Key takeaways
- CASS 10A requires every safeguarding institution that receives or holds relevant funds to maintain a resolution pack at all times.
- Each document must be retrievable within 48 hours of an insolvency practitioner's appointment, or of a request by the FCA or the Bank of England (CASS 10A.1.7R).
- Some items, including acknowledgement letters and the latest reconciliation records, should be retrievable immediately (CASS 10A.1.9E).
- A document that becomes materially inaccurate must be corrected within 5 business days (CASS 10A.1.11R).
- The governing body must receive a report on compliance with CASS 10A at least once a year, and any failure must be notified to the FCA immediately.
What are the key facts on the resolution pack?
The safeguarding resolution pack is a maintained set of documents that lets an insolvency practitioner find and return relevant funds quickly.
| Item | Position |
|---|---|
| Rule | CASS 10A, introduced by PS25/12 |
| Regulator | Financial Conduct Authority |
| Applies to | Safeguarding institutions that receive or hold relevant funds under CASS 15 (CASS 10A.1.1R) |
| Deadlines | Retrieve within 48 hours; correct material changes within 5 business days; annual report to the governing body |
| In force | 7 May 2026 |
| Last checked | 11 October 2026, against the FCA Handbook and PS25/12 |
What is the resolution pack for?
It exists so that an administrator, the FCA or the Bank of England can retrieve the information needed to return customer funds without reconstructing the firm's records.
CASS 10A.1.2G describes three users: an insolvency practitioner appointed to the firm, the Bank of England or the Financial Services Compensation Scheme in a resolution, and the FCA. The need is practical. PS25/12 reports that payments and e-money firms entering insolvency between 2018 and mid-2023 had an average shortfall of 65% in funds owed to customers, and the FCA's cost benefit analysis models the average time to return funds falling from 2.3 years to 1.3 years under the new regime. Our guide to what happens to customer money if a payment or e-money firm fails explains the insolvency process the pack supports.
CASS 10A is a separate chapter from CASS 10, which sets the resolution pack for investment firms holding client money and custody assets. The two are similar in design but apply to different firms, and a group with both types of business may need both packs.
What must the pack contain?
CASS 10A.2.1R lists ten core documents, and CASS 10A.3.1R adds existing records that also form part of the pack.
| CASS 10A.2.1R item | Document | Practical content |
|---|---|---|
| (1) | Master document | Enough information to retrieve every other document in the pack |
| (2) | Institutions holding relevant funds or relevant assets | Each bank, custodian or other institution appointed directly or through an agent or distributor, with full legal name, postal and email address, telephone number and all account numbers (CASS 10A.2.3R) |
| (3) | Agreements with those institutions | Each executed agreement, including side letters and acknowledgement letters under CASS 15.7 |
| (4) | Insurers and guarantors | Each institution providing an insurance policy or comparable guarantee |
| (5) | Policies and guarantees | A copy of each executed policy or guarantee, including side letters |
| (6) | Agents and distributors | Each agent and e-money distributor |
| (7) | Group members | Each group entity involved in operational functions for safeguarding, with entity type, jurisdiction and function |
| (8) | Third-party service providers | Each third party used for operational functions, how to access the information it holds and how to transfer any funds or assets it controls |
| (9) | Procedures | The firm's procedures for managing, recording and transferring relevant funds and relevant assets |
| (10) | Key individuals | The senior managers, directors and others responsible for critical operational functions, and the individual given oversight under CASS 15.2.4R |
CASS 10A.3.1R adds, where applicable, the records kept under CASS 15.4.11R, CASS 15.6.7R, CASS 15.8.3R, CASS 15.8.8R and CASS 15.8.9R (third-party appointments, due diligence, records and accounts, client balances and reconciliation records), the policies required by CASS 15.8.1R, and the standard terms and conditions used with clients. CASS 10A.2.2G gives examples of key individuals: staff who perform reconciliations and record checks, and staff responsible for client documentation.
What is the 48-hour retrieval test?
The firm must be able to deliver each document as soon as practicable and in any event within 48 hours.
Under CASS 10A.1.7R the clock runs from the appointment of an administrator, receiver, trustee, liquidator or similar officer. The same 48 hours applies if the firm decides to retrieve the pack itself, or if the FCA or the Bank of England asks for it. CASS 10A.1.5G makes the expectation clear: the documents should already exist, ready to retrieve, rather than being produced during the 48 hours.
CASS 10A.1.9E goes further for the most important items. Acknowledgement letters, copies of insurance policies or guarantees, the document identifying key individuals and the latest internal and external reconciliation records should be retrievable immediately, and any system the pack depends on should remain operational and accessible after insolvency. Failing these points may be relied on as tending to show a breach of the 48-hour rule.
Group arrangements are permitted. Under CASS 10A.1.6R and 10A.1.8R a document held in another group member's pack can satisfy the requirement, provided that member is subject to the same rule and the arrangements still allow delivery within 48 hours.
How current must the pack be?
The pack must be reviewed regularly, and any document made materially inaccurate by a change must be corrected within 5 business days.
CASS 10A.1.11R sets the 5 business day limit, and CASS 10A.1.12G gives a change of safeguarding bank or custodian as an example of a material change. The pack may be held electronically, provided the retrieval and update duties can still be met (CASS 10A.1.13G). Most of the content changes with ordinary operations: accounts open and close, agreements are renewed, agents join and leave, staff move roles, and every reconciliation day produces a new latest record.
How does the pack connect to the daily reconciliation records?
The reconciliation records are the part of the pack an administrator relies on first, because they show what was owed and held at the last confirmed point.
