Safeguarding CASS 15 Readiness (2026 Regime)

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With the new safeguarding regime coming into force on 7 May 2026, firms are now under immediate pressure to ensure their frameworks are compliant and operationally robust.

Many firms believe they are “largely there” — but in practice, we are consistently seeing gaps in core areas such as reconciliations, fund flow mapping, and resolution planning.

This is not just a documentation exercise. The FCA’s expectations now extend directly into how your finance function, controls, and systems actually operate day-to-day.

From 7 May 2026, firms will be expected to operate in line with enhanced requirements, including:

• Daily safeguarding reconciliations (excluding weekends and bank holidays) 
• A clearly defined and documented safeguarding framework 
• A maintained resolution pack to support the return of funds in an insolvency scenario 
• Strengthened books and records, with clear distinction of relevant funds at all times 
• A new monthly safeguarding return to the FCA (with the first submission due shortly after go-live) 

These are not theoretical requirements — they require fully operational processes, ownership, and evidence.

In practice, we are seeing consistent issues across the market:

• No clear end-to-end mapping of how funds move through the business 
• Finance functions not aligned to regulatory expectations 
• Reconciliations that exist in principle, but not in a controlled, auditable format 
• Unclear ownership of safeguarding responsibilities 
• No resolution pack, or one that would not stand up in an insolvency scenario 
• Over-reliance on third parties without sufficient oversight or documentation 

We run a simple, low-cost fixed fee safeguarding audit and readiness review, designed to quickly establish where you stand and what needs to be addressed.

This is not a generic audit — it is a practical, FCA-aligned assessment focused on your actual operating model.

We will:

• Review your current safeguarding and finance framework 
• Map your end-to-end fund flows and identify where relevant funds arise 
• Assess your reconciliation approach against regulatory expectations 
• Review your books and records structure and controls 
• Assess your current (or proposed) resolution pack 
• Identify gaps and provide a clear, prioritised remediation plan 

Where required, we can also support implementation, including:

• Building or enhancing reconciliation frameworks 
• Designing safeguarding operating models 
• Developing resolution packs 
• Updating policies and control frameworks 

The first monthly safeguarding return will be due shortly after go-live, and firms should expect increased FCA scrutiny from day one.

Delays at this stage do not just create compliance risk — they create operational and supervisory risk.

We are currently supporting a number of firms through final implementation and gap remediation ahead of the new regime.  If you would like a clear view of your current position and what needs to be done.