In August 2025, the FCA launched a considerable overhaul of the safeguarding regime for payments and e-money firms. The result? PS12/25, a policy statement that makes clear the significant new expectations under CASS 15.

CASS 15 covers any firms which hold relevant funds above the qualifying threshold of more than £100,000, within a 53-week period, or expect to. As the May 7th deadline nears, firms can no longer ‘wait and see’. The requirement for a first CASS 15 audit is on its way, and for a firm to put its best foot forward, the preparation needs to start now.

Be Prepared for CASS 15

The new regulation is a big shift from the existing regime, and the requirement for a regulatory audit by a statutory auditor will make a considerable impact. The FCA has outlined extensive rules, and firms must comply with these ahead of the 7 May.

These changes include the need for daily reconciliations, as well as monthly reporting requirements on safeguarding funds. Planning for firm failures will also be a requirement, via a CASS 15 resolution pack. Similarly, there is the clear provision for the first CASS 15 audit to be completed within 6 months.

Many FinTech firms are run with as few employees as possible, as a way to stay agile. Under CASS 15, this won’t be as simple. Firms need to make sure they are structured correctly, with the right people in the right positions. Management also needs to lead by example, by supporting on regulatory oversight and compliance. The right tone and messaging from the top is particularly important.

Making the Right Partnerships

The new changes make a significant difference, and firms should start working with both a compliance advisor, to support with preparedness reviews, and a statutory auditor, to deliver CASS 15 audits. Finding a team of advisors who understand the rules and requirements in the new world of CASS 15 is key. By establishing strong partnerships now, firms can have a valuable outsourced ‘head of compliance’ to support further down the line. These can be crucial through rule mapping, for example, to identify problems, propose solutions, and deal with structural concerns a firm may have.

The best time to bring in an auditor before CASS 15 would’ve been when the policy was first launched, but the second-best time is now. Management should be engaging with auditors now who provide CASS 15 audits, to ensure they perform the right due diligence in identifying and bringing in the right partners for the job.

Compliance teams and directors should also be asking the right questions. Resources are an important concern, and when choosing an auditor, working out whether they can perform regular audits well, at all stages of a business scaling up, is vitally important. It may seem obvious, but is still foundational. Whether an auditor has the know-how to perform in the new CASS 15 world is key to consider.

Communication is the Key

These conversations should be starting now. Multiple advisors should be in the conversation to find the right match. Each firm is unique, and the audit and financial challenges they face will be different. Setting up a foundation of collaboration now makes sure that this will continue going forward.

The first year of a CASS 15 audit will not be easy. There will likely be a learning curve for the sector as a whole. Most likely, there will be breaches across the industry, and these will be reportable to the FCA. There are therefore likely to be difficult conversations needed with auditors.

Setting up advice and compliance partnerships now is important to avoid disappointment once we reach the 7 May. Starting the groundwork early, and allowing auditors to understand the firm’s entity, means they will more easily be able to recognise risk areas. This helps in developing a CASS 15 audit strategy, which in itself can be an advantage. All stakeholders can ensure that audit work is completed well within the deadline.

CASS 15 is not just an exercise for compliance. It’s an opportunity to use robust governance as an advantage ahead of the rest of the market. The new rules will be an unknown to both firms and investors, and getting your house in order first shows reliability and discipline to investors. In an industry where actions are louder than words, this is very important.

Many firms are now looking to strengthen their compliance at the cutting edge of fintech. If you want to stay ahead of the curve on regulation, and build a company that scales with confidence, approaching an auditor is an obvious next step.

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