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The Monthly Safeguarding Return Under SUP 16.14A: A Practical Guide for 2026

Published 6 August 2026 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. What the monthly safeguarding return is
  2. Who must submit REP027
  3. When REP027 is due
  4. What the return covers
  5. Where the data comes from
  6. Points that need care
  7. Preparing the return: a monthly routine
  8. How REP027 fits with the firm's other reporting
  9. Frequently asked questions
Key takeaways
  • REP027 is the FCA's monthly safeguarding return under SUP 16.14A and has applied since 7 May 2026.
  • It is due within 15 business days of the end of each calendar month and is submitted through My FCA.
  • Authorised payment institutions, authorised and small EMIs, credit unions issuing e-money and small payment institutions that opt in to safeguarding must all file it.
  • Firms confirm that at least one internal and one external reconciliation ran on every reconciliation day, and report the D+1 segregation requirement against the resource.
  • EMIs report e-money and unrelated payment services funds as separate pools, and every shortfall is reported even if corrected the same day.
  • The FCA rejected quarterly reporting for smaller firms, so audit-exempt firms still file REP027 monthly.

What the monthly safeguarding return is

The monthly safeguarding return, form REP027, is the report every payment and e-money firm that safeguards customer money now sends the FCA each month. Safeguarding means keeping customer money separate from the firm's own money so it can be returned if the firm becomes insolvent. The return is required by SUP 16.14A of the FCA Handbook, introduced by Policy Statement PS25/12 alongside the CASS 15 safeguarding rules, and has applied since 7 May 2026.

REP027 gives the FCA a monthly view of each firm's relevant funds, safeguarding method, accounts, reconciliations, shortfalls and breaches. The FCA uses it for trend analysis, peer comparison and supervisory engagement. It replaced the safeguarding questions that used to sit in the periodic returns for payment institutions and e-money institutions. For the wider rules it reports against, see our CASS 15 explainer.

Who must submit REP027

Firm typeMust submit REP027?
Authorised payment institution holding customer moneyYes
Authorised e-money institutionYes, with e-money and unrelated payment services reported separately
Small e-money institutionYes
Credit union issuing e-moneyYes
Small payment institution that has opted in to safeguardingYes
Small payment institution that does not safeguardNo
Payment initiation or account information firm onlyNo; it holds no customer money

The FCA considered allowing smaller or lower-risk firms to report quarterly and decided against it, describing monthly reporting as necessary and proportionate. A firm that is exempt from the annual safeguarding audit still files REP027 every month, and the return includes a field identifying firms that rely on the audit exemption.

When REP027 is due

SUP 16.14A.3R requires the return within 15 business days of the end of each calendar month. Business days exclude weekends and UK bank holidays. The deadline is the same for every firm type; there is no separate reporting calendar by permission. A firm does not file for the month in which it first becomes a safeguarding institution, and starts with the following month.

Reporting monthDue by
September 202621 October 2026
October 202620 November 2026
November 202621 December 2026
December 202622 January 2027

The dates above are calculated from the rule for England and Wales bank holidays. Each firm's own schedule is shown in My FCA, and the firm should diarise each deadline at the start of the year rather than calculate it month by month.

How it is submitted

REP027 is submitted electronically through My FCA, the FCA's online portal for firms. The firm's reporting schedule in My FCA shows the due dates that apply to it.

What the return covers

The return was refined after a pilot in which a sample of firms each submitted two trial returns. The table summarises the main areas and where the data should come from.

AreaWhat is reportedSource record
Relevant fundsFunds safeguarded, with e-money and unrelated payment services as separate poolsDaily internal reconciliations
Segregation positionD+1 segregation requirement compared with D+1 segregation resourceDaily D+1 comparison
ReconciliationsConfirmation that at least one internal and one external reconciliation ran each reconciliation dayReconciliation calendar and records
Reconciliation methodWhether a non-standard internal method is usedMethod approval and auditor's report
ShortfallsShortfalls in the month and how they were correctedBreak and breach records
AccountsSafeguarding accounts, the institutions holding them and balancesExternal reconciliations
Relevant assetsWhich assets are held with which custodiansCustodian statements
MethodSegregation, insurance or guarantee, or a combination, with provider detailsSafeguarding policy and contracts
Audit exemptionWhether the firm relies on the £100,000 exemptionDocumented exemption assessment
BreachesBreaches in the month and notifications made to the FCABreach register

Terms used in the return

  • Relevant funds: sums received in exchange for e-money, and sums received from or for customers, or from other payment providers, to carry out payment transactions.
  • D+1 segregation requirement: the relevant funds that should be held in safeguarding accounts or as relevant assets; D+1 refers to the deadline of the end of the business day after receipt.
  • D+1 segregation resource: the amount actually held in those accounts and assets.
  • Reconciliation day: any day other than a weekend, a UK bank holiday or a day on which a relevant foreign market is closed.

