CASS 15: Your first audit, done right
For years, CASS was a world reserved for investment firms – client money (CASS 7), client assets (CASS 6), and complex custody chains. That era is over.
On 15 August 2025, the FCA dropped a major regulatory pivot: the overhaul of the safeguarding regime for payments and e‑money firms. The result? PS12/25 – the policy statement that locks in the new expectations under CASS 15.
With CASS 15 going live on 7 May 2026, any firm holding £100,000+ of relevant funds can no longer afford to “wait and see”. Your first CASS 15 audit is coming, and the groundwork must start now.
Preparedness
The transition from the safeguarding regime to CASS 15 and the requirement to perform a regulatory audit, as executed by a statutory auditor, is a big shift. The FCA has set out the draft rules which firms must comply with from 7 May 2025.
The fundamental changes include:
- The needs for daily reconciliations
- Monthly reporting requirements on safeguarding funds
- Planning for firm failures (implementation of a CASS 15 resolution pack)
- CASS 15 audit to be completed within four months of the year end
Firms need to ensure that they are appropriately structured, the right people are in the relevant positions and that management is demonstrating and supporting on regulatory oversight and compliance (the tone from the top is fundamental).
Finding the right partners
The impact is twofold. Firms should be working with a compliance advisor who understands the rules and requirements, and can support you through a rule mapping exercise identifying and proposing solutions to gaps you may have.
Management should be talking to auditors now who provide CASS 15 audits, ensuring they perform the appropriate due diligence in identifying and onboarding the right partner for the job.
When choosing your auditor, ask yourself:
- Do they have the resources to perform the audit?
- Do they have the appropriate technical expertise to perform the audit?
- Do you feel that they can provide the appropriate levels of challenge?
Communication
Start now! Speak to multiple advisors, find the right match and then make sure that you are in constant communication going forward.
The first year of a CASS 15 audit won’t be easy, and it certainly won’t be clean. You should expect to have breaches which will be reportable to the FCA and you need to be prepared to have difficult conversations with your auditor.
Securing your advisory and compliance partnerships now is important to avoid disappointment closer to the time. It will allow you to start the groundwork early, allowing the audit team to build on understanding the entity and identifying the key risk areas in developing the CASS 15 audit strategy.
It will allow you to work with the auditor in terms of understanding what information will be requested and their expectations of presentation and turnaround, ultimately ensuring that all of the audit work is completed within the four month deadline.
