
Identify PS25/12 and CASS 15 gaps for APIs, EMIs and small EMIs before FCA reporting, audit or supervisory review, with a readiness score and the controls to strengthen first.
Fourteen questions on your safeguarding arrangements. The result appears on this page.
The rules the tool applies, in full. The result is guidance from your answers; the firm confirms it in a written proposal the same day.
Each answer scores 2 for “Yes”, 1 for “Partly” and 0 for “No”. Priority items count double. The score is the total as a percentage of the maximum for the questions that apply to your firm.
| Result | Score |
|---|---|
| Audit-ready position | 85% or above, with no priority item at its lowest answer |
| Targeted remediation | 60% to 84%, or 85% and above with a priority item at its lowest answer |
| Priority remediation | Below 60% |
The audit question applies only where the firm has safeguarded more than £100,000 at any time in the last 53 weeks. The requirements are those of the FCA’s supplementary safeguarding regime in CASS 15, introduced by PS25/12 and in force since 7 May 2026.
Authorised payment institutions, authorised EMIs and small EMIs, and small payment institutions that choose to safeguard. It has applied since 7 May 2026.
The existing safeguarding methods remain, and the FCA added client-assets controls: daily internal and external reconciliations, a resolution pack, a monthly safeguarding return, an annual safeguarding audit for firms above the threshold, and a single accountable director or senior manager.
Every firm in scope that has safeguarded more than £100,000 at any time over a 53-week period. Firms below the threshold still file the monthly return, and many banks and partners ask for a voluntary audit.
Within 15 business days of each month end, filed as REP027 through My FCA.
No. The check runs in your browser and nothing is sent unless you choose to send the result to the firm through the contact form.
A reply within three business hours and a written proposal on the licence, the requirements, the cost and the timing the same day.