding requirement£5,000,000Total of the lines above
Safeguarding resource per the firm's records£4,985,000Balances of safeguarding accounts in the firm's books
Difference£15,000 shortfallPay in by the end of the day; find the cause

In this example the cause might be a fee swept from the safeguarding account before it fell due under the firm's policy. The firm pays in £15,000 the same day, records the cause, corrects the sweep timing in its system and confirms on the following reconciliation days that the difference has not returned. The calculation should be reproducible from the underlying data and reviewable by someone who did not prepare it.

Separate reconciliations for e-money and payment services

An authorised EMI that offers both e-money and payment services unrelated to e-money must keep the relevant funds for each activity distinct. CASS 15 applies separately to the e-money asset pool and the unrelated payment services asset pool, so each needs its own requirement, resource and reconciliation, and each is reported separately in the monthly return.

Combining the balances can hide a shortfall in one pool behind an excess in the other, and obscures which customers have claims against which pool in an insolvency. Firms with several product lines should review how each transaction type is mapped to a pool, considering the product's legal classification, the customer contract and the purpose for which the money was received.

What happens when a reconciliation shows a shortfall

CASS 15.8.50R requires the firm to find the reason for any difference between resource and requirement. A shortfall must be paid in or invested as soon as possible and in any case by the end of the day on which the reconciliation is performed. An excess is withdrawn. For the D+1 comparison, CASS 15.8.51R applies the same end-of-day deadline and, where relevant funds cannot be used, requires the firm to use its own money, even if that creates a temporary surplus.

Topping up the account does not close the matter. The firm must understand why the shortfall arose. A one-off timing issue calls for a different response from a recurring system error or a flawed calculation, and repeated shortfalls point to a control weakness that daily top-ups do not fix. Recurring shortfalls should be analysed for root cause, documented and escalated to the director or senior manager responsible for safeguarding.

When the FCA must be told

CASS 15.8.60R requires the firm to inform the FCA in writing and without delay if:

  • its internal records are materially out of date, inaccurate or invalid;
  • it cannot, or materially does not, carry out an internal reconciliation;
  • it cannot, or materially does not, pay in a shortfall or withdraw an excess;
  • it cannot, or materially does not, carry out an external reconciliation;
  • it cannot, or materially does not, resolve discrepancies found externally;
  • it becomes aware that in the preceding 12 months the amount safeguarded was materially different from the amount it was required to safeguard.

The FCA has not defined materiality for these purposes, so the firm should set documented, board-approved thresholds and apply them consistently.

Handling reconciliation discrepancies

Not every difference is a breach, but every material difference must be understood. Causes include items recorded internally before they appear on the bank statement, foreign exchange timing, unallocated receipts, incorrect ledger entries, bank charges and genuine shortfalls.

For differences found in the external reconciliation, CASS 15.8.56R requires the firm to investigate and take all reasonable steps to resolve them without undue delay. Where a discrepancy cannot be resolved straight away and one record suggests more money should be safeguarded, CASS 15.8.57R requires the firm to treat that record as accurate until the matter is resolved and to pay in its own funds to cover the gap.

What the record must show

CASS 15.8.9R requires the firm to record, for each reconciliation, the time and date it was carried out, the actions taken and the outcome, including the D+1 comparison. Records are kept for five years. The audit trail should show how each discrepancy was investigated and resolved, not only that the process was run. Repeated manual adjustments with little explanation suggest that the control is forcing numbers to agree rather than finding real differences.

Procedures to set

  • An owner for each class of difference.
  • Ageing limits after which an item is escalated.
  • Value thresholds for escalation to the responsible senior manager and for considering FCA notification.
  • Approval of every manual adjustment by someone other than the preparer.

Controlling timing differences

Timing differences are unavoidable, and they are where weak practice most easily becomes normal. Examples include internal recording before bank or scheme settlement, cross-border transactions that span banking days, and card acquiring settlement delays that do not match internal cut-offs.

Item typeExpected to clearAction if not cleared
Domestic payment in transitNext reconciliation dayInvestigate as an unexplained break
Cross-border or FX settlementWithin the settlement cycle for the currencyTrace with the correspondent bank; escalate
Card scheme settlementWithin the scheme's settlement cycleReconcile to scheme reports; escalate
Unallocated receiptWithin the firm's allocation limitKeep safeguarded; escalate for allocation or return

The clearing periods above are examples; each firm should set its own from its actual flows. Genuine timing items should be predictable, evidenced and logged with an expected clearing date. Items that pass that date must be investigated rather than labelled timing indefinitely. Management information should separate normal timing items from unexplained breaks, so unresolved issues do not build up beneath a stable headline figure.

Manual and automated reconciliations

CASS 15 does not require automation. A smaller firm can legitimately reconcile in spreadsheets, provided the process is accurate, controlled, reviewable and leaves a reliable audit trail. Manual processes do carry more exposure to human error, inconsistent treatment and weak evidence, and that exposure grows with volume, product complexity, currencies and banking relationships. A process that works for a few thousand transactions a month may not hold at much larger scale.

Dependence on one person is a resilience weakness if only one employee understands the workbook or the daily adjustments. Automation reduces genuine exposure, but an automated process built on the wrong logic produces wrong answers faster, so the method must be right before it is automated. IT controls over access, changes and record integrity are within the scope of the safeguarding audit either way.

