IQ-EQ Compliance Director, Philip Buckingham, has co-authored an article with Gravita Audit Partner, Dan Rose, for FT Adviser examining the Financial Conduct Authority’s proposed Cass 15 rules and their implications for electronic money institutions and payment service providers.
Read the full article:
FCA rules are changing for e-money firms
The article explores how the FCA’s proposals will introduce new safeguarding, reporting and audit requirements for firms holding client money, reflecting a broader regulatory focus on strengthening client asset protection across the financial services sector.
With implementation confirmed for 7 May 2026, firms have just six months to prepare for significantly heightened scrutiny. The new framework requires firms to build stronger internal systems, create comprehensive Cass resolution packs, align operations with investment firm expectations, and appoint experienced Cass auditors.
For many e-money and payment firms facing their first Cass audit, this represents a fundamental operational shift. Early preparation is essential – firms should conduct detailed impact assessments, perform gap analyses, review technology infrastructure for real-time reconciliation capabilities and engage experienced auditors well ahead of implementation.
