Preparation is key: CASS 15 for payments and e-money firms

With recent insolvencies revealing a 65 per cent shortfall in customer funds being protected, Oliver Hawes summarises new safeguarding rules for the payments sector and suggests how management teams can prepare for the changes.

Oliver Hawes (ohawes@pkf-l.com) is a director in PKF Littlejohn's Financial Services team with 16 years of experience working in external audit and more than seven years in the financial services sector. He sits on the ICAEW CASS working party.

In September 2024, the Financial Conduct Authority published its proposed changes to the safeguarding rules for payment services and electronic money firms. The aim of the updates is to align the existing safeguarding regime with the current Client Assets Sourcebook (CASS) rules and lead to the creation of a new Chapter 15 of the Client Assets Sourcebook (CASS 15) along with amendments to the Supervision Manual (SUP 3A).