Safeguarding & Client Asset Protection
Navigating the FCA's Supplementary Regime, CASS 10A & CASS 15
The Safeguarding Supplementary Regime came into force on 7 May 2026. It introduces a wide range of measures to strengthen safeguarding practices, including monthly reporting, daily reconciliations, the requirement to maintain a resolution pack and annual audits. Lumiel helps firms understand the regime's requirements, strengthen controls and build compliant frameworks.
Key requirements and how Lumiel supports your regulatory compliance
Governance Framework
Assessing your governance arrangements including a check of processes to meet enhanced notifications and breach reporting requirements.
Monthly FCA Returns
Checking the compliance of your monthly returns which are due within 15 days of each month end.
CASS 10A Resolution Pack
Reviewing pack readiness against the 48 hour submission timeline, supporting with process improvements and implementing automated solutions.
Annual Safeguarding Audit
Applicable for most payment firms and when safeguarding more than £100,000, we provide independent challenge of controls and evidence ahead of the annual audit.
Daily Reconciliations
We review and enhance your daily internal and external reconciliations which must be performed at least once each reconciliation day.
Third Party Due Diligence
Review your approach and documented evidence in the selection, appointment and review of third parties for safeguarding arrangements.
Insurance Enhancements
Checking your insurances / guarantees as an alternative to safeguarding relevant funds which must comply with contractual and notification obligations.
Liquid Assets Investments
We assess your approach including liquidity strategy, credit risk policy and procedures when safeguarding relevant funds through investments in eligible, secure, liquid assets.
Is your Safeguarding framework ready for the annual independent audit requirement? Benchmark your current position against PS25/12.
Schedule a Safeguarding ReviewKey Regulatory Sources
PS25/12 Changes to the safeguarding regime for payments and e-money firms
The FCA's policy statement introducing the Safeguarding Supplementary Regime.
FCA Approach DocumentPayment Services and Electronic Money
Helps businesses understand the FCA's approach to implementing the PSRs 2017, the EMRs 2011 and relevant payment services and e-money rules in the FCA's Handbook. Safeguarding is addressed in Chapter 10.