CASS 15.8.9R requires each internal and external reconciliation to record its date and time, the actions taken, the outcome of the safeguarding requirement and resource calculations and, where relevant, the D+1 comparison. Those records form part of the pack under CASS 10A.3.1R, and the latest of them should be retrievable immediately under CASS 10A.1.9E. A pack that holds only month-end summaries cannot meet that expectation.
Insolvency adds a further step. After an insolvency event the firm, or the officer appointed, must perform an internal reconciliation as soon as reasonably practicable by reference to the time of the event, and an external reconciliation based on the next available statements (CASS 15.8.23R to 15.8.24G and 15.8.44R to 15.8.46R). Both depend on the records and system access the pack describes. In practice this means the pack should explain how to run the reconciliation, not only where past results are stored: the data sources, the reconciliation point, the method in use and who can operate the system. Our guide to CASS 15 reconciliation covers the daily method.
Who oversees the resolution pack?
The governing body receives an annual compliance report, and the firm must tell the FCA immediately if it cannot comply.
CASS 10A.1.14R requires a report on compliance with the chapter to the governing body at least once a year. CASS 10A.1.15R requires written notification to the FCA immediately if the firm has not complied, or cannot comply, with the duty to maintain and retrieve the pack. The individual allocated safeguarding oversight under CASS 15.2.4R is named in the pack itself; see who is responsible for safeguarding.
What does a retrieval drill look like?
A timed drill shows whether the pack can actually be produced inside 48 hours.
Worked example. A payment institution with three safeguarding banks, one custodian, 14 agents and two outsourced providers runs a drill starting at 09:00 on a Tuesday, with the head of finance treated as unavailable.
| Elapsed time | Step | Result |
|---|---|---|
| 0 h 10 m | Master document opened by the nominated deputy | Index lists 31 documents and their locations |
| 0 h 40 m | Immediate items retrieved: acknowledgement letters, latest reconciliations, key individuals | Complete |
| 2 h 00 m | Institutions and accounts document checked against bank records | One account opened 9 business days earlier is not listed |
| 6 h 00 m | Bank and custodian agreements, agent list and procedures retrieved | Agent list shows 13 agents; one appointed last month is missing |
| 26 h 00 m | Outsourced provider access instructions tested | One provider's export takes 20 hours to arrive |
| 31 h 00 m | Pack complete and delivered | Within 48 hours, with three findings |
The drill passed the 48-hour test but found three faults. The missing account and agent entries were both more than 5 business days old, so the pack had been materially inaccurate for longer than CASS 10A.1.11R allows. The firm corrects both, considers whether the failure must be notified under CASS 10A.1.15R, and adds the provider's 20-hour delay to its risk log.
What should a firm check?
These checks keep the pack usable on the day it is needed.
- Map each pack item to CASS 10A.2.1R(1) to (10) and CASS 10A.3.1R, so nothing is omitted.
- Name an owner for each document and a deputy who can retrieve it without the owner.
- Link pack updates to the events that change them: account openings, agent appointments, contract renewals and staff changes.
- Store the latest internal and external reconciliation records where they can be retrieved immediately.
- Confirm outsourced providers can deliver data and transfer funds or assets within the 48 hours.
- Run and time a retrieval drill at least once a year, with key people unavailable.
- Report compliance to the governing body at least annually and record its conclusions.
How does Safeheld help?
Safeheld produces the resolution pack from the same records it uses for daily reconciliation.
Accounts, acknowledgement letters, reconciliation records and the history of every break sit in one place, so the parts of the pack that change most often stay current. See audit and regulatory evidence, the CASS 15 and PS25/12 guide and safeguarding acknowledgement letters.
Frequently asked questions
What is a safeguarding resolution pack?
It is the set of documents CASS 10A requires a payment or e-money firm to maintain so that an insolvency practitioner, the FCA or the Bank of England can identify and return relevant funds quickly.
How quickly must the resolution pack be retrieved?
As soon as practicable and in any event within 48 hours of an insolvency appointment, or of a request by the FCA or the Bank of England (CASS 10A.1.7R).
What must a resolution pack contain?
The ten documents in CASS 10A.2.1R, including a master document, the institutions and agreements holding relevant funds, agents, third parties, procedures and key individuals, plus the records listed in CASS 10A.3.1R.
How often must the resolution pack be updated?
It must be reviewed regularly, and a document made materially inaccurate by a change must be corrected within 5 business days (CASS 10A.1.11R).
Can the resolution pack be held electronically?
Yes, provided the firm can still meet the retrieval and update requirements for each document (CASS 10A.1.13G).
Is CASS 10A the same as CASS 10?
No. CASS 10 is the resolution pack for investment firms holding client money and assets. CASS 10A applies to payment and e-money safeguarding institutions.
What if a firm cannot comply with CASS 10A?
It must notify the FCA in writing immediately (CASS 10A.1.15R).
References
- FCA Handbook, CASS 10A Payment services and electronic money: resolution pack
- FCA Handbook, CASS 15.7 Acknowledgement letters
- FCA Handbook, CASS 15.8 Records, accounts and reconciliations
- FCA, PS25/12: Changes to the safeguarding regime for payments and e-money firms (PDF)
- FCA, PS25/12 policy statement page
About Safeheld
Safeheld is reconciliation and regulatory financial control software for regulated firms that hold client money. It keeps the account register, acknowledgement letters, reconciliation records and break history behind the safeguarding resolution pack current every reconciliation day, and produces the pack on request. To discuss your safeguarding operations, contact us at safeheld.com/contact.
This article is general information on the UK safeguarding rules and is not legal or regulatory advice.