CASS 15 software helps payment institutions and electronic money institutions operate and evidence the Financial Conduct Authority's strengthened safeguarding regime. A complete platform should connect relevant-funds records, internal and external reconciliation, shortfall correction, exceptions, REP027, audit evidence and the CASS 10A resolution pack.
The category is broader than transaction matching. CASS 15 requires an institution to calculate what it should safeguard, establish what it actually safeguards, compare its records with third-party evidence and preserve accountable decisions when the two positions differ.
Key takeaways
- CASS 15 has applied since 7 May 2026 and requires internal and external reconciliation at least once each reconciliation day.
- The software must model the safeguarding requirement and safeguarding resource, not merely match bank transactions.
- REP027, audit evidence and resolution-pack records should derive from the same controlled position.
- Every rule, adjustment, exception and approval needs a reproducible history.
- Safeheld connects these activities in one regulated control workflow.
What CASS 15 software is
CASS 15 software is a system for operating the records and controls required by CASS 15, CASS 10A, SUP 16.14A and the related safeguarding framework.
It should answer five questions for every reconciliation day:
- What relevant funds does the firm owe or hold for clients?
- What qualifying safeguarding resource protects that requirement?
- Do the firm's records agree internally?
- Do those records agree with banks, custodians and other third parties?
- What happened to every shortfall, excess and unresolved difference?
A system that answers only the fourth question is ordinary bank reconciliation software, not a complete CASS 15 platform.
The required control chain
| Stage | Required system output |
|---|---|
| Ingestion | Complete, validated source population with originals retained |
| Classification | Relevant-funds treatment by entity, product and transaction state |
| Internal reconciliation | Safeguarding requirement and resource with component detail |
| External reconciliation | Comparison with independent third-party balances |
| Exception control | Owner, age, cause, action, evidence and escalation |
| Reporting | REP027 figures linked to approved records |
| Assurance | Period evidence, activity history and rule versions |
| Resolution | Current CASS 10A documents and retrieval evidence |
Weakness at the beginning flows through every later stage. If a ledger file is incomplete, a perfectly formatted REP027 return is still wrong.
Relevant-funds logic
The hardest part of CASS 15 is often defining the population. The platform needs approved rules for when money becomes relevant funds, which client it belongs to and when the obligation ends.
The treatment must reflect real products and money flows, including unallocated receipts, fees, chargebacks, refunds, settlement delays, agents, prefunding and foreign exchange. These rules should have named approval, effective dates and test cases.
Safeheld applies controlled classification and calculation logic to the firm's source data. A user can trace a result to the records and rule version that produced it rather than relying on an unexplained workbook formula.
Internal and external reconciliation
CASS 15.8 requires internal and external safeguarding reconciliations as frequently as necessary and at least once each reconciliation day.
The internal reconciliation compares the safeguarding requirement with the safeguarding resource. The external reconciliation compares internal account records with statements or confirmations from banks, custodians and other relevant parties.
Safeheld keeps these controls separately evidenced. That distinction identifies whether a difference arises inside the firm's books or between those books and a third party.
Shortfalls and exceptions
An identified shortfall is not resolved by changing the spreadsheet. The firm needs evidence of the initial position, corrective funding, cause, approval and final outcome.
Safeheld creates an accountable case for material differences. The workflow records ownership, ageing, supporting evidence, remediation and regulatory assessment. Repeat causes can then be reported across cases rather than disappearing inside free-text notes.
Automated matching reduces manual work, but unexplained exceptions remain visible. A high match rate is not useful if the system silently excludes a late or missing source.
REP027 and reporting evidence
REP027 is the monthly safeguarding return under SUP 16.14A. It is generally due within 15 business days after month end.
The return should draw from the same governed reconciliations used in daily control. Safeheld connects the reporting workflow to the approved source position, validations, exceptions, sign-off and submission evidence.
This avoids the common failure where the board pack, daily safeguarding record and filed return show different values for the same date.
Annual audit evidence
The annual safeguarding audit tests operation across a period. The platform therefore needs to preserve original sources, completed runs, changes, exceptions and approvals, not only a clean current dashboard.
Safeheld produces period evidence from the operational record. Historical results remain linked to the rules and data effective at the time, allowing a reviewer to reproduce the position without rebuilding it from email and spreadsheets.
CASS 10A resolution pack
CASS 10A requires prescribed documents to be retrievable as soon as practicable and within 48 hours in the specified circumstances. Key documents should be immediately retrievable.
Safeheld links account information, owners, acknowledgement evidence, procedures and recent reconciliation records to the current control environment. Event-driven updates reduce the drift created by a pack refreshed only before an audit.
Security and governance
A regulated control platform needs role-based access, maker-checker review, activity history, controlled configuration and resilient evidence export. Users who change rules should not be able to conceal the effect by editing completed records.
Buyers should also assess encryption, backup, incident management, recovery, sub-processors and exit portability. The firm must remain able to obtain and use its complete regulatory record.
Why Safeheld
Safeheld is built as a system of record for protected client funds and reserves. It reads bank statement files and figures from ledgers and payment systems, reconciles the position, routes breaks for investigation and produces regulatory and audit evidence from the same controlled data.
The differentiator is not a generic “compliance dashboard”. It is the connection between calculation, reconciliation, correction, reporting and evidence, designed around the operating requirements of regulated payment firms.
Request a Safeheld demonstration using representative ledger and bank data. The demonstration should prove source completeness, a known exception, accountable resolution and reproduction of a completed historical run.
Frequently asked questions
What does CASS 15 software do?
It supports relevant-funds records, safeguarding calculations, internal and external reconciliation, exceptions, REP027, audit evidence and resolution-pack maintenance.
Is CASS 15 software mandatory?
No specific product is mandated. Firms must meet the regulatory outcomes and evidence them. Manual processes become increasingly fragile as volume and complexity increase.
Is CASS 15 software the same as bank reconciliation software?
No. Bank reconciliation compares internal cash records with a bank. CASS 15 software must also calculate the safeguarding requirement and resource and support the wider regulatory workflow.
Can Safeheld replace regulatory judgement?
No. Safeheld operates controlled workflows and evidence. The firm remains responsible for scope, methodology, notifications and submissions.
How should a firm test CASS 15 software?
It should use representative source data and known difficult cases, then test traceability, failed feeds, shortfalls, review, reporting and historical reproduction.