The CASS resolution pack is the set of documents that allows customer money to be returned quickly if a payment institution or e-money institution becomes insolvent. An administrator or liquidator needs to know what was safeguarded, where it is held, who is entitled to it and how to move it. CASS 10A of the FCA Handbook requires every safeguarding institution to keep that information assembled and current, so it is ready before it is ever needed.
CASS 10A applies to a safeguarding institution whenever it receives or holds relevant funds under CASS 15, the FCA's safeguarding chapter for payment and e-money firms. Both came into force on 7 May 2026 under Policy Statement PS25/12. The chapter is modelled on CASS 10, which has applied to investment firms holding client money and assets for many years. Our CASS 15 explainer covers the wider regime.
The FCA's case for the rule rests on experience: firms that became insolvent between 2018 and 2023 had an average shortfall of 65% in the money owed to customers, and scattered or incomplete records made returning what remained slow and costly, with those costs met from the funds owed to customers.
Every firm that safeguards relevant funds under CASS 15 must maintain a pack at all times while CASS 10A applies to it. That covers authorised payment institutions holding customer money, authorised and small e-money institutions, credit unions issuing e-money and small payment institutions that have opted in to safeguarding. There is no size exemption: the £100,000 threshold that exempts some firms from the annual safeguarding audit does not apply to the resolution pack.
Where a firm belongs to a group, it may rely on a group member to hold some documents, provided that member is subject to the same rule and the firm has arrangements in place for delivery within the 48-hour limit (CASS 10A.1.6R and 10A.1.8R).
CASS 10A.2.1R sets out ten core documents. The table lists each, with a plain description of what it should hold in practice.
| Required document | What it should hold |
|---|---|
| 1. Master document | An index with enough information to find and retrieve every other document in the pack |
| 2. Safeguarding institutions | Every bank or custodian holding relevant funds or assets, including those appointed through agents or e-money distributors, with account identifiers and currencies |
| 3. Executed agreements | A copy of each signed agreement with those institutions, including side letters and the CASS 15.7 acknowledgement letters |
| 4. Insurers and guarantors | Any institution providing insurance or a guarantee under the Electronic Money Regulations or Payment Services Regulations |
| 5. Policies and guarantees | A copy of each executed policy or guarantee, including side letters |
| 6. Agents and distributors | Each agent and e-money distributor and how it relates to the flow of relevant funds |
| 7. Group members | Group entities performing safeguarding functions, with entity type, jurisdiction and functions |
| 8. Third-party providers | Each third party used for operational functions, how to access its information and how to transfer relevant funds or assets it controls |
| 9. Procedures | How relevant funds and assets are received, identified, segregated, recorded and transferred |
| 10. People | Senior managers, directors and other critical individuals, their responsibilities, and the person responsible for safeguarding under CASS 15.2.4R |
CASS 10A.3.1R adds existing records, where they apply, that the pack must include or link to.
| Record | Source rule |
|---|---|
| Due diligence and appointment records for third parties holding or managing relevant funds or assets | CASS 15.4.11R and 15.6.7 |
| Records and accounts of relevant funds, including what each customer is owed | CASS 15.8.3R and 15.8.8R |
| Reconciliation records: time, date, actions and outcome, including the D+1 comparison | CASS 15.8.9R |
| Safeguarding policies and procedures, including the calculation method | CASS 15.8.1R |
| Standard customer terms and conditions | CASS 10A.3.1R |
Two items deserve particular care. The calculation method should record the firm's judgements on where relevant funds begin and end, the treatment of fees and foreign exchange, and whether it uses the standard or a non-standard reconciliation method, so that an insolvency practitioner can repeat the calculation. The customer entitlement records should explain not only where each customer's balance is held but how to extract it from the firm's systems.
CASS 10A.1.7R requires two things. The firm must have arrangements that allow an administrator, receiver, liquidator or similar officer to retrieve each document as soon as practicable and in any event within 48 hours of appointment. The firm itself must be able to retrieve each document within the same limit when it decides to, or when the FCA or the Bank of England asks.
Forty-eight hours is far too short to build a pack from nothing. The rule assumes a pack that already exists, is complete and is current. The ability to reconstruct one on request does not meet it.
