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The FCA’s safeguarding reforms for payments and e-money firms: an update

25 October 2025 / Author(s): John Budd , Simon Lafferty
Issue: November 2025 / Categories: Feature

The Financial Conduct Authority (FCA) believes clients of payments and e-money firms are exposed to unacceptable risks due to poor safeguarding practices across the sector. The FCA has now published final rules and guidance to address these in PS25/12. The interim-state rules have been modified in several respects, including removing the need for reconciliations on non-working days and exempting firms who have not safeguarded relevant funds from the audit requirement. The implementation period for these changes has been extended from six to nine months. The end-state rules, which included a statutory trust and abolition of the so-called “D+1 rule”, have been paused due to stakeholder concerns.

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