PS25 Safeguarding Compliance
FCA-compliant safeguarding arrangements for UK payment institutions and electronic money institutions. Deadline 7 May 2026.
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Your enquiry
The FCA safeguarding rules in PS25/12 have applied since 7 May 2026 to all UK authorised payment institutions, authorised EMIs and small EMIs, including the monthly REP027 return.
Speak to a licensing expertWhat we do
The FCA's Policy Statement PS25 introduces significantly enhanced safeguarding requirements for all UK payment institutions and electronic money institutions. These changes represent the most substantial reform of safeguarding regulation since the Payment Services Regulations were introduced.
The new requirements cover enhanced segregation of customer funds, more frequent reconciliation, strengthened governance and oversight, improved record-keeping, and new reporting obligations. Compliance is mandatory from 7 May 2026.
Our PS25 safeguarding service helps firms understand the new requirements, assess their current arrangements against the enhanced standards, and implement the necessary changes before the deadline.
Gap Assessment
We assess your current safeguarding arrangements against PS25 requirements and identify gaps.
Framework Design
We design enhanced safeguarding policies, procedures, and controls compliant with PS25.
Implementation
We support implementation including system changes and process updates.
Testing & Assurance
We test your enhanced arrangements to verify compliance before the deadline.
What's Included
PS25 Gap Assessment Report
Detailed analysis of your current arrangements against PS25 requirements.
Enhanced Safeguarding Policy
Updated safeguarding policy suite compliant with PS25 requirements.
Reconciliation Process
Designed and documented internal and external reconciliation procedures performed on each reconciliation day, meeting CASS 15 standards.
Governance Framework
Board-level safeguarding oversight arrangements and reporting.
Auditor Engagement
Support engaging an independent auditor for safeguarding assurance.
Ongoing Monitoring
Post-implementation monitoring and periodic assurance reviews.
Who this service is for
Firm types
- - FCA-authorised payment institutions
- - FCA-authorised EMIs
- - Small EMIs (SEMIs)
- - Firms using insurance-based safeguarding
Situations & Triggers
- - Preparing for the 7 May 2026 PS25/12 deadline
- - Responding to FCA safeguarding findings
- - Setting up safeguarding for the first time
- - Reviewing adequacy of existing arrangements
Why firms choose Regulatory Counsel
200+ licence and registration engagements
Applications taken through regulators in the United States, the United Kingdom, Europe, Canada, Australia, the Middle East and Asia.
Senior-led
The same senior practitioners run your engagement from the first assessment to the last regulator question.
Every regulated sector
Payment, e-money, money transmission, crypto, banking, lending, insurance, mortgage and investment firms.
In writing, the same day
Every enquiry is answered the same business day, and scope, timeline and fees are set out in writing before work begins.
Related insights
Opening a Safeguarding Account: A Practical Guide for UK Payment Institutions
A safeguarding account is a segregated account, at an approved bank or the Bank of England, that holds customers' money apart from the firm's own. This guide covers which banks qualify, the CASS 15 acknowledgement letter and the controls the FCA expects from day one.
FCA Compliance for UK Payment Institutions: Requirements, Safeguarding and Supervisory Expectations
What UK payment institutions must do in 2026: authorisation and capital, CASS 15 safeguarding in force since 7 May 2026, the annual audit, agents, financial crime, incident reporting and the FCA's payments priorities.
FCA Compliance for Electronic Money Institutions: Requirements, Safeguarding and Supervisory Expectations
What UK electronic money institutions must do in 2026: authorisation and capital, CASS 15 safeguarding, own funds under Method D, redemption rights, distributors, reporting and the FCA's payments priorities.
Ready to get started?
Every enquiry is answered the same business day, with a written proposal.
Speak to a licensing expertFrequently asked questions
PS25 is the FCA's Policy Statement introducing enhanced safeguarding requirements for UK payment institutions and EMIs. It strengthens rules around protecting customer funds.
The PS25/12 Supplementary Regime comes into force on 7 May 2026. All authorised payment institutions, authorised EMIs and small EMIs must be fully compliant by this date.
Key changes include enhanced fund segregation, more frequent reconciliation (daily), strengthened governance oversight, improved record-keeping, and new regulatory reporting on safeguarding.
Potentially. PS25 may require changes to your safeguarding account arrangements. We assess your current arrangements and advise on any necessary changes.
Non-compliance could result in enforcement action, restrictions on accepting customer funds, financial penalties, and in serious cases, cancellation of authorisation.
Yes. We provide ongoing monitoring, periodic assurance reviews, and management reporting to ensure maintained compliance.
No. PS25/12 does not apply to Small Payment Institutions (SPIs). The FCA has confirmed that SPIs may voluntarily opt in to the safeguarding regime but are not required to comply. PS25/12 applies to authorised payment institutions, authorised EMIs and small EMIs.
Costs depend on the current state of your safeguarding arrangements and the extent of changes needed. We provide fixed-fee proposals after an initial assessment.