Question 1

What is CASS 15?

Accepted Answer

It is the FCA’s new, prescriptive regulatory framework that moves Payment and E-Money Institutions into the strict "CASS" style safeguarding regime previously reserved for investment firms.

Question 2

Who exactly is in scope?

Accepted Answer

All Authorised Payment Institutions (APIs), E-Money Institutions (AEMIs), and Small EMIs must comply; Small PIs may voluntarily opt-in to the same standards.

Question 3

What is the "Supplementary Regime" implementation date?

Accepted Answer

The rules officially come into force on May 7, 2026, providing a firm deadline for all system, control, and policy upgrades.

Question 4

Is there an exemption for smaller firms?

Accepted Answer

Firms that have never safeguarded more than £100,000 in relevant funds during the previous 53 weeks are exempt from the mandatory annual audit, though all other rules apply.