On 7 August 2025, the Financial Conduct Authority (FCA) officially published its long-awaited policy statement, PS25/12, which sets out changes to the safeguarding regime for payments and e-money firms.

Background

In 2024, the FCA consulted on the safeguarding regime for payments firms and proposed new rules and guidance to improve the regime, ultimately to improve the safety of customer funds held by these firms. The proposed changes were to be introduced in two stages:

• ‘Interim rules’ (now the 'Supplementary Regime', which includes the introduction of CASS 15 and associated rules and guidance) - to encourage greater compliance with existing safeguarding requirements, support more consistent record keeping, and strengthen reporting and monitoring requirements.

• ‘End-state rules’ (now the 'Post-Repeal Regime') - to completely replace the safeguarding requirements of the E-Money Regulations (EMRs) and the Payment Services Regulations (PSRs) with the CASS regime.

On 7 August 2025 the FCA released its policy statement PS25/12, which summarises the feedback on its consultation as well as its approach to the Post-Repeal regime. It also sets out final rules and guidance to be included in the FCA Handbook.

Stage 1 - Supplementary Regime

The Supplementary Regime has an implementation period of nine months, with the new Supplementary Regime rules, guidance and related amendments to the Approach Document (see draft Approach Document here) coming into force on 7 May 2026.

The key changes introduced in the Supplementary Regime can be split into three areas:

Improved books and records

Payments firms will be required to:

• Perform safeguarding reconciliations at least once each day, other than weekends