The FCA’s Policy Statement PS25/12 delivers the most substantial overhaul to safeguarding and reconciliation obligations in recent years through the introduction of CASS 15. With less than a year before the rules come into full effect, firms must act swiftly to ensure their safeguarding frameworks are compliant and underpinned by robust, technology-driven reconciliation solutions, as now required under the revised regime.

This transition is about more than compliance. It is a fundamental shift in how payments firms and e-money institutions manage financial integrity across their operations.

The challenge: from legacy to live safeguarding

For many firms, the challenge begins with one of the central principles of CASS: maintaining data integrity and independence between firm and client records. Firms often operate without an independent ledger to track cash movements separately from client data, undermining the clear segregation required under FCA rules. This lack of structural independence complicates the reconciliation process, making it difficult to trace the origins, flow, and accuracy of transactional data. As a result, preparing reliable information ready for safeguarding reconciliations becomes an operational and governance challenge in itself.

Lessons from first adopters

Based on our firsthand experience with client implementation projects, several key lessons have emerged for firms preparing to comply with the FCA’s updated safeguarding framework.

1.     Redesign operations, not just reports

Firms must design reconciliation processes to reflect how client assets actually move through their systems and consider the accuracy and usefulness of legacy workflows. This may involve new integrations from payment gateways, banking partners, and source ledgers into a single transactional flow that produces a clear, auditable record, capable of showing where assets move into and out of the perimeter of CASS.

2.     Technology is now essential for governance

Manual reconciliations are neither efficient nor sustainable. Automation not only reduces human error but also strengthens real-time control and provides transparent audit trails.

3.     Governance and documentation matter more than ever

Evidence of decision-making, control design testing, and demonstrating appropriate change management is as important as the reconciliation itself. Firms must demonstrate not just that they have controls in place, but that they are owned, reviewed, and continually improved. Strong documentation reinforces this culture and builds regulator confidence.

Why firms without a cash book face added complexity

Some firms don’t maintain a cashbook as an independent data source when building CASS reconciliations for several practical and structural reasons. Usually, this is rooted in how their systems, processes, and operational models have evolved.  Many firms’ accounting systems weren’t designed with CASS in mind. Historically, client money and firm money were tracked within the same ledger environment, with tagging or account codes distinguishing them. In legacy setups, bank feeds post directly into the general ledger, bypassing a separate cashbook stage.

Some firms rely on automated postings from operational platforms (e.g. trading or payments systems) rather than a traditional manual or semi-manual cashbook.

These reasons undermine the accuracy and independence of a firm’s internal books and records, a critical aspect of CASS compliance.

Grath’s platform was designed to address exactly this issue. By providing a flexible ledger architecture that integrates directly with payment processing systems, Grath allows firms to recreate a digital “cash book” dynamically. Our reconciliation engine consolidates data from multiple banks, accounts, and operational systems, creating a single, real-time view of safeguarded funds.

This gives compliance and finance teams complete oversight, from transaction initiation to safeguarding account confirmation, supported by a transparent and auditable trail.

Turning compliance into a strategic advantage

The transition mandated by CASS 15 represents more than an increased compliance burden for firms. It is an opportunity to reimagine their governance structures and apply quantitative measurements across their operational resilience.

Firms that quickly adopt technology-led safeguarding solutions will find themselves not just compliant but more efficient, more transparent, and held in greater trust by clients and regulators alike. Automating reconciliations reduces operational friction, improves data quality, and provides the kind of evidence regulators increasingly expect to see on demand.

Those who delay may face a scramble to retrofit controls under time pressure. Those that embrace the change will be better placed to demonstrate proactive compliance and to build long-term confidence with customers and regulators.

Building the foundation for resilient safeguarding

Grath’s safeguarding reconciliation platform helps firms navigate this transformation.  Integrating directly with payment systems and banking partners, Grath creates a unified ledger of client funds and enables real-time monitoring across accounts and currencies. 

By embedding safeguarding controls into a single platform, Grath gives firms confidence that every client transaction is accurately tracked, every discrepancy is investigated, and every reconciliation is fully evidenced.

For payments firms, EMIs, and other regulated entities facing the new safeguarding regime, this is not simply a regulatory necessity. It is an opportunity to strengthen governance and unlock sustainable growth.

If your firm is preparing for CASS 15 and wants to modernise safeguarding reconciliations, Grath can help. Our high-performance platform simplifies and automates the preparation and reconciliation of multiple source data, streamlines break management, and supports key regulatory and operational reconciliations, providing continuous oversight and complete transparency across your safeguarding framework.