By Nicky Green - Advisory Director | 11/09/2025

Policy Statement 25/12 – Changes to the safeguarding regime for payments and e-money firms

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With the FCA’s introduction of Policy Statement 25/12, the safeguarding framework for payments and e-money firms is entering a new era. Responsibility for detailed safeguarding requirements now sits within the CASS regime, reflecting the growing importance of protecting client funds as reliance on these firms continues to rise.

This white paper provides a comprehensive guide to the FCA’s new safeguarding rules and their implications for the sector. It explores the rationale behind the changes, key features of the new CASS 15 framework, and practical steps firms must take to adapt.

By strengthening safeguarding arrangements, firms can reduce insolvency risks, improve consumer confidence, and ensure faster return of client funds if things go wrong. For firms operating in this rapidly evolving space, understanding and preparing for these requirements is essential.

Click the link to learn more about how we can support your firm with CASS 

If you would like to discuss the contents of this paper or find out more about how we can support your firm. Please get in touch at hello@square4.com, or a member of the team below.

Nicky Green – Advisory Director & Author 

Chloe Curtis – Principal Consultant

Elliot Cooper – Client Partner 

*Having trouble downloading the white paper? Please reach out to hello@square4.com to receive a PDF copy.*

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