Why payment and e-money firms work with us
Specialist focus
We advise payment and e-money firms on UK and European authorisation, compliance and regulator engagement.
Experience since 2013
We have supported applicant and regulated firms across EMI, Payment Institution and fintech authorisation projects for over a decade.
Safeguarding services for payment and e-money firms
We help payment and e-money firms assess safeguarding arrangements, identify gaps, prepare for FCA expectations and implement practical controls across reconciliations, governance, audits, reporting and resolution planning.
Safeguarding Audits
We review safeguarding arrangements and prepare clear findings and recommendations for boards, auditors or FCA engagement.
Gap Analysis
We assess current safeguarding arrangements against FCA expectations and PS25/12 requirements, then provide a practical remediation plan.
Policy and Procedures Review
We review and strengthen your safeguarding policies, procedures, and governance framework to ensure they meet FCA expectations and are operationally effective.
Ongoing Compliance Support
We provide retained safeguarding support to keep your arrangements compliant as regulations evolve, including periodic reviews, regulatory monitoring, and preparation for your annual audit.
Training
We deliver tailored safeguarding training for your compliance team, finance team, and board, ensuring your people understand their obligations and how to meet them in practice.
Remediation
If the FCA has raised concerns about your safeguarding practices, we help you identify the root causes, implement corrective measures, and engage with the regulator on your behalf.
Preparing for PS25/12 safeguarding changes
The FCA's Supplementary Regime (PS25/12) introduces significant new safeguarding obligations for all authorised PIs and EMIs. These changes represent the most substantial overhaul of the safeguarding framework since the Payment Services Regulations 2017. Firms that are not operationally ready by May 2026 face regulatory intervention, including potential restrictions on permissions.
The key changes include mandatory daily reconciliation of safeguarded funds on every business day, monthly safeguarding regulatory returns submitted directly to the FCA, annual safeguarding audits conducted by a qualified auditor for firms safeguarding over £100,000, appointment of a named senior manager with direct responsibility for safeguarding, board-level approval of safeguarding policies including the definition of material discrepancy, and maintenance of a resolution pack enabling rapid return of customer funds within 48 hours' notice in an insolvency scenario.
Beyond the Supplementary Regime, the FCA's Post-Repeal Regime will eventually replace the existing EMR and PSR safeguarding provisions entirely with a CASS-style statutory trust framework. While the implementation date has not been confirmed, firms should be preparing their infrastructure now.
We help firms assess their current position, identify gaps, and implement the operational changes required to meet both the Supplementary Regime and the eventual Post-Repeal Regime.
Frequently Asked Questions
When does the Supplementary Regime come into force?
The new rules take effect on 7 May 2026. Firms should begin preparation now, as the operational changes required for daily reconciliation, monthly returns, resolution packs, and auditor engagement are significant.
Do I need an annual safeguarding audit?
Under the Supplementary Regime, annual safeguarding audits are mandatory for authorised PIs and EMIs that have safeguarded £100,000 or more over a rolling 53-week period. The audit must be conducted by a qualified auditor. We can manage this for you.
What is the Post-Repeal Regime?
The Post-Repeal Regime will replace the existing EMR and PSR safeguarding requirements with a CASS-style statutory trust framework. Under this regime, customer funds will be held on statutory trust, providing stronger insolvency protection. The implementation date has not yet been confirmed by HM Treasury.
How often should we review our safeguarding arrangements?
We recommend a formal review at least annually, aligned with your safeguarding audit cycle. However, any material change to your payment flows, banking relationships, or business model should trigger an immediate review to ensure your arrangements remain adequate.
Can you support us alongside our existing compliance team or auditors?
Yes. We regularly work alongside in-house compliance teams and external auditors, providing specialist safeguarding expertise to complement your existing resources. We can act as your primary safeguarding adviser or provide targeted support on specific areas.
What if the FCA has already raised concerns about our safeguarding?
We support firms through remediation following FCA supervisory engagement. We identify gaps, implement corrective measures, and can engage with the FCA on your behalf where appropriate.