Safeguarding Audits
Efficiency and accuracy for payment services and e-money firms.
Our specialist safeguarding team delivers independent reasonable assurance audits for payment services and e-money institutions required to obtain annual assurance over their safeguarding arrangements.
Under the current regulatory framework, we assess compliance with the safeguarding requirements of the Payment Services Regulations 2017 (PSR's) and Electronic Money Regulations 2011 (EMR's), testing the design and operating effectiveness of key controls.
As safeguarding transitions into the FCA’s new CASS 15 regime, our team continues to provide reasonable assurance engagements to support firms in meeting the enhanced requirements.
Safeguarding requirements
The PSRs and EMRs require payment and e-money firms to safeguard relevant funds from the point at which they are received. Firms must maintain robust organisational arrangements to minimise the risk of loss or shortfall, including appropriate internal controls, risk management processes and accounting procedures.
In line with its statutory objective to protect consumers, the Financial Conduct Authority (FCA) currently expects firms to obtain an annual audit of compliance with these safeguarding requirements. As safeguarding is brought within the FCA’s Client Assets Sourcebook under the new CASS 15 regime, firms will be required to comply with the enhanced safeguarding framework and associated audit requirements.
What the auditor opines on
The auditor opines on:
Whether the institution has maintained systems during the year sufficient to meet the applicable safeguarding requirements
Whether the firm complied with those requirements at the end of the audit period
The FCA consulted on the safeguarding regime and submitted its policy statement on the new safeguarding rules in 2025. Our service will evolve in line with policy updates as they are issued, ensuring you can trust that we will always help you to fulfil your audit obligations.
Why work with us?
Audit expertise
As a qualified auditor, we are well‑placed to support your payments or e‑money firm in meeting both the current safeguarding requirements and the forthcoming CASS 15 safeguarding regime. Our audit services are underpinned by extensive experience working with financial services firms across the sector, enabling us to provide robust and informed assurance as regulatory frameworks evolve.
Relationship led approach
Our team dedicates time to learn all there is to know about your business, allowing us to tailor all our services to meet your individual needs.
Regulatory knowledge
With payments and e-money firms facing ongoing regulatory scrutiny and evolving best practice, we stay ahead of the curve, closely tracking changes and maintaining a clear understanding of FCA expectations. This ensures your audits consistently meet the required standards.
Cross sector expertise
Your goals shape our approach. With experience auditing firms across a wide range of sectors, our team brings deep insight and shared expertise to deliver focused, high-quality support that drives your business forward.
FAQs and articles
What did the FCA consult on?
The FCA recently consulted (in CP24/20) on the safeguarding regime as a whole, including audit arrangements. A proposal put forward by the FCA was ultimately to bring safeguarding requirements into the CASS rules, as CASS 15. Please click the following link for our summary of the consultation.
What are my safeguarding audit obligations under the new regime?
Please click the arrow below to see a table summarising the key changes to the safeguarding regime as announced in the long-awaited policy statement PS25/12. On this page we highlight the key impacts that the policy changes will have on the safeguarding audit regime for payments firms.
Are safeguarding audits and CASS audits similar?
Yes. The fundamental principle to protect client funds is the basis of each set of requirements. The procedures followed in each type of audit are designed to provide assurance on whether the firm is following this fundamental principle. Bringing the safeguarding requirements into a CASS chapter enables auditors to streamline their approach and to more efficiently leverage expertise gained on other CASS audit engagements.