The 7 May 2026 effective date for CASS 15 marks the most significant overhaul of safeguarding rules in a decade. For Payment Institutions (PIs) and Electronic Money Institutions (EMIs), the shift from a principles-based regime to the prescriptive, controls-driven environment of the Client Assets Sourcebook (CASS) is a major operational hurdle.

On 4 February 2026, legislation was passed in Parliament which brings cryptoassets within scope of the Financial Services and Markets Act 2000, and subject to regulation by the Financial Conduct Authority, from October 2027.

In 2026, the cost of maintaining an in-house KYC and AML operation has reached an all-time high. Between the 70% talent shortage affecting the fintech sector and the rising technical debt of legacy monitoring systems, firms are struggling to balance regulatory rigour with commercial viability.