Safeguarding Compliance for Payment & E-Money Firms — PS25
We help payment institutions and EMIs design, audit and maintain safeguarding arrangements that meet FCA requirements — including the enhanced obligations under PS25 from June 2026.
Speak to an ExpertPS25 Deadline: June 2026
The FCA's PS25 policy statement significantly strengthens safeguarding requirements for all payment institutions and electronic money institutions. Annual safeguarding audits become mandatory. Act now to ensure compliance.
What We Do
Safeguarding is one of the most critical regulatory obligations for payment institutions and electronic money institutions. We help firms design, implement and maintain safeguarding arrangements that meet current FCA requirements and prepare for the enhanced obligations under PS25.
PS25 — What Changes
From June 2026, PS25 introduces a statutory trust over safeguarded funds, mandatory annual safeguarding audits, enhanced reconciliation requirements, resolution pack obligations and strengthened record-keeping standards. Firms must demonstrate that client funds are protected at all times and can be returned promptly in the event of insolvency.
Annual Safeguarding Audit
PS25 makes annual independent safeguarding audits mandatory. We conduct safeguarding audits covering fund segregation, reconciliation processes, account arrangements, record keeping and compliance with the safeguarding regulations. Our audit reports meet the FCA's expected standard and provide clear remediation recommendations.
Safeguarding Framework Build
For firms establishing or upgrading their safeguarding arrangements, we design the complete framework: safeguarding policy, daily and periodic reconciliation procedures, account structure, record-keeping standards, internal controls and governance oversight. We ensure the framework meets both current requirements and PS25 obligations.
Safeguarding Account Introduction
We introduce firms to banks that offer designated safeguarding accounts with appropriate terms and acknowledgement letters. We support the account setup process and ensure the documentation meets FCA requirements.
Ongoing Monitoring
We provide ongoing safeguarding monitoring as part of our compliance retainer, including periodic review of reconciliation accuracy, account arrangements and emerging regulatory guidance.
Sectors We Serve
Frequently Asked Questions
Safeguarding requires payment institutions and EMIs to protect client funds by holding them in segregated accounts at a credit institution or insuring them. This ensures client funds can be returned if the firm becomes insolvent.
PS25 introduces a statutory trust over safeguarded funds, mandatory annual audits, enhanced reconciliation requirements, resolution pack obligations and stronger record-keeping standards. These take effect from June 2026.
Yes, from June 2026 under PS25. All FCA-authorised payment institutions and electronic money institutions must have an annual independent safeguarding audit.
SPIs are not required to safeguard under current rules. However, firms approaching the volume threshold for full authorisation should prepare safeguarding arrangements in advance.
Yes. We introduce firms to banks offering designated safeguarding accounts and support the setup process, including appropriate acknowledgement letters.
Daily reconciliation is best practice and will be strengthened under PS25. We help firms implement robust daily and periodic reconciliation processes.
Under PS25, firms must maintain a resolution pack containing all information needed to return client funds promptly in the event of insolvency. We design the pack structure and ensure it is maintained.
Speak to Our Team
Get in touch to discuss how we can support your regulatory and compliance needs.
info@regulatorycounsel.co.uk | 2 Frederick Street, London WC1X 0ND