CASS 15 Templates for Safeguarding Institutions
Apr
Summary
The FCA’s Client Assets (CASS) Sourcebook has been a part of the financial services regulations for more than 20 years. The rules contained in CASS apply to regulated firms who hold or control client money or client assets. As of 7th May 2026, the CASS sourcebook will also apply to electronic money institutions and payment institutions.
To remain consistent with existing regulations for both types of provider, the revised and new CASS modules refer to these firms as safeguarding institutions. This article sets out the new regulations applying to these institutions and the CASS templates we have now published.
What is CASS?
CASS stands for Client Assets Sourcebook and forms part of the business standards portion of the FCA handbook. It applies to any regulated firm, electronic money institution or payment institution that holds or controls client money and safe custody assets. The aim of the rules and guidance in CASS is to ensure adequate protections and controls for safeguarding client assets should a firm fail and/or exit the market.
FCA Principle 10 Clients’ Assets – “A firm must arrange adequate protection for clients’ assets when it is responsible for them”.
CASS Resolution Pack
In addition to the rules and requirements firms must follow in the CASS sourcebook, they must also adhere to CASS 10 and CASS 10A which set the requirements for a CASS Resolution Pack. This pack is a collection of records and documents required by the sourcebook for firms holding client money and/or safe custody assets. The aim of the resolution pack is to ensure quick and easy access to essential documents and information should the company fail. It provides bodies such as the FCA, an insolvency practitioner or a liquidator to safeguard, access and and administer client assets.
Safeguarding Institutions
As of May 2026 electronic money institutions and payment institutions (safeguarding institutions) have obligations under the CASS sourcebook. Pursuant to Regulation 20 of the Electronic Money Regulations (‘EMR’) and Regulation 23 of the Payment Services Regulations (‘PSR’), safeguarding institutions are required to safeguard relevant funds. In addition to some of the standard CASS requirements, safeguarding institutions have 2 dedicated CASS modules to apply to them directly.
CASS 15 Payment Services and Electronic Money Relevant Funds
CASS 15 sets out the provisions, rules and guidelines for safeguarding institutions on how to handle relevant funds. The module includes compliance requirements, the relevant funds regime, organisational requirements and oversight.
Module 15 of CASS denotes each institutions’ responsibility to establish, implement and maintain adequate policies and procedures sufficient to ensure compliance with the relevant funds regime.
CASS 10A Payment Services and Electronic Money Resolution Pack
Unit 10A relates to the resolution pack (RP) requirements applicable to safeguarding institutions. It lays out general provisions, core content requirements and existing records that form part of the CASS RP.
The core requirements under CASS 10A.2.1 define the documents, records and written procedures that each safeguarding institution must include within its CASS resolution pack. This includes a master document which contains information sufficient to retrieve each document in the institution’s CASS RP.
Relevant Funds
CASS rules for safeguarding institutions apply to relevant funds. These ‘funds’ are defined by the EMR regulation 20(1) and PSR regulation 23(1) as: –
- Funds received in exchange for electronic money that has been issued.
- Sums received from, or for the benefit of, a payment service user for the execution of a payment transaction.
- Sums received from a payment service provider for the execution of a payment transaction on behalf of a payment service user.
CASS 15 Safeguarding Institutes Templates
We have now revised and added to our popular CASS Manual and Resolution Pack templates. Revisions include sections in the manual that related to the CASS 15 requirements and the provisions applicable to safeguarding institutions. We have also included a notification schedule, setting out all FCA notifications and timeframes required under CASS.
In addition to the above changes, we have now included a CASS 10A Resolution Pack template in Excel. This document provides the full scope of the master document requirements. The resolution pack templates are compliant for authorised payment institutions and electronic money institutions. We have included some of the required RP templates, such as registry of third party institutions and CASS employees. We have kept the original £65 (exc vat) price for the manual to ensure it is affordable for all firms.
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