As of 7 May 2026, full compliance of CASS 15 is required.
Who does this affect?
The CASS 15 rules apply to the following types of organisations: – Authorised payment institutions – E-money institutions – Credit unions that issue e-money Small payment institutions are able to opt-in to comply with the new rules on a voluntary basis; a firm will be considered exempt from CASS 15 if it has held less than £100,000 of relevant funds for fewer than 53 weeks. Increased protection for funds held One of the main aims of the new CASS regime is to provide security to clients, particularly in the event of a regulated firm becoming insolvent, and to ensure that all of the safeguarded funds are returned to clients should this be the case. Under CASS 15, firms are now required to hold safeguarding funds under an arrangement that ensures that funds held on behalf of clients are protected and maintained separately from other creditors of the firm.
In practice, this requires firms to safeguard the monies held once they meet the definition of ‘relevant funds’, with the rules providing details of the methods by which this is permitted. Methods of safeguarding As had been set out in the FCA’s proposal document CP25/12, the CASS 15 rules state a number of potential methods of safeguarding relevant funds – including holding the funds in a designated safeguarding account or investing the funds in secure liquid assets – and also permit protection of funds by obtaining an insurance or guarantee for the amount of funds held. Whilst the methods listed are the same as under the previous safeguarding regime, they have been significantly strengthened to add legal certainty to the protection afforded to clients, in line with the FCA’s wider aims.