Ask three people at a payment or e-money firm what “client money” means and you will often get three different answers, and at least one of them will be wrong. That matters more than it used to. Since the FCA’s new CASS 15 chapter came into force on 7 May 2026, firms authorised under the…
Last reviewed: July 2026 Quick answer: CASS 15 requires payment and e-money firms to run two distinct reconciliations — internal and external — on every reconciliation day, comparing what the firm should be safeguarding against what it actually holds. Any shortfall must be corrected from the firm’s own funds by the end of the day…
Last reviewed: July 2026 Quick answer: CASS 15 is the FCA’s new sourcebook chapter setting out detailed, mandatory rules on how payment institutions and e-money institutions must safeguard customer funds. It forms the “Supplementary Regime,” which came into force on 7 May 2026. It requires daily reconciliations, monthly regulatory returns, annual audits (for most firms),…
