When payments and e-money firms failed between 2018 and 2023, customers lost an average of 65% of their funds. That's not just a regulatory statistic, it's real people losing real money because firms didn't properly protect client assets.

Keith Maner, Manager and Group CASS Lead at Thistle Initiatives, is clear about what's at stake: "No one is exempt, past performance offers no protection if current standards aren't being met, and the FCA is prepared to act firmly as its focus on CASS compliance grows."

What's changing

CASS 15 brings payments and e-money firms under the same rigorous framework that investment firms already follow. The interim rules take effect by end of 2025, requiring:

• Daily reconciliations instead of ad-hoc checks
• Detailed resolution packs for potential insolvency scenarios
• Annual safeguarding audits by independent firms
• Monthly regulatory returns to the FCA
• Statutory trust arrangements that legally protect customer funds

But this isn't just about payments firms. We're seeing increased enforcement across all CASS-regulated businesses, making compliance a priority for every firm holding client assets.

Why this matters for your business

Maner puts it simply: "CASS compliance isn't just best practice anymore; it's a critical safeguard against regulatory action."

Getting CASS wrong doesn't just risk regulatory penalties. It puts your customers' money at risk, damages your reputation, and can threaten your ability to operate. We've seen firms close because they couldn't demonstrate proper client asset protection.

Getting it right, however, builds trust with customers and regulators. It shows you take your responsibilities seriously and have the systems to back that up.

The fundamentals haven't changed

Whether you're working with existing CASS rules or preparing for CASS 15, the core principles remain the same:

• Segregation: Keep client money completely separate from your own funds
• Reconciliation: Know exactly what you're holding and where it is, every day
• Documentation: Maintain records that clearly show compliance
• Governance: Make sure someone senior owns this and understands what's required

The challenge is building systems that work in practice and can demonstrate compliance when regulators ask tough questions.

Get ahead of the curve

We've partnered with Thistle Initiatives to help firms navigate CASS requirements. This 10-step survival guide breaks down what you need to know and gives you practical steps to build robust safeguarding practices.

Whether you're already following CASS rules or preparing for CASS 15, this guide helps you understand the requirements and implement systems that actually work.

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Download the CASS Survival Guide to get practical guidance on building compliant safeguarding practices for your firm.