In short
The FCA has issued one enforcement outcome for safeguarding failures at a payment or e-money firm: the public censure of Premier FX on 23 February 2021. No financial penalty for safeguarding has ever been imposed on a payment institution or e-money institution. Every other case is a supervisory requirement, a special administration or a court judgment, and the shortfalls are reported by courts and administrators, not by the FCA. The FCA's own figure for 12 firms that failed between 2018 and mid-2023 is an average 65% shortfall in the money owed to customers.
Key takeaways
- One censure, no fines: Premier FX (23 February 2021) is the only FCA enforcement outcome for safeguarding breaches at a payment or e-money firm, and the penalty was withheld to protect creditors.
- The FCA stated in CP24/20 that 12 safeguarding firms failed between the first quarter of 2018 and the second quarter of 2023 with an average 65% shortfall in the funds owed to customers.
- Court-reported shortfalls are large: Rational FX £14.76 million (expected return 7.7p in the pound), Monneo about €10 million of €28.1 million, LCC Trans-Sending (Small World) paid 48.64p in the pound, Supercapital about £585,000 of £12.6 million.
- Most cases begin with a requirement to stop regulated activity (a VREQ or OIREQ) and end in a special administration under the Payment and Electronic Money Institution Insolvency Regulations 2021.
- The Court of Appeal in Ipagoo (9 March 2022) held that the e-money regulations create no trust, but that the asset pool must be topped up from the firm's general assets to cover any safeguarding shortfall.
- From 7 May 2026 the CASS 15 rules in PS25/12 require daily reconciliation, a monthly return and an annual audit, which is the FCA's answer to the pattern in this tracker: failures found only at insolvency.
What this tracker covers
This page lists every public action by the Financial Conduct Authority (the FCA) that concerned the safeguarding of customer money by a UK payment institution or e-money institution, together with every insolvency of such a firm where the FCA, a court or the administrators reported on the safeguarded funds. Safeguarding means keeping customer money separate from the firm's own money, in a designated account at a bank or covered by insurance, so that it can be returned if the firm fails.
Each entry gives the date, the firm, what happened in plain words, the outcome, the rule involved and a link to the primary source: an FCA notice or news page, a court judgment, an administrators' report or a government review. Where the source does not state a shortfall, the entry says so. Nothing here is taken from press reports alone; items that exist only on the FCA Register and could not be read at source are left out until they can be.
The tracker is kept current as cases land. The date at the top of the page is the date of the last review. For the rules themselves, see the PS25/12 safeguarding guide and the CASS 15 safeguarding audit guide.
The position in numbers
The table counts the cases listed on this page by outcome. One firm can appear in more than one row where a requirement was followed by an administration.
| Outcome | Count since 2018 | What it means |
|---|---|---|
| Enforcement outcome (final notice) | 1 | Premier FX public censure, 23 February 2021. No fine has ever been imposed for safeguarding at a payment or e-money firm. |
| Requirements to stop or restrict business | 11 | Imposed by the FCA (an OIREQ) or agreed by the firm (a VREQ or voluntary undertaking) before or at the point of failure. |
| Special administrations | 15 | Insolvency under the 2021 special regime for payment and e-money firms, including conversions from ordinary administration or liquidation. |
| Ordinary administrations or liquidations | 6 | Premier FX, Ipagoo, Supercapital, Glint, Allied Wallet and Loot, before the special regime existed. |
| Court judgments on safeguarded funds | 9 | Ipagoo (two), Allied Wallet (two), Supercapital, Xpress Money, Rational FX, Monneo and Argentex (two) on how shortfalls are shared and distributions made. |
| Average shortfall at failed firms | 65% | FCA figure for 12 firms that failed between Q1 2018 and Q2 2023 (CP24/20 paragraph 1.3; repeated in PS25/12). |
Cases in 2025 and 2026
Twelve months of new special administrations, two of them preceded by a First Supervisory Notice that set out the safeguarding failings in detail. A First Supervisory Notice is the FCA's formal statement of the requirements it has imposed and why.
- 15 Oct 2026. ePayments Systems Ltd (e-money institution). Entered special administration (Opus Restructuring: Mark Boast and Allister Manson). The FCA says the administrators will assess all funds held to confirm the position. No shortfall stated. Outcome: Special administration. Safeguarding under the Electronic Money Regulations 2011 (EMRs), regulation 20. Source: FCA news.
- 18 Jun 2026. Monevium Ltd (payment institution). Entered special administration (S&W Partners) after a voluntary undertaking restricting its activities on 28 February 2024. No shortfall stated. Outcome: Voluntary undertaking, then special administration. Payment Services Regulations 2017 (PSRs), regulation 23. Source: FCA news.
- 2 and 11 Jun 2026. Euro Exchange Securities UK Ltd (e-money and payment services). The FCA required the firm to cease all regulated activity, citing systemic weaknesses in its financial crime framework and safeguarding arrangements and concerns about ownership and governance. The court appointed interim managers on 4 June and special administrators (Teneo) on 11 June. No amounts stated. Outcome: Own-initiative requirements (OIREQ), interim managers, special administration. Safeguarding under the EMRs and PSRs; financial crime controls. Source: FCA press release and court order.
- 17 Dec 2025. BeAccount Ltd, trading as Payine (authorised e-money institution). First Supervisory Notice: cease e-money and payment services, return all customer funds and notify customers. The FCA's review of nine client files found every one inadequate. The safeguarding bank had ended its relationship with the firm in April 2025, freezing customer funds. No shortfall figure. Outcome: Variation of authorisation with immediate effect. EMRs regulation 11(1) and 6(5)(b); Money Laundering Regulations 2017 regulations 18, 19, 27, 28, 33 and 35; relevant funds under EMRs regulation 20 and PSRs regulation 23. Source: Supervisory notice (PDF).
- 24 Nov 2025. JNFX Ltd (payment institution, foreign exchange). Entered special administration (Azets) after a voluntary undertaking restricting activities on 20 November 2025. No reason or shortfall stated. Outcome: Voluntary undertaking, then special administration. PSRs regulation 23. Source: FCA news.
- 1 Sep and 6 Oct 2025. Currency Matters Ltd (authorised payment institution). The firm told the FCA on 21 August 2025 that it was insolvent. Its reconciliation showed a critical shortfall in relevant funds (amount not stated). Client balances were held with a firm that is not an authorised bank, funds may have been mixed with the firm's own, and misappropriation by an individual over about two and a half years was suspected. About £2 million was stuck with a former payment provider. Special administration (Opus) followed on 6 October 2025. Outcome: First Supervisory Notice with asset restrictions, ring-fencing and weekly bank statements to the FCA; then special administration. PSRs regulation 23 (including 23(6)(a)) and regulation 37; Principle 11. Source: Supervisory notice (PDF) and FCA news.
- 21 Jul 2025. Argentex LLP (e-money institution and wealth manager). Ceased trading on 17 July 2025 and entered special administration (FRP Advisory) after a voluntary requirement agreed on 24 June 2025 and a further restriction on 17 July. The court recorded 302 customers and 3,346 open foreign exchange contracts, with the administrators still reconciling safeguarded funds and client money. No safeguarding shortfall figure yet. Outcome: Special administration; High Court directions [2025] EWHC 2625 (Ch) and [2025] EWHC 3125 (Ch). EMRs relevant funds; CASS 7 client money for the investment business. Source: FCA news, judgment, 15 Oct 2025 and judgment, 27 Nov 2025.
- 7 Jul 2025. Ziglu Ltd (e-money institution). The FCA restricted the firm's products on 23 May 2025; the firm gave a voluntary undertaking on 13 June and agreed to stop payment and crypto activity on 17 June. Special administration (RSM) followed. Cryptoassets were not safeguarded. No safeguarded e-money shortfall stated. Outcome: Requirements, then special administration. EMRs regulation 20. Source: FCA news.
- 14 Apr 2025. Blackthorn Finance Ltd (payment services). The FCA imposed restrictions and an asset requirement on 17 November 2023. A solvent members' voluntary liquidation began on 29 August 2024, but the liquidators concluded the firm did not have enough assets to meet all claims and it was converted to a special administration (S&W). The asset requirement was lifted on 6 October 2025. Outcome: OIREQ in 2023, then special administration. Source: FCA news.
- 10 Feb 2025. Nvayo Ltd (e-money institution). On 8 August 2023 the FCA barred the firm from providing e-money services without consent, citing serious anti-money-laundering concerns. The Upper Tribunal refused to suspend the requirement on 5 February 2024. Special administration (Leonard Curtis) followed on 10 February 2025, with the administrators to assess the safeguarded funds. No shortfall stated. Outcome: OIREQ; Upper Tribunal decision [2024] UKUT 00035 (TCC); special administration. Money Laundering Regulations; EMRs safeguarding. Source: FCA news and tribunal decision.
- 30 Jan 2025. Contis Financial Services Ltd (e-money institution, Solaris group). The directors applied for special administration (Interpath) after a long-running dispute with a third-party institution over the release of customer safeguarded funds blocked an orderly wind-down. No shortfall stated. Outcome: Special administration. EMRs safeguarding. Source: FCA news.
Cases from 2021 to 2024
The period in which the special administration regime was first used (Viola Money, December 2021) and in which the courts settled how a safeguarding shortfall is shared between customers and other creditors.
- 18 Jun 2024. LCC Trans-Sending Ltd, trading as Small World (authorised payment institution, money remittance). Closed to new business on 10 June 2024, gave an undertaking on 13 June and entered special administration (Grant Thornton). The court approved the distribution plan on 13 March 2025 with a final claims deadline of 31 August 2025. The first and final distribution of relevant funds was paid on 3 July 2026 at 48.64 pence in the pound. Outcome: Special administration; court-approved distribution plan. PSRs regulation 23. Source: FCA news and administrators' updates.
- 13 Mar 2024. Silverbird Global Ltd (authorised payment institution). Gave a voluntary undertaking on 11 March 2024 and entered special administration (FRP Advisory). Customer funds held through its principal, The Currency Cloud, sit outside the estate. No shortfall stated. Outcome: Voluntary undertaking, then special administration. PSRs regulation 23. Source: FCA news.
- 29 Nov 2023. Rational Foreign Exchange Ltd, trading as RationalFX (authorised payment institution). The directors found a shortfall in the funds that should have been safeguarded on 26 November 2023; the FCA imposed requirements and the firm entered special administration (Interpath) the same day. The court recorded a shortfall of £14.76 million between relevant funds and eligible claims before costs, an expected return of 7.7 pence in the pound, funds in 134 accounts at 10 banks, and that in early 2022 funds had been swept to an account described as segregated but not safeguarded. Outcome: OIREQ; special administration; distribution plan approved [2025] EWHC 1958 (Ch), 28 July 2025. PSRs regulation 23. Source: FCA news and judgment.
- 6 Apr and 30 May 2023. Monneo Ltd (authorised payment institution). The FCA required the firm to stop providing payment services on 6 April 2023; special administration (FRP Advisory) followed on 30 May. The court recorded 396 customers, about €28.1 million that should have been safeguarded against about €18.8 million held, an original shortfall of about €10 million (revised to about €7.5 million against admitted claims), a top-up of about €3.1 million from the firm's own assets, and recovery of about 65% of relevant funds. Outcome: OIREQ; special administration; distribution plan approved [2025] EWHC 2818 (Ch). PSRs regulation 23. Source: FCA news and judgment.
- 19 Jul 2022. Allied Wallet Ltd, in liquidation (e-money institution). The court applied the Ipagoo ruling to the payment services rules: the pool of safeguarded assets must include the money that should have been safeguarded, any deficiency is made good from the firm's general assets, and only the costs of distributing the pool come out of it. The court noted that significant sums were missing and unaccounted for. Outcome: Judgment [2022] EWHC 1877 (Ch). EMRs regulation 24; PSRs regulation 23(15). Source: Judgment.
- 9 Mar 2022. Ipagoo LLP, in administration (e-money institution). The Court of Appeal held that the e-money regulations do not create a trust over customer funds, but that the asset pool returned to customers must include a sum equal to the funds that should have been safeguarded, with any shortfall made good from the firm's general estate. Ipagoo had received about €3.81 million, £235,854 and US$265,980 from customers; the court described serious non-compliance. The shortfall was not quantified. Outcome: Judgment [2022] EWCA Civ 302. EMRs regulations 20, 21, 22 and 24. Source: Judgment.
- 24 Feb 2022. Allied Wallet Ltd (e-money institution). First-instance directions recorded that only 4 of the firm's 55 bank accounts were operated as safeguarding accounts, that the safeguarding accounts held £362,928 against merchant claims of £21.27 million from 57 merchants, that 4,459 cardholders were owed £654,504, and that a shortfall was almost certain. Outcome: Judgment [2022] EWHC 402 (Ch). EMRs and PSRs safeguarding. Source: Judgment.
- 11 Feb 2022. Xpress Money Services Ltd (authorised payment institution). In June 2020 the FCA required the firm to stop all payment services as it no longer met the conditions of authorisation. On the FCA's application it entered special administration (FRP Advisory) on 11 February 2022. The court approved a distribution plan on 9 February 2023; only about £426,000 reached the administration account from the safeguarding accounts, and claims received totalled under $5,500 from about 1,623 customers contacted. Outcome: OIREQ in 2020; special administration; [2023] EWHC 1120 (Ch). PSRs regulation 23. Source: FCA news and judgment.
- 14 and 21 Dec 2021. Viola Money (Europe) Ltd (authorised e-money institution). The FCA required the firm to stop all e-money and payment services, citing serious concerns about how it was run, then applied for special administration, which the court ordered on 21 December 2021 (Interpath). The first use of the special regime. No shortfall stated. Outcome: OIREQ; special administration. EMRs safeguarding. Source: FCA news.
- 23 Feb 2021. Premier FX Ltd, in liquidation (authorised payment institution, money remittance). The FCA found that the firm told customers their money was held in segregated accounts and protected by the FSCS when it was not, and used new customers' money to pay others. The sole director died in June 2018; the firm stopped trading on 10 August 2018 and went into administration on 13 August 2018. 136 creditor claims of about £9.2 million stood against assets of about £1.84 million. Outcome: Public censure. A financial penalty was not imposed so that creditors would not lose further money. Breach period 1 January 2013 to 13 August 2018. PSRs 2009 regulations 19 and 28; PSRs 2017 regulations 23 and 33. Source: Final notice (PDF) and press release.
Cases from 2018 to 2020
The failures that prompted the FCA's July 2019 Dear CEO letter and its 2020 temporary safeguarding guidance, which introduced the annual safeguarding audit.
- 29 Jun 2020. Supercapital Ltd, in administration (authorised payment institution). The court approved the distribution plan: about £12.6 million of client funds with a shortfall of about £585,000 arising from unrecovered duplicate payments, before costs. The judge held that the payment services rules create a trust, a view later overruled by the Court of Appeal in Ipagoo. Outcome: Judgment [2020] EWHC 1685 (Ch). PSRs regulation 23(14). Source: Judgment.
- 26 Jun 2020. Wirecard Card Solutions Ltd (authorised e-money institution). After the collapse of its German parent, the FCA required the firm to stop regulated activity, not to dispose of assets or funds, and to post a notice on its website, to protect safeguarded e-money. Consent to resume was given on 29 June, effective 30 June, with continuing requirements on where customer money is held and on transfers of the firm's own assets. Outcome: OIREQ, then partly lifted. EMRs regulation 20. Source: FCA news.
- 20 Mar 2020. Allied Wallet Ltd (e-money institution). The High Court wound the firm up on the FCA's petition. Outcome: Winding-up order. Source: FCA statement.
- 27 Sep 2019. Supercapital Ltd (authorised payment institution). Stopped regulated business on 12 September 2019 and entered administration (Griffins) on 27 September. The FCA page states no shortfall; the figure came out in the 2020 judgment above. Outcome: Administration, before the special regime existed. PSRs regulation 23. Source: FCA news.
- 18 Sep 2019. Glint Pay Services Ltd (e-money institution). Entered administration (FRP Advisory) and left it on 19 November 2019 after new investment. The FCA page confirms safeguarding applied to e-money balances but not to customers' gold holdings. No shortfall. Outcome: Administration, firm rescued. EMRs safeguarding. Source: FCA news.
- 24 Jul and 1 Aug 2019. Ipagoo LLP (e-money institution). The FCA's Regulatory Decisions Committee imposed requirements on 24 July 2019: stop regulated activity, no disposal of assets or e-money funds, notify customers. Administration (FRP Advisory) followed on 1 August 2019. Outcome: OIREQ; administration. EMRs safeguarding. Source: FCA news.
- 4 Jun 2019. Allied Wallet Ltd (e-money institution, authorised 2014). The FCA barred regulated activity and asset disposals after the firm failed to disclose a US Federal Trade Commission judgment of $110 million against it, citing concerns about conduct, management and safeguarding arrangements. The FCA applied for provisional liquidation and BDO were appointed on 23 August 2019. Outcome: OIREQ; provisional liquidation. EMRs safeguarding; disclosure duties. Source: FCA statement.
- 29 May 2019. Loot Financial Services Ltd (agent of Wirecard Card Solutions). The agent entered administration. The FCA confirmed that customer funds were safeguarded by the principal e-money institution. No shortfall. Outcome: FCA statement only. EMRs safeguarding by the principal. Source: FCA statement.
- 13 Aug 2018. Premier FX Ltd (authorised payment institution). Stopped trading on 10 August 2018 by agreement with the FCA; the High Court made an administration order on 13 August 2018. The censure followed in 2021 (above). Outcome: Administration. PSRs regulation 23. Source: Final notice (PDF).
What the courts have settled
Four points of law now govern what customers get back when a safeguarding firm fails, and all of them came from the cases above rather than from the regulations.
| Point | Case | Effect for customers |
|---|---|---|
| No trust, but a top-up | Ipagoo, Court of Appeal, 9 March 2022 | Safeguarded money is not held on trust, but the pool returned to customers must equal the amount that should have been safeguarded. Any shortfall is made good from the firm's other assets before ordinary creditors are paid. |
| Same rule for payment institutions | Allied Wallet, 19 July 2022 | The Ipagoo approach applies under the Payment Services Regulations as well as the e-money rules. Customers rank ahead of the general creditors for the top-up. |
| Costs come first | Ipagoo and Allied Wallet | The costs of distributing the safeguarded pool, and of reconstituting it, are paid from the pool. That is why returns such as 7.7p (Rational FX) and 48.64p (Small World) are after costs. |
| Distribution plans need court approval | Supercapital (2020), Xpress Money (2023), Rational FX (2025), Monneo (2025), Small World (2025) | Under the special administration regime a plan setting the claims deadline and the rate of return is approved by the High Court. Payment typically follows a year or more after the firm fails; HM Treasury's December 2025 review found first distributions often take 12 months or longer. |
What the FCA has said, with the numbers it has published
The FCA rarely publishes firm-level findings outside an insolvency, but its letters and policy papers carry the sector-wide numbers behind the CASS 15 rules.
| Date | Document | What it says | Source |
|---|---|---|---|
| 4 Jul 2019 | Multi-firm review and Dear CEO letter | A review of 11 firms found widespread failures: late segregation, poorly designated accounts and infrequent reconciliation. Every e-money and payment institution was told to confirm compliance by 31 July 2019. | Review and letter (PDF) |
| 9 Jul 2020 | Portfolio letter and temporary safeguarding guidance | Reported widespread and continuing material issues, and introduced the expectation of an annual safeguarding audit. | Letter (PDF) and guidance |
| 18 May 2021 | Dear CEO letter to e-money firms | Firms had to write to all customers by 29 June 2021 explaining that e-money is not covered by the Financial Services Compensation Scheme. | Letter (PDF) |
| 16 Mar 2023 | Payments portfolio letter | Safeguarding named the top priority; common failings listed; some firms had not appointed a safeguarding auditor. | Letter (PDF) |
| 25 Sep 2024 | Consultation paper CP24/20 | 12 safeguarding firms became insolvent between Q1 2018 and Q2 2023 with an average 65% shortfall in funds owed. Supervisory cases were opened in 2023 on about 15% of safeguarding firms. 380 payment institutions and 250 e-money institutions were required to safeguard, holding almost £22 billion. | CP24/20 (PDF) and press release |
| 3 Feb 2025 | Payments portfolio letter | States that customer money may not always be safe if a payments firm fails. | Letter (PDF) |
| 7 Aug 2025 | Policy statement PS25/12 | Repeats the 65% average shortfall. E-money institutions safeguarded about £26 billion in 2024, up from £11 billion in 2021; payment institutions about £6 billion a day. Average time to return funds in the FCA's cost-benefit analysis: 2.3 years. CASS 15 applies from 7 May 2026, with an audit exemption below £100,000. | PS25/12 (PDF) and press release |
| Dec 2025 | HM Treasury independent review of the special administration regime | Lists the 12 special administrations to November 2025 and finds that first distributions often take 12 months or more; Xpress Money took at least 15 months. | Review report (PDF) |
Skilled person reviews: what is published
A skilled person review (under section 166 of the Financial Services and Markets Act 2000) is an independent investigation the FCA requires a firm to commission and pay for. The FCA publishes counts by sector and by subject, but no safeguarding-specific count for payments firms.
For 2025/26 the FCA commissioned 31 reviews across all sectors, 3 of them in payments and digital assets, and 1 under the client assets and safeguarding subject heading across the whole FCA. In response to a Freedom of Information request in January 2024 the FCA said that e-money firms had been given business restrictions for financial crime weaknesses 2 times in 2021, 5 in 2022 and 12 in 2023, with 14 e-money firms under restrictions at January 2024. Those restrictions were for financial crime, not safeguarding, and are not counted in the tables above.
| Period | Figure | Source |
|---|---|---|
| 2025/26 full year | 31 skilled person reviews FCA-wide; 3 in payments and digital assets; 1 under client assets and safeguarding | FCA data |
| Q4 2024/25 | 0 in payments and digital assets | FCA data (PDF) |
| Q4 2023/24 | 5 in retail banking and payments; 0 under client assets and safeguarding | FCA data (PDF) |
| Jan 2024 (FOI) | E-money firms given business restrictions for financial crime weaknesses: 2 (2021), 5 (2022), 12 (2023) | FOI response |
What the pattern shows
Three things recur. First, the shortfall is discovered at the point of failure, not before: Rational FX's directors found theirs on 26 November 2023 and the firm was in special administration by the 29th; Currency Matters found a critical shortfall when it reconciled after telling the FCA it was insolvent. Second, the money was in the wrong kind of account: segregated but not safeguarded at Rational FX, held with a firm that was not a bank at Currency Matters, in 4 safeguarding accounts out of 55 at Allied Wallet. Third, the customer waits: a year or more to a first distribution, 2.3 years on average in the FCA's own analysis, and a fraction of the balance at the end of it.
CASS 15, in force from 7 May 2026, is built against exactly this pattern: an internal reconciliation every business day, an external reconciliation against bank records, a monthly return to the FCA, an annual audit and a resolution pack that lets administrators find the money on day one. The cases above are the reason those rules exist. For how the daily reconciliation works in practice, see the CASS 15 reconciliation guide and what the monthly safeguarding return requires.
Safeheld reconciles safeguarded funds every business day, works every difference to its cause and keeps the record the resolution pack and the auditor require. If your firm safeguards customer money under CASS 15, talk to us about safeguarding.
Frequently asked questions
Has the FCA ever fined a firm for safeguarding failures?
No. The only enforcement outcome for safeguarding at a payment or e-money firm is the public censure of Premier FX on 23 February 2021, where the FCA