KEEPING CUSTOMERS’ MONEY SAFE

The FCA has repeatedly highlighted to electronic money institutions (EMIs) and payment institutions (PIs) the safeguarding of customers’ funds as a priority area of concern. Firms are expected to safeguard customers’ funds in line with the Payment Services Regulations 2017 and/or the Electronic Money Regulations 2011 (as applicable), and the FCA’s guidance set out in its Approach Document. If an EMI or PI enters insolvency, its safeguarding arrangements should mean customers’ funds are returned quickly and in full. From May 2026, new rules and requirements will be introduced, resulting in significant changes to the safeguarding regime and regulatory requirements. 

OUR SERVICES

Our experienced team closely monitor the regulatory landscape and help our clients to maintain the highest levels of regulatory compliance. Our e-money and payment services offering includes: 

• Safeguarding Audit: All EMIs and some PIs are currently required to arrange an annual audit of their safeguarding arrangements, including the identification of relevant customer funds, documented process and procedures and reconciliation records. This requirement will extend to all PIs from May 2026, although only statutory auditors will be permitted to perform safeguarding audits from that date. 
• Safeguarding health-check: Although Complyport will not be able to perform a statutory safeguarding from May 2026, it can still deliver a similar assurance programme against the new requirements in the form of an ‘assurance review’ or ‘pre-audit healthcheck’ to better position you ahead of the statutory audit. 
• Safeguarding gap analysis: Given the extensive changes to the safeguarding regime, Complyport can help you with a gap analysis exercise, assessing your level of readiness against the new requirements. 
• Policy Review and Drafting: We assist with reviewing and updating your policies to ensure they align with the new Safeguarding requirements, ensuring that your governance frameworks, reconciliation procedures and book and records meet the new standards. 
• Training and Development:  We provide comprehensive training programs to ensure that your staff understand and can implement the safeguarding principles and requirements, staying informed and compliant as the regime evolves. 

KEY BENEFITS 

• Comprehensive Safeguarding Support: Whether transitioning from the old regime to the new regime, or safeguarding for the first time, we provide end-to-end support tailored to your needs. 
• Enhanced Consumer Outcomes: We help you ensure that you correctly identify customers’ funds and ensure that they are protected and kept separate from your own funds, in line with FCA’s expectations. 
• Proactive Gap Analysis: Our Impact Assessment offers a clear picture of where your firm stands in terms of compliance, with actionable solutions to address any shortfalls. 
• Custom Solutions: Whether you need support with policies, training or the entire safeguarding process, we provide bespoke services that align with your business model.