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Payment and e-money safeguarding readiness checker.

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.

Run the check.

Fourteen questions on your safeguarding arrangements. The result appears on this page.

Which type of firm are you?
Have you safeguarded more than £100,000 at any time in the last 53 weeks?

Firms that have not are exempt from the annual safeguarding audit.

Is the safeguarding method chosen and documented for each flow of relevant funds?
Are relevant funds held in designated safeguarding accounts, with an acknowledgement letter from each institution?
Are relevant funds segregated by the end of the business day after receipt?
Are internal and external reconciliations performed on every reconciliation day, with records kept?
Are shortfalls corrected the same day, with breaches recorded and notified to the FCA?
Is a resolution pack maintained, retrievable within 48 hours and updated within five business days of a change?
Is responsibility for safeguarding allocated to a single director or senior manager?
Is the monthly safeguarding return prepared from the reconciliation record and filed within 15 business days of month end?
Is due diligence on your safeguarding banks and insurers documented and reviewed periodically?
Is a safeguarding policy approved by the board, covering receipt, segregation, reconciliation and discrepancies?
Does the board receive safeguarding management information every month?
Answer each highlighted question to see your result.

How the result is worked out.

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.

ResultScore
Audit-ready position85% or above, with no priority item at its lowest answer
Targeted remediation60% to 84%, or 85% and above with a priority item at its lowest answer
Priority remediationBelow 60%

Priority items

  • Safeguarding method
  • Safeguarding accounts and letters
  • Segregation timing
  • Daily reconciliations
  • Shortfalls and notifications
  • Resolution pack
  • Monthly safeguarding return
  • Annual safeguarding audit

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.

Questions firms ask.

Which firms does CASS 15 apply to?

Authorised payment institutions, authorised EMIs and small EMIs, and small payment institutions that choose to safeguard. It has applied since 7 May 2026.

What changed under PS25/12?

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.

Who needs an annual safeguarding audit?

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.

When is the monthly return due?

Within 15 business days of each month end, filed as REP027 through My FCA.

Is my result stored?

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.

Speak to an expert.

A reply within three business hours and a written proposal on the licence, the requirements, the cost and the timing the same day.