PS25 Safeguarding Compliance
FCA-compliant safeguarding arrangements for UK payment institutions and electronic money institutions. Deadline 7 May 2026.
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FCA PS25/12 Safeguarding Deadline: 7 May 2026 — All UK authorised payment institutions, authorised EMIs and small EMIs must comply.
Speak to an ExpertWhat We Do
The FCA's Policy Statement PS25 introduces significantly enhanced safeguarding requirements for all UK payment institutions and electronic money institutions. These changes represent the most substantial reform of safeguarding regulation since the Payment Services Regulations were introduced.
The new requirements cover enhanced segregation of customer funds, more frequent reconciliation, strengthened governance and oversight, improved record-keeping, and new reporting obligations. Compliance is mandatory from 7 May 2026.
Our PS25 safeguarding service helps firms understand the new requirements, assess their current arrangements against the enhanced standards, and implement the necessary changes before the deadline.
Gap Assessment
We assess your current safeguarding arrangements against PS25 requirements and identify gaps.
Framework Design
We design enhanced safeguarding policies, procedures, and controls compliant with PS25.
Implementation
We support implementation including system changes and process updates.
Testing & Assurance
We test your enhanced arrangements to verify compliance before the deadline.
What's Included
PS25 Gap Assessment Report
Detailed analysis of your current arrangements against PS25 requirements.
Enhanced Safeguarding Policy
Updated safeguarding policy suite compliant with PS25 requirements.
Daily Reconciliation Process
Designed and documented daily reconciliation procedures meeting PS25 standards.
Governance Framework
Board-level safeguarding oversight arrangements and reporting.
Auditor Engagement
Support engaging an independent auditor for safeguarding assurance.
Ongoing Monitoring
Post-implementation monitoring and periodic assurance reviews.
Who This Service Is For
Firm Types
- —FCA-authorised payment institutions
- —FCA-authorised EMIs
- —Small EMIs (SEMIs)
- —Firms using insurance-based safeguarding
Situations & Triggers
- —Preparing for the 7 May 2026 PS25/12 deadline
- —Responding to FCA safeguarding findings
- —Setting up safeguarding for the first time
- —Reviewing adequacy of existing arrangements
Why Work With Us
Financial Services Only
We operate exclusively within regulated financial services. Every member of our team has direct regulatory experience in this sector.
Senior-Led Delivery
Every engagement is led by a senior consultant with hands-on regulatory experience — not delegated to junior staff.
Practical, Not Theoretical
We build frameworks that work in practice, not just on paper. Our advice is grounded in what regulators actually expect.
Global Reach
We advise across 65+ jurisdictions, combining local regulatory knowledge with a consistent, high-quality approach.
Related Insights
EMI Safeguarding Requirements Under PS25/12: What Has Changed
PS25/12 introduces the most significant overhaul of EMI safeguarding since PSD2 — statutory trust, daily reconciliation, annual audit and enhanced governance.
PS25/12 Safeguarding Compliance Checklist: What Payment Firms Must Do Before May 2026
A step-by-step compliance checklist for payment institutions preparing for the PS25/12 safeguarding regime, effective 7 May 2026.
Safeguarding Audits Under PS25/12: What EMIs Need to Know About the New Requirements
The new PS25/12 mandatory annual safeguarding audit — what EMIs must prepare, how to select an auditor, and what the FCA expects in the first reporting cycle.
Frequently Asked Questions
PS25 is the FCA's Policy Statement introducing enhanced safeguarding requirements for UK payment institutions and EMIs. It strengthens rules around protecting customer funds.
The PS25/12 Supplementary Regime comes into force on 7 May 2026. All authorised payment institutions, authorised EMIs and small EMIs must be fully compliant by this date.
Key changes include enhanced fund segregation, more frequent reconciliation (daily), strengthened governance oversight, improved record-keeping, and new regulatory reporting on safeguarding.
Potentially. PS25 may require changes to your safeguarding account arrangements. We assess your current arrangements and advise on any necessary changes.
Non-compliance could result in enforcement action, restrictions on accepting customer funds, financial penalties, and in serious cases, cancellation of authorisation.
Yes. We provide ongoing monitoring, periodic assurance reviews, and management reporting to ensure maintained compliance.
No. PS25/12 does not apply to Small Payment Institutions (SPIs). The FCA has confirmed that SPIs may voluntarily opt in to the safeguarding regime but are not required to comply. PS25/12 applies to authorised payment institutions, authorised EMIs and small EMIs.
Costs depend on the current state of your safeguarding arrangements and the extent of changes needed. We provide fixed-fee proposals after an initial assessment.