CASS 15 – The new safeguarding rules explained

As of 7 May 2026, afloat compliance of CASS 15 is required.

Who does this affect?

The CASS 15 rules use to the pursuing types of organisations:

• Authorised outgo institutions

• E-money institutions

• Credit unions that contented e-money

Small outgo institutions are capable to opt-in to comply with the caller rules connected a voluntary basis; a steadfast volition beryllium considered exempt from CASS 15 if it has held little than £100,000 of applicable funds for less than 53 weeks.

Increased extortion for funds held

One of the main aims of the caller CASS authorities is to supply information to clients, peculiarly successful the lawsuit of a regulated steadfast becoming insolvent, and to guarantee that each of the safeguarded funds are returned to clients should this beryllium the case.

Under CASS 15, firms are present required to clasp safeguarding funds nether an statement that ensures that funds held connected behalf of clients are protected and maintained separately from different creditors of the firm. In practice, this requires firms to safeguard the monies held erstwhile they conscionable the explanation of ‘relevant funds’, with the rules providing details of the methods by which this is permitted.

Methods of safeguarding

As had been acceptable retired successful the FCA’s connection papers CP25/12, the CASS 15 rules authorities a fig of imaginable methods of safeguarding applicable funds - including holding the funds successful a designated safeguarding relationship oregon investing the funds successful unafraid liquid assets - and besides licence extortion of funds by obtaining an security oregon warrant for the magnitude of funds held.

Whilst the methods listed are the aforesaid arsenic nether the erstwhile safeguarding regime, they person been importantly strengthened to adhd ineligible certainty to the extortion afforded to clients, successful enactment with the FCA’s wider aims.

Where funds are held successful designated safeguarding slope accounts, firms are present required to person acknowledgement letters successful place, reviewed and signed by the third-party institution, earlier the relationship is entitled to person applicable funds.

When investing successful unafraid liquid assets, firms request to guarantee the governance and hazard illustration astir the assets selected is managed appropriately.

Where a steadfast uses an security oregon warrant to support the funds held, absorption indispensable guarantee that they person a documented and wide contingency program successful spot to screen the security warrant successful the lawsuit of failure. In addition, firms indispensable corroborate renewal oregon replacement astatine slightest 3 months earlier an security argumentation oregon warrant expires, oregon other beryllium acceptable to screen the funds via segregation.

Reconciliations

A further cardinal constituent of the CASS 15 rules is simply a request to transportation retired regular interior and outer reconciliations, cross-referencing their interior records and outer third-party statements to guarantee the accuracy of lawsuit funds held.