The safeguarding return

Alongside the day-to-day safeguarding rules, payments and e-money firms in scope of CASS 15 must submit a monthly safeguarding return to the FCA. This guide covers what the safeguarding return requires and where firms may need stronger governance.

The safeguarding return must be submitted within 15 business days after the end of each calendar month.

The first submissions were due in July 2026. Firms were not required to submit a return for the first month of implementation.

The FCA Handbook SUP 16 Annex 29BR contains a template for the return, with notes explaining the detail needed in each section. The information it asks for includes:

• the amount of relevant funds segregated;
• the institutions and other third parties where the firm has placed relevant funds;
• third parties used to insure or guarantee the return of funds in the event of insolvency;
• secure liquid assets held during the reporting period;
• third parties used to outsource operational functions;
• any notifiable CASS breaches in the period; and
• the audit firm appointed, if the firm is in scope of the audit.

Governance considerations

A return is only as reliable as the process behind it. We see four areas firms should get right.

1. 1

   Ownership and accountability

   An accountable owner should oversee the return, with clearly documented responsibilities across functions. Section owners should ensure their inputs are complete and accurate before submission to the FCA.

2. 2

   Data integrity controls

   Inputs should be verified. What appears on the return should agree with the firm's books and records and its reconciliations, with no disparities between them. Any adjustments should be documented, justified and reviewed.

3. 3

   Review, challenge and sign-off

   The person signing off the return should challenge the inputs, investigate unusual month-on-month movements and document the findings. Retain evidence of review and approval before submission.

4. 4

   Reporting the results

   Variance analysis from the return should be considered for the relevant governance committee, on an ad hoc basis depending on the firm's model.

The practical message is that a reliable return depends on the controls behind it. Clear ownership, figures reconciled to the firm's books and records, and documented review and challenge help firms submit accurate returns.