CASS 15: Why ‘Wait and See’ is Not an Option for Electronic Money and Payment Institutions

While Mansion House speeches and political headlines speak of deregulation, the reality on the ground for Payment Institutions (PIs) and Electronic Money Institutions (EMIs) is quite the opposite. The FCA’s CASS 15 rules mark a significant tightening of safeguarding expectations — and enforcement is only heading in one direction.

CASS 15 is not simply another compliance tick-box. It reflects a clear regulatory direction: safeguarding failures in the payment and e-money sectors have been too frequent and too costly. The FCA’s response is a dedicated, standalone safeguarding framework to reinforce existing obligations and drive consistency.

Although the industry is still awaiting further FCA clarification later this year, the direction of travel is already clear. Our understanding from discussions with the industry is that preparedness across the sector remains alarmingly low. This mirrors historic patterns: even long-standing CASS 7 firms often struggle with embedding these principles fully into operational models. Enforcement action has been a clear reminder — the FCA expects safeguarding to be more than just policy documents; it must be evidenced through governance, reconciliation, and oversight.

For EMIs and PIs, the message is clear:

• Don’t underestimate the depth of review the FCA expects.

• Start your CASS 15 readiness with a proper gap analysis — not assumptions.

• Governance structures must clearly own safeguarding risks.

At Phoenix FSC, we help firms translate rules into practical frameworks — not just to comply, but to protect their reputation and their clients’ money.

Safeguarding isn’t going away. Neither should your attention to it.

If you’d like to discuss how ready your safeguarding model really is for CASS 15, get in touch.