FCA's PS25/12: Strengthening Safeguarding for E-Money and Payment Firms

Author: Ed Buckman - Chief Commercial Officer - published August 2025

Topics: Safeguarding customer funds, payments, e-money firms,

Regions and Regulators: UK (FCA), Ireland (CBI), Luxembourg (CSSF)

The FCA’s latest policy statement sets out enhanced expectations for safeguarding customer funds. These new obligations, effective from May 2026, are designed to strengthen consumer protection and improve operational resilience across the sector. 

Below, we outline some of the key requirements that Payment and E-Money firms will need to prepare for:

• Daily Reconciliation: Firms must reconcile safeguarded funds daily, ensuring accuracy and timeliness to protect customer money.
• Clear Documentation: Firms must maintain robust documentation of safeguarding arrangements, including how funds are identified and segregated.
• Audit Assurance: Annual audits of safeguarding arrangements are now mandatory, with firms required to submit audit reports to the FCA.
• Enhanced Governance: Firms must embed safeguarding into their governance frameworks, with clear accountability at senior management level.
• Improved Disclosures: Firms must provide transparent disclosures to customers about how their funds are protected, including risks and limitations.
• Wind-Down Planning: Safeguarding must be integrated into wind-down plans, ensuring customer funds remain protected in insolvency scenarios.

Take Action with Confidence

Navigating the new FCA safeguarding rules requires clarity and precision. Ruleguard is the leading CASS compliance platform, trusted by firms across financial services to manage regulatory obligations with confidence. If your firm is preparing for these changes, now is the time to ensure your systems and controls are fit for purpose.

Speak to Ruleguard today to ensure your firm is ready.

About the author

Ed is the Chief Commercial Officer at Ruleguard, leading the strategy behind Ruleguard Connect — a platform designed to transform how regulated financial institutions oversee critical third parties.

 

Covering investment managers, fund services delegates, principal firms, and other outsourced functions, our goal is to eliminate manual processes and fragmented tech stacks through scalable oversight technology.

 

With over 20 years in financial services, Ed focuses on building propositions, scaling commercial functions, and simplifying complexity to help firms adapt to an evolving regulatory landscape. Open to strategic partnerships and collaboration to drive industry progress.

 

Contact Ed