CASS 15 & Safeguarding
Know what your safeguarding auditor will find, before they find it.
An independent readiness assessment for payment and e-money institutions facing their first CASS 15 safeguarding audit.
Is your first audit coming?
Who needs one
Authorised payment institutions (other than payment initiation or account information only) and e-money institutions, unless you have not safeguarded more than £100,000 at any point over 53 weeks.
When your period ends
CASS 15 took effect on 7 May 2026. Your first audit period can run no more than 53 weeks from then, so it ends by May 2027 at the latest. Many firms align it to their financial year end.
When the report is due
Within six months of the end of your first audit period, then four months for later years. A period ending 31 December 2026 means a report to the FCA by 30 June 2027.
What we test
We look at your arrangements the way a qualified auditor will: against CASS 15, the Payment Services Regulations and the Electronic Money Regulations, with every breach in view.
- Daily reconciliations: method, evidence and how breaks are resolved
- Segregation of relevant funds from working capital
- Acknowledgement letters for every safeguarding account
- Monthly safeguarding return: accuracy and supporting records
- Resolution pack: a live retrieval test, not a document check
- Breach log, escalation and board oversight
- IT and outsourced reconciliation controls
- Third-party and insurance or guarantee arrangements
How it works
- 1
Scoping call
Thirty minutes on your business model, flow of funds, safeguarding method, audit period end and auditor.
- 2
Document and data request
Policies, reconciliations, acknowledgement letters, monthly returns, resolution pack, breach log, board MI and outsourcing agreements.
- 3
Walkthroughs and testing
We walk through your processes with the people who run them and sample-test controls as an auditor would.
- 4
Findings and plan
A RAG-rated view of every requirement, a prioritised remediation plan with owners and dates, and a board-ready summary.
What you get
- Findings report rated by requirement
- Prioritised remediation plan with owners and dates
- Board-ready summary for your safeguarding senior manager
- Evidence index your auditor can work from
Pricing
A fixed fee, agreed after the scoping call and based on your size and safeguarding model. No open-ended billing.
Then what?
Findings to fix before fieldwork
We can deliver the remediation too, with the evidence to show it works.
See remediationAlready received a qualified opinion?
RegRepair leads remediation programmes from first finding to a clean close.
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