The return's explanatory notes include guidance on the exchange rate to use when converting foreign currency balances, and on how firms with an unlimited insurance policy or guarantee should complete it.

Where the data comes from

Every figure in REP027 should trace to a daily operational record. The return is a summary of the month's controls, not a separate calculation.

  • The segregation requirement and resource come from each reconciliation day's internal reconciliation.
  • The reconciliation confirmation comes from the reconciliation calendar, fixed in advance, matched to the records of reconciliations performed.
  • Shortfalls and corrections come from the break and breach records.
  • Account balances come from the external reconciliation.
  • Breaches and notifications come from the breach register.

When those records sit in a controlled system, preparing the return is a matter of drawing approved data. When they sit in spreadsheets, the firm has to rebuild the month from scattered files, emails and memory, and the return starts to drift from what the auditor will later test. Our guide to internal and external safeguarding reconciliations explains how the daily records should be built.

Points that need care

Consistency with audit evidence

A return compiled separately from the reconciliation records will diverge from what the auditor tests. The FRC's interim guidance for safeguarding auditors expects them to check that the monthly return is consistent with the other evidence they gather.

The reconciliation confirmation

A calendar drawn up after the event often does not match the reconciliations actually performed. Fix the calendar in advance, including which foreign market closures the firm treats as relevant, and check the records against it before confirming.

Separate pools

E-money and unrelated payment services funds are reported separately. Combining them can hide a shortfall in one pool behind an excess in the other.

Shortfalls corrected the same day

A shortfall paid in by the end of the reconciliation day still occurred and is still reported, together with how it was corrected.

Return disclosure and notification are separate

Reporting a breach in REP027 does not replace a notification the rules require. Under CASS 15.8.60R a firm must tell the FCA in writing without delay if, for example, it cannot carry out a reconciliation or cannot correct a shortfall. That notification is made when the event occurs, not when the next return is filed.

Preparing the return: a monthly routine

StageWhat to do
Every reconciliation dayPerform and record both reconciliations and the D+1 comparison; log breaks and their resolution; update the breach register
First business days after month endDraw the return from those records; check the reconciliation confirmation against the calendar; confirm the pool split
ReviewConfirm shortfalls and corrections are complete and balances agree to the external reconciliations; an independent reviewer checks the figures
ApprovalThe director or senior manager responsible for safeguarding under CASS 15.2.4R approves the return
By business day 15Submit through My FCA and record the submission
After submissionRetain the return and supporting records; include the key figures in board management information

The firm is responsible for the accuracy of the return. If an error is found after submission, correct it with the FCA promptly and record the cause, so the same error does not recur. Records made under CASS 15 are kept for five years.

How REP027 fits with the firm's other reporting

REP027 sits alongside the firm's other periodic returns to the FCA, such as its financial returns, and its annual safeguarding audit. The audit tests the same records that feed the monthly return, so a gap between the two is a likely audit finding. Our guide to FCA safeguarding audits under CASS 15 explains what the auditor tests, and our overview of FCA regulatory reporting for PIs and EMIs sets REP027 in the context of every return a firm submits.

Safeheld, the firm's own safeguarding platform, assembles REP027 from the reconciliation records approved during the month, so the reported figures match the daily records and the supporting evidence stays available for audit. More detail is on the Safeheld page.

Frequently asked questions

What is the monthly safeguarding return?

It is form REP027, required by SUP 16.14A since 7 May 2026. It reports a firm's relevant funds, safeguarding method, accounts, reconciliations, shortfalls and breaches for each calendar month.

When is the safeguarding return due?

Within 15 business days of the end of each calendar month. The deadline is the same for every firm type and is shown in the firm's reporting schedule in My FCA.

How is REP027 submitted?

Electronically through My FCA, the FCA's online portal for firms.

Do small payment institutions have to submit REP027?

Only if they have opted in to safeguarding. An SPI that safeguards files the return monthly like an authorised firm.

Do we report shortfalls corrected the same day?

Yes. A shortfall that occurred is reported however quickly it was corrected, together with how it was corrected.

How are e-money and payment services funds reported?

Separately. They are separate asset pools under CASS 15 and are reconciled and reported as such.

What if a reconciliation was not performed on a reconciliation day?

It is a breach that must be notified to the FCA in writing without delay under CASS 15.8.60R, recorded in the breach register and reflected in the next return.

References

  1. FCA Handbook: SUP 16.14A Safeguarding return
  2. FCA: Safeguarding requirements for payment institutions and e-money institutions
  3. FCA PS25/12: Changes to the safeguarding regime for payments and e-money firms
  4. FCA Handbook: CASS 15.8 Records, accounts and reconciliations
  5. FCA: My FCA

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained FCA authorisations for payment and e-money firms including Orbital, Oval and Hryze since 2013, and sets up the monthly REP027 safeguarding return for them. Its safeguarding work covers reconciliation design, return preparation and review, breach registers and alignment with the annual safeguarding audit.

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.