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Regulatory scrutiny of safeguarding arrangements in the UK has intensified, with the Financial Conduct Authority (FCA) increasingly focused on whether firms can demonstrate that customer funds could be returned promptly in the event of an insolvency.
The new safeguarding rules are outlined in an FCA policy statement, PS25/12, published in August 2025, with key changes to the regime for payment institutions and e-money institutions.
One vital element of the updated rules on safeguarding, which take effect on May 7, 2026, is the creation of a CASS 15 resolution pack.
This is a core component of any firm’s safeguarding framework, and will be assessed on whether it enables a third party to reconstruct customer balances, validate safeguarding positions and execute fund returns without delay or reliance on internal knowledge.
The regulator expects payments firms to familiarise themselves with the updated rules and establish systems and controls to ensure compliance.
However, recent supervisory engagement has highlighted recurring weaknesses, including:
- Inconsistencies between customer records and safeguarding accounts.
- Inability to produce accurate, timely data extracts.
- Over-reliance on key individuals or systems to interpret information.
- Resolution packs that are technically complete but operationally unusable.
Firms should therefore ensure that their resolution pack is:
- Data-driven, with reconciled and clearly structured customer-level information.
- Executable, with step-by-step processes that can be followed by a third party.
- Resilient, with access to critical data and systems not dependent on specific individuals or single points of failure.
The FCA has been clear on what it wants from payment and e-money institutions. Firms must evidence not only that safeguarding arrangements exist, but that they would function effectively under stress.
A well-constructed and regularly tested resolution pack is central to meeting this expectation and mitigating the risk of harm to customers.
About this checklist
To help firms build and maintain a complete, accurate and readily accessible resolution pack, Vixio has created this guide, which breaks down the CASS 15 requirements into actionable workstreams that organisations can use to ensure their documentation is complete.
If users follow the steps accurately, they should be able to create packs that would enable an insolvency practitioner to identify, access and return safeguarded funds without delay.
KEY REQUIREMENTS (DOWNLOAD HERE FOR OWN CHECKLIST)
OTHER CONSIDERATIONS
COMMON PITFALLS TO AVOID
- Overly high-level documentation that lacks operational detail
- Inconsistent data between reconciliation records and customer balances
- Missing or outdated safeguarding account documentation
- Reliance on key individuals rather than documented processes
- Resolution packs that are technically complete but not usable in practice
PRE-SUBMISSION CHECKS
- Can a third party understand the firm’s safeguarding model without explanation?
- Can customer balances be reconciled to safeguarding accounts immediately?
- Can required data be extracted quickly and in a usable format?
- Can all key systems be accessed without relying on a single individual?
- Can funds be returned using only the information contained in the pack?
