The CASS Resolution Pack: What It Is, What Belongs In It, and How to Keep It Audit-Ready
Last reviewed: July 2026
Quick answer: A CASS Resolution Pack (RP) is a structured set of documents, mandated under CASS 10A for payment and e-money firms (and CASS 10 for investment firms), that allows an administrator or insolvency practitioner to quickly identify and return customer funds if a firm fails. It isn’t a wind-down plan, and it isn’t optional. The FCA expects it to be complete, accurate, and retrievable — in some cases immediately, and in all cases within 48 hours of a request.
For background on the wider reform this sits within, see our guide to CASS 15 and the Safeguarding Supplementary Regime.
Why the Resolution Pack exists
The FCA’s rationale for the Resolution Pack requirement is grounded in real firm failures, not theoretical risk. In reviewing insolvencies between Q1 2018 and Q2 2023, the FCA found firms consistently lacked readily available, organised information about their own safeguarding arrangements — which meant administrators had to piece together where customer money actually was, often causing significant delay in returning it. The average shortfall between funds owed to customers and funds actually safeguarded, across those failures, was 65%.
The Resolution Pack is the FCA’s direct response: rather than trusting that a failed firm’s records will be usable in a crisis, the regulator now requires firms to maintain, in advance, a standing document set that works as a roadmap for whoever has to unwind the firm — whether that’s the FCA itself, an insolvency practitioner, an administrator, a receiver, or a liquidator.
Importantly, this is a live, standing obligation, not a document you assemble after something goes wrong. The FCA has used surprise visits as a supervisory tool specifically to test whether firms can actually produce their Resolution Pack, and within what timeframe — treat this as something that could be tested at any time, not just something to have ready “in theory.”
CASS 10 vs CASS 10A: which applies to you
- CASS 10 — the original chapter, covering custody assets and client money held by investment firms.
- CASS 10A — the newer chapter, introduced as part of the payments/e-money safeguarding reform, covering “relevant funds” held by payment institutions, e-money institutions, small e-money institutions, and credit unions issuing e-money.
The content requirements under the two chapters are broadly consistent in structure, though the underlying detail differs to reflect the different nature of the assets involved — client money and custody assets under CASS 10, versus relevant funds under CASS 10A. If you’re a payments or e-money firm, CASS 10A is your starting point; the concept will likely be new to your business even if it’s long-established for banks and investment firms.
What should be in the Resolution Pack
There is no single fixed template, but the FCA expects a comprehensive, structured record. In practice, most Resolution Packs need to include:
The master document An index document giving enough detail to locate every other document in the pack — including where each one is held, its retrieval deadline, and when it was last reviewed. This is the document an administrator sees first, and it needs to actually work as a map.
Institutional and account detail
- Details of every institution holding relevant funds or custody assets on the firm’s behalf (banks, custodians)
- Full details of safeguarding accounts, including account identifiers, the credit institution involved, and confirmation the account is correctly designated
- Executed agreements with those institutions, including acknowledgement letters confirming the account status
Third-party and distribution network detail
- Details of agents, appointed representatives, distributors, or other third parties involved in handling or distributing relevant funds
- Details of any group entities involved in safeguarding arrangements
- Client contracts relevant to safeguarding
Governance and protection detail
- Details of directors and key personnel responsible for safeguarding
- Insurance or guarantee policies relied on as part of the safeguarding method, where applicable
- A clear narrative overview of the firm’s safeguarding arrangements — how funds are received, held, reconciled, and protected in practice, not just in policy
Reconciliation evidence
- Records of the firm’s internal and external reconciliations relating to relevant funds, since these are what an administrator needs to establish what should be there versus what actually is
In total, firms typically end up with 20 or more individual documents or records feeding into a complete pack — this is a genuinely substantial compliance artefact, not a single policy document.
Retrieval timelines and accuracy standards
Two operational standards matter most in practice:
- Retrieval speed. Component documents must be retrievable either immediately or within 48 hours of a request, depending on the document. Firms should not treat the 48-hour window as a target to design toward across the board — some documents are expected to be available on demand.
- Accuracy and correction. Any inaccuracy identified in the Resolution Pack should be corrected promptly, and in any case within five business days of the change in circumstances that caused it. A pack that’s accurate on the day it’s built but not maintained will fail a real test.
The Resolution Pack must be reviewed at least annually, and firms should expect to report on their compliance with the Resolution Pack rules at board level as part of that cycle.
Common pitfalls
- Treating it as a one-off project. The Resolution Pack decays the moment banking relationships, agents, or account structures change. Without an owner and a review trigger tied to operational change, it goes stale fast.
- Building the index without the underlying documents actually being retrievable. A polished master document that points to records nobody can locate within 48 hours doesn’t meet the standard.
- Treating CASS 10A as identical to CASS 10. The structure is similar, but relevant funds under a payments/e-money model — often high-volume, funds-in-transit, time-critical reconciliations — carry a different risk profile to custody assets and client money held by an investment firm. The FCA expects the pack to reflect the firm’s actual model, not a generic template.
- No board-level ownership. Given the FCA expects annual reporting on Resolution Pack compliance, this can’t sit purely with an operations or compliance analyst — it needs senior sign-off.
How to test your Resolution Pack
A pack that has never been tested is a pack you don’t actually know works. A reasonable testing cycle includes:
- Desktop review — confirm every document referenced in the master index actually exists, is current, and is where the index says it is.
- Retrieval drill — have someone outside the usual document owner try to retrieve the full pack within the required timeframe, exactly as an administrator or FCA supervisor would request it.
- Scenario walkthrough — talk through a hypothetical insolvency event and check whether the pack, as it stands, would actually let a third party identify and return funds without needing to ask your team follow-up questions.
- Board reporting — feed the outcome of the above into your annual board report on Resolution Pack compliance, with any gaps logged and assigned an owner and a deadline.
Frequently asked questions
Is the Resolution Pack the same as a wind-down plan? No. A wind-down plan addresses how the firm itself would cease trading. The Resolution Pack is specifically about returning customer funds quickly and is a separate, additional requirement.
Who can actually ask to see our Resolution Pack? The FCA, an insolvency practitioner, an administrator, a receiver, or a liquidator — anyone with a legitimate role in resolving the firm or protecting customer funds.
How often do we need to review it? At least annually as a formal review, but individual documents need correcting within five business days of any change that makes them inaccurate — the annual review is a floor, not a substitute for ongoing maintenance.
We’re a small payment institution — does this still apply to us? The Resolution Pack requirement applies regardless of the audit exemption threshold that applies elsewhere in the safeguarding regime. Size may affect how many documents you need, not whether the obligation applies.
This page is for general information only and does not constitute regulatory or legal advice. Firms should refer to the FCA Handbook (CASS 10 and CASS 10A) directly and seek advice specific to their circumstances.
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