Here you will find six FCA CASS safeguarding compliance tips every UK firm should review for the 2025/26 regulatory cycle.
Six FCA CASS Safeguarding Compliance Tips for Firms
1. Master the CASS Fundamentals First
- Review CASS arrangements against the core principle: client assets must be kept safe, segregated, and protected
- Train staff to understand their responsibilities
- Document processes clearly for regulators
Training: CASS for Beginners at leamancrellin.co.uk covers regulatory requirements, best practices, and lessons from past failures.
2. Understand What Regulators Look For
- Demonstrate real-time visibility of client asset positions
- Show how you identify and resolve CASS breaches quickly
- Provide management information that gives the complete picture
Training: CASS Support Functions course helps teams understand three lines of defence and develop monitoring tools.
3. Address Common Compliance Pitfalls
- Carry out daily reconciliations on all reconciliation days (excluding weekends, UK bank holidays, and relevant foreign market closures under CASS 15)
- Resolve unclear bank segregation arrangements
- Review dormant client asset procedures
Training: CASS Operations course provides technical rules and practical examples to avoid operational mistakes.
4. Implementing FCA CASS 15 Safeguarding Compliance Tips in Practice (Effective 7 May 2026)
- Plan for mandatory daily reconciliations on reconciliation days (excluding weekends, UK bank holidays, and relevant foreign market closure days)
- Create comprehensive CASS 10A resolution packs with details of safeguarding arrangements, fund locations, agents/distributors, and transfer procedures for potential insolvency
- Upgrade systems to submit monthly safeguarding returns to the FCA within 15 business days of month end
- Focus on today’s safeguarding obligations while monitoring potential trust-based reforms
Status: Final rules published in PS25/12 (August 2025). Firms must comply by 7 May 2026, following a nine-month preparation period.
5. Strengthen Governance and Oversight
- Designate clear senior management responsibility for CASS
- Implement monitoring systems to catch issues before regulators
- Allocate adequate resources to CASS functions
Training: CASS Senior Manager course provides briefings for function holders, while CASS Certification Function course equips certification holders with essential skills.
6. Prepare for Enhanced Reporting and Audits
- Upgrade systems to submit monthly safeguarding returns to the FCA
- Engage auditors early to address emerging CASS assurance expectations
- Plan for annual external safeguarding audits, unless exempt (firms safeguarding £100,000 or less over a continuous 53-week period)
- Ensure safeguarding audit reports are filed with the FCA within four months of the audit period end
Training: All CASS courses at leamancrellin.co.uk help prepare teams for enhanced regulatory scrutiny.
Training and Resources for FCA CASS Safeguarding Compliance
Leaman Crellin provides comprehensive CASS training, delivered by experienced compliance professionals and former regulators, including:
- CASS for Beginners – Essential knowledge for new professionals
- CASS Operations – Technical rules for operations teams
- CASS Support Functions – Monitoring compliance and risk management
- CASS Certification Function – Skills for certification holders
- CASS Senior Manager – Briefings for senior management
These FCA CASS safeguarding compliance tips will help your business meet all current FCA requirements and maintain strong compliance.