Safeheld, the firm's own safeguarding platform, runs the internal and external reconciliations and the D+1 comparison for each asset pool, manages breaks through to approval and keeps a record that cannot be altered afterwards. More detail is on the Safeheld page.

Connecting reconciliations to REP027, the audit and the resolution pack

Daily reconciliations are the foundation of the wider safeguarding framework. The same data should feed the monthly safeguarding return, management information, the annual audit and the resolution pack.

  • REP027: the monthly return, filed through My FCA within 15 business days of month end, reports whether every reconciliation was completed and any shortfalls. Our guide to the monthly safeguarding return covers each section.
  • The audit: the auditor re-performs reconciliations for sample dates and counts reconciliations against reconciliation days. Our guide to FCA safeguarding audits sets out what is tested.
  • The resolution pack: CASS 10A requires the pack to include the firm's reconciliation records and procedures, so an insolvency practitioner can see the latest position. Our article on the CASS 10A resolution pack lists the contents.

Senior management should see the quality of reconciliations, not just completion: material shortfalls, recurring breaks, aged differences, manual adjustments, system issues and overdue remediation.

Common reconciliation weaknesses

The most significant weaknesses usually sit inside processes that appear to work. A firm can reconcile to its bank balance perfectly every day while its underlying requirement is wrong.

  • Incomplete transaction data feeding the requirement.
  • Inconsistent treatment of fees, refunds and chargebacks.
  • E-money and payment services pools combined.
  • Cut-off times that change from day to day.
  • Manual adjustments with weak evidence or no independent approval.
  • External reconciliation run less often or less rigorously than the internal one.
  • Timing items left open beyond their expected clearing date.
  • Reliance on one person.

The test is whether the method can consistently and independently show that the right amount of customer money is safeguarded.

What firms should test now

  1. Review a representative sample of reconciliations end to end, not just the final report.
  2. Trace the safeguarding requirement back to customer and transaction records.
  3. Confirm that the internal reconciliation uses internal records and the external one uses third-party data.
  4. Check how differences were investigated and whether shortfalls were paid in by the end of the reconciliation day.
  5. Check whether recurring issues were escalated and their causes fixed.
  6. Compare the method with the current business model, since new products, banks, currencies, agents or settlement routes can leave a sound method incomplete.
  7. Ask another competent person to reproduce and explain a reconciliation without help.

The firm's safeguarding and CASS 15 practice reviews reconciliation methods, tests them against the rules and redesigns them where needed. For the wider rules introduced on 7 May 2026, see our CASS 15 explainer.

Why reconciliations matter more to the FCA now

The FCA strengthened the regime after finding that payment and e-money firms which became insolvent between 2018 and 2023 had an average shortfall of 65% in the money owed to customers. Daily reconciliations are the early-warning mechanism: they flag insufficient safeguarding, inaccurate records and third-party balances that do not match expectations before they become a loss.

Monthly reporting and the annual audit make reconciliation weaknesses visible in a way they were not before May 2026. For boards, persistent breaks, unexplained adjustments and frequent shortfalls are signs of deeper issues in systems, product design, data quality or governance, and deserve the same attention as a financial loss.

Frequently asked questions

How often must payment and e-money firms perform safeguarding reconciliations?

Internal and external reconciliations must each be performed as often as necessary and at least once each reconciliation day. High-volume or complex firms may need more frequent controls.

What is the difference between an internal and external safeguarding reconciliation?

The internal reconciliation uses the firm's own records to test whether its safeguarding resource matches its requirement. The external reconciliation compares those records with statements from the banks, custodians and third parties holding the money or assets.

What is a reconciliation day?

Any day other than a Saturday, a Sunday, a UK bank holiday or a day on which a relevant foreign market is closed.

What happens if a safeguarding reconciliation shows a shortfall?

The firm must find the reason and pay in the shortfall as soon as possible and in any case by the end of the day the reconciliation is performed, using its own funds if relevant funds are not available. It should also fix the cause, especially if shortfalls recur.

Can safeguarding reconciliations be performed in spreadsheets?

Yes. CASS 15 does not require automation, but a spreadsheet process must be accurate, controlled, independently reviewable and able to produce a reliable audit trail.

Are insurance policies and guarantees included in the external reconciliation?

No. CASS 15 excludes insurance policies and guarantees from the external reconciliation, and a firm with unlimited cover need not perform an internal reconciliation but must calculate its safeguarding requirement daily.

What should a firm do if it is unsure its reconciliation method complies with CASS 15?

Test the full method rather than the written procedure: trace the requirement to customer records, test inputs and timing items, and confirm shortfalls are paid in by the end of the day. An independent review before the first audit period ends leaves time to correct gaps.

References

  1. FCA Handbook: CASS 15.8 Records, accounts and reconciliations
  2. FCA Handbook: CASS 15 Safeguarding
  3. FCA PS25/12: Changes to the safeguarding regime for payments and e-money firms
  4. FCA: Safeguarding requirements for payment institutions and e-money institutions
  5. Payment Services Regulations 2017, regulation 23
  6. FRC: Interim Guidance on Payment and E-money Safeguarding Assurance Engagements

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained FCA authorisations for payment and e-money firms including Oval, Global Send and HFS since 2013, and designs the safeguarding reconciliation methods CASS 15 requires. Its safeguarding work covers requirement calculations, internal and external reconciliation design, break handling, REP027 alignment and audit readiness.

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.