CASS 10A.1.9E, an evidential provision, says some items should be retrievable immediately rather than within 48 hours: the documents identifying safeguarding institutions, the acknowledgement letters, the insurance policies or guarantees, the list of critical individuals and the latest reconciliation records. Where any of these are produced by a system, the firm should arrange for that system to remain operational and accessible after insolvency. The firm should also make the pack available promptly to an adviser acting for the FCA or an insolvency officer.
Keeping the pack accurate is the main practical task. Balances, reconciliations, acknowledgement letters, agents and staff all change. CASS 10A.1.11R requires the firm to review the pack's content on an ongoing basis and to correct any material inaccuracy in a core document promptly and in any event no more than five business days after the change. The FCA's own example of a material change is a change of safeguarding institution.
| Event | Pack update needed |
|---|---|
| New safeguarding account or bank | Institutions list, agreements and acknowledgement letter |
| Account closed | Institutions list; keep the letter for five years |
| New agent or e-money distributor | Agents and distributors list; procedures if flows change |
| New outsourced provider | Third-party list with access and transfer details |
| Change of responsible director or key staff | People document |
| New product or currency | Procedures, calculation method and terms |
| Insurance renewal or change | Insurers list and policy copy |
A pack that holds a typed copy of the account list is out of date as soon as an account changes. A pack that points to the system where accounts are actually recorded is correct at the moment it is retrieved. CASS 10A.1.13G allows any document to be held electronically, provided the 48-hour and five-business-day rules can still be met. Drawing the pack from live records means the 48-hour rule is met by retrieval rather than assembly. Items that must stay static, such as signed acknowledgement letters, should have their review dates tracked and flagged when renewal is due.
CASS 10A.1.14R requires the firm's governing body to receive a report on compliance with CASS 10A at least annually. The report should confirm that the pack is complete, state when it was last tested and how long retrieval took, list any changes that required correction and whether each was made within five business days, and set out any open actions.
Ownership normally sits with the director or senior manager responsible for safeguarding under CASS 15.2.4R, with named owners for each document. The safeguarding auditor may test the pack's completeness, currency and retrieval time as part of the annual audit; our guide to FCA safeguarding audits explains how.
A pack that has never been retrieved has not been tested. Firms should periodically produce it as if responding to a real request, at least once a year and after any significant change, and record the result.
If retrieval depends on one person knowing where things are kept, the pack does not serve its purpose, because that person may not be available in an insolvency.
The most reliable packs are generated from the records the firm already keeps for daily safeguarding. The account list comes from the system that holds accounts; acknowledgement letter status comes from the letter register; the latest reconciliation comes from the reconciliation record. Our guide to safeguarding reconciliations explains how those daily records are built.
Safeheld, the firm's own safeguarding platform, builds the CASS 10A pack from the safeguarding accounts, balances, acknowledgement letter status, third parties, reconciliation history and customer entitlement records it already holds, and flags gaps. More detail is on the Safeheld page. The firm's safeguarding practice also designs and tests resolution packs for firms that maintain them in-house.
It is the set of documents that allows customer money to be identified and returned if a payment or e-money firm becomes insolvent. It covers safeguarding institutions, agreements and acknowledgement letters, agents, third parties, procedures, key people and the related CASS 15 records.
Each document must be retrievable as soon as practicable and in any event within 48 hours. The rule assumes a pack that already exists and is current.
Yes. CASS 10A applies to every safeguarding institution holding relevant funds under CASS 15 from 7 May 2026. It is modelled on CASS 10, which applies to investment firms.
Its content must be reviewed on an ongoing basis, and any material inaccuracy in a core document corrected within five business days of the change.
Yes. CASS 10A.1.13G allows any document to be held electronically, provided the firm can still meet the 48-hour retrieval and five-business-day correction rules.
Yes. Producing it as if responding to a real request, using someone other than its maintainer, is the only way to confirm it is complete, current and retrievable within 48 hours.
Buckingham Capital Consulting has obtained FCA e-money authorisations for firms including Dzing Finance, Hryze and HFS since 2013, and builds the CASS 10A resolution packs those firms maintain. Its safeguarding work covers pack design, document ownership, retrieval testing and the annual report to the governing body.
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.