CASS 15
CASS 15 tightens the safeguarding screws: fixing the cracks, strengthening compliance and keeping consumer money exactly where it should be.
CASS 15 is on the way and we’ve got you covered.
From 7 May 2026, a new supplementary regime will tighten safeguarding rules and raise standards for all in-scope payment and e-money institutions. So what’s changing, and what do you need to know?
Until now, annual audits by a qualified auditor weren’t mandatory, many safeguarding reviews were handled by compliance advisors. From 7 May 2026, that changes. FinTechs are fast, lean, and always chasing growth or funding, which makes it tricky to keep internal governance and regulatory frameworks as sharp and robust as they need to be.
The key changes being introduced are:
Improved books and records
- Perform daily reconciliations (excluding weekends)
- Maintain a resolution pack (CASS10A)
Enhanced monitoring and reporting
- Annual CASS 15 audit (by a qualified auditor)
- Submit monthly safeguarding regulatory returns to the FCA
Strengthening elements of safeguarding
- Conduct due diligence when appointing or reviewing third parties managing or holding funds/assets
How will this impact you
Who is in scope?
- Authorised Payment Institutions (APIs)
- Electronic Money Institutions (EMIs)
- Small EMIs and credit unions issuing e-money
Are there any exemptions?
Yes, for certain small firms that meet all of the following conditions:
- Are not required to hold a safeguarding account (e.g., do not hold customer funds)
- Do not issue e-money or provide payment services
- Are otherwise not subject to safeguarding obligations
- Remain below the £100k threshold of relevant funds (these firms are still required to have adequate arrangements but are not subject to audit)
Navigate CASS 15 with confidence: Expert support, every step. Let our experts guide the way.
- Financially: Ongoing reporting and compliance will cost more than firms are used to.
- Knowledge & experience: Working with trusted compliance advisors will be essential if internal expertise is limited.
- Prioritisation & workload: Daily reconciliations, drafting a resolution pack, and keeping up with all the rules may require extra team resources.
Key dates for your diary
Prepare now for CASS 15 and avoid last-minute pressure.
Get ahead of the CASS 15 changes before the deadlines catch you out. CASS 15 will fundamentally change how firms demonstrate compliance, with strict implementation and audit timelines beginning in 2026.Firms that plan early can transition smoothly, manage risk, and face their first audits with confidence.
7 May 2026
CASS 15 comes into force; all firms must be fully compliant.
End of April 2027
First audit deadline for firms with December 2026 year ends (80 business days after year end).
End of July 2027
First audit deadline for firms with March 2027 year ends (80 business days after year end).
13 November 2027
All audit reports must be filed with the FCA.
Why HaysMac?
Discover a specialist focus on FinTech needs in the heart of London’s thriving entrepreneurial marketplace
We believe that our expertise within financial services, technology and the regulatory environment makes us a uniquely valuable partner for FinTechs. We understand the nuances of working in both regulated and unregulated environments. Our experience in accounting and FinTech allows us to support clients in navigating fast-changing requirements with confidence. Headquartered in central London, we are able to leverage our global alliance to provide solutions to international scale ups and market leaders.
We have a long track record of working with private equity and venture capital firms and understand what investors and their beneficiaries need most. For regulated entities, we know just how rigid the frameworks can be, and so we can support businesses in being as dynamic as possible – in a market where dynamism is non-negotiable.
As a regular sounding board, we help FinTechs to make fast, consequential decisions all the year round
We provide outsourcing services for founders at the start of their journey, giving them the capacity and confidence to do what they do best. To use a sporting analogy, we’re happy to do the unglamorous work in defence, releasing clients to focus their time and effort on scoring goals.
During fundraising rounds, we advise on cash flow and provide transaction expertise around cash remodelling and forecasting. As clients grow, we are on hand to support through international expansion and tax structuring. When clients are looking to exit, we can help deliver a smooth dismount whether listing or selling. Throughout each stage, our FinTech accountants provide technical insight and practical support tailored to the sector.
Not sure what you need?
Our sector teams are equipped with specialists across all service lines, enabling them to assist you with all aspects of your business needs and challenges. Our team combines deep accounting knowledge with a practical understanding of the FinTech landscape, making us a natural fit for growing firms in this space. Have a problem you need help with? Let us find the solution.
Our services
It’s unusual to find specialist sector know-how at every level of an accountancy firm. We like being a bit different at HaysMac. Meet the team member who’s ready to help make an impact. Partner with the best.
Karen Allan
Partner, Co-Head of Financial Services
Per-Olof Ahlstrom
Head of Risk Assurance & Advisory Services
Key contact
Let's talk
Karen Allan Partner, Co-Head of Financial Services
Contact us today to speak with a specialist who understands your needs, and can deliver the support that makes a difference.
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