CASS 15 Safeguarding Audits

What Is a CASS 15 Safeguarding Audit?

CASS 15 went live on 7 May 2026. UK payment institutions and e-money firms are now operating under the FCA's new safeguarding regime, and the first annual CASS 15 audit reports will start landing with the FCA in the months ahead. Black Maple is a registered audit firm authorised to perform that audit and issue the report. If your year-end is anywhere between now and March 2027, the conversation about who is doing the work is one you want to have in the next sixty days, not the week before the deadline. The annual CASS 15 audit is not a tick-box exercise. Daily reconciliations of relevant funds, documented cut-off times, and a clear audit trail of the safeguarding account itself are all in scope. We've seen the rules through every draft since the FCA consultation paper, and we've been doing client-money work under the previous regime for over a decade.

The rules require these firms to safeguard relevant funds (being customer money received for payment transactions or in exchange for e-money), by holding it in designated accounts at approved banks, or in qualifying liquid assets, kept strictly separate from the firm's own money.

Under the new regime, any firm that holds £100,000 or more in relevant funds during a 53 week period must arrange an annual safeguarding audit and submit the resulting report to the FCA. This audit must be conducted by a registered auditor, regulated by a recognised supervisory body such as the ICAEW. Prior to CASS 15, safeguarding reviews could be carried out by compliance consultants with no auditor registration or professional accountability to the FCA. That is no longer permitted.

The key changes introduced by CASS 15 include, but are not limited to:

  • Mandatory annual safeguarding audit conducted by a registered auditor and submitted directly to the FCA by the firm, replacing the previously informal and inconsistently applied review process;

  • Daily reconciliations of safeguarded funds, both internal and external, on every business day;

  • Resolution packs must be maintained per CASS 10A. These will contain all documentation an insolvency practitioner would need to identify and begin returning customer money and must be retrievable within 48 hours of appointment;

  • Monthly safeguarding return submitted to the FCA providing standardised data on the firm's safeguarding position;

  • Named senior manager accountability with a single director or senior manager responsible for operational oversight of the regime and annual reporting to the board;

  • Third-party due diligence requirements on all banks, custodians, and other parties involved in holding or managing relevant funds; and

  • Prescribed acknowledgement letters now mandatory in a standard template form (CASS 15 Annex 1) for every relevant funds bank account and relevant assets account, replacing the previously guidance-based expectation

Who needs a Safeguarding Audit?

From 7 May 2026, a mandatory annual safeguarding audit is required for any firm that falls within the scope of CASS 15 and holds £100,000 or more in relevant funds during its audit period. The following firm types are in scope:

Firms that solely provide payment initiation services or account information services are excluded. The audit must be conducted by a registered auditor and the report submitted to the FCA by the firm within six months of the first audit period end, and within four months for all subsequent periods.

Contact us for more information

Do you need a CASS 15
safeguarding audit?

Answer four questions to find out whether your firm has a legal obligation to appoint a registered auditor under FCA PS25/12 and SUP 3A.

FCA PS25/12 · In force 7 May 2026
Find out in minutes whether your firm needs a safeguarding audit

This tool follows the decision logic of CASS 15 and SUP 3A as introduced by the FCA's Payments and Electronic Money (Safeguarding) Instrument 2025. Your result includes the relevant regulatory references.

What the Audit Covers.

The safeguarding audit under SUP 3A is a reasonable assurance engagement. The auditor assesses whether the firm has complied with the relevant funds regime under CASS 15 across the full audit period. The audit covers:

What the CASS 15 Safeguarding Audit Covers | Black Maple
What does a CASS 15 safeguarding audit cover? Seven areas covered by a CASS 15 safeguarding audit under SUP 3A, evenly spaced around a central hub. What the audit covers SUP 3A reasonable assurance Relevant funds Were all customer funds correctly recorded? Breaches Were breaches investigated and reported to the FCA? Third parties Were banks and custodians properly vetted? Governance Was a named senior manager accountable? Resolution pack Was the resolution pack complete and retrievable? Reconciliations Were daily reconciliations performed accurately? Segregation Were funds held at approved banks with valid letters?

Why Appoint black Maple

CASS 15 is a new regime. No firm large or small has a back catalogue of safeguarding audits under the new rules. What matters is whether your auditor understands the framework, has built their methodology around the right source material, and can demonstrate the competence that SUP 3A requires firms to assess before appointing them.

Black Maple is an ICAEW-regulated audit and advisory firm. Our safeguarding audit work is conducted under ISAE (UK) 3000, the assurance standard underpinning the FRC's Interim Guidance on Payment and E-Money Safeguarding Assurance Engagements, published in March 2026. We have built our engagement methodology directly around that guidance and the source instrument, FCA 2025/38, rather than working backwards from a generic audit approach.

Every engagement is led and delivered by a senior qualified professional. There are no juniors on our teams. For a regime where the FRC has explicitly flagged auditor competence as a threshold requirement, that matters.

For firms requiring a larger or more complex engagement, we work in association with a top 15 firm with established FCA-regulated audit capability.

Frequently Asked Questions