Brief Guide to Safeguarding regime for PSI and EMI coming in 2026
....a follow-up to our previous post.....
Requirement for annual Safeguarding audits by qualified auditors. A threshold of £100,000 relevant funds, under which Payment Services Institution (PSI) and E-Money Institution (EMI) will not be required to arrange a safeguarding audit under SUP 3A.
SUP 3A.3.3G clarifies that PSI and EMI are not required to appoint the same auditor for their safeguarding audit and their statutory audit. Although the firms may appoint the same auditor if they wish to do so.
The PSI or EMI can choose whether it wishes to align its Safeguarding audit period to its financial year end. SUP 3A.9.7R sets out that the period covered by a safeguarding report must not end more than 53 weeks after the period covered by the previous report, or after the firm becomes subject to the rules.
The requirement for a limited assurance audit for PSI and EMI holding no relevant funds will no longer apply.
Submission of monthly safeguarding return to FCA for applicable PSI and EMI.
Firms to conduct daily checks to make sure the right amount of money is being safeguarded to protect customers. Internal relevant funds reconciliations are required daily but not on the weekends and bank holidays.
Better planning if firms fail so customers receive their money back sooner. As reference made in our previous guide, CASS 10A will come into play and require PSI and EMI to maintain CASS Resolution pack.