The UK Financial Conduct Authority (FCA) has confirmed new daily safeguarding requirements for payment and e-money institutions, aimed at strengthening consumer protection and addressing risks identified in the sector. Following a final policy statement in August 2025, the changes were clarified in a recent analysis by law firm Mayer Brown on 12 September 2025. The reforms include an obligation for firms to carry out daily internal and external reconciliations, provide monthly safeguarding returns to the FCA, and maintain a “CASS 10A resolution pack” to facilitate prompt fund return in the event of insolvency. Firms have less than nine months to implement these requirements, as the “Supplementary Regime” takes effect on 7 May 2026 (source).
Key Highlights
- Daily Reconciliations: Payment firms must perform daily internal and external reconciliations and promptly resolve discrepancies, using their own funds to rectify shortfalls.
- Monthly Reporting: A new monthly safeguarding return must be submitted to the FCA within 15 business days of each month-end.
- CASS 10A Resolution Pack: Firms are required to maintain an up-to-date pack containing all key information and documents, enabling insolvency practitioners to identify and return client funds more efficiently.
- Annual Audit: Most payment firms must complete yearly safeguarding audits (with limited exemptions for those safeguarding less than £100,000), to be submitted within four months of period end.
- Due Diligence & Asset Diversification: Firms must exercise care in choosing third parties to hold safeguarded funds and diversify where possible.
Background and Objectives
The FCA’s changes address concerns that “some payments firms do not currently have sufficiently robust safeguarding practices,” which the regulator notes “present an unacceptable risk of harm to consumers and market integrity.” Data shows that between Q1 2018 and Q2 2023, failed payment firms had an “average shortfall of 65% in funds owed to clients.” With the use of non-bank payment accounts rising from 1% in 2017 to 12% in 2024 among UK consumers, and e-money institutions safeguarding approximately £26bn, the reforms aim to ensure relevant funds “can be returned to customers as quickly and fully as possible.”
| New Requirement | Applies to | Key Deadline |
|---|---|---|
| Daily Safeguarding Reconciliation | All FCA-authorised Payment Firms (except payment initiation/account information only) | 7 May 2026 |
| Monthly Safeguarding Return | All Payment Firms under FCA supervision | 15 business days after each month-end |
| CASS 10A Resolution Pack | All Payment & E-money Firms | 7 May 2026 |
Practical Considerations for Casino Players
For players relying on fast, secure withdrawals from UK-licensed casinos, these new rules are designed to minimise withdrawal delays caused by firm failure or operational issues. Payment methods such as Apple Pay, PayPal, Trustly, and others may see strengthened safeguards and reduced risk of loss. Customers will benefit from improved transparency, annual audit requirements, and enhanced reporting obligations for payment providers.
The FCA’s full policy details are available via Mayer Brown. For an overview of withdrawal methods and tips on fast payouts, visit our guides to fast payout casinos, common withdrawal issues, safe online casinos, UK casino withdrawals by method, and complete list of withdrawal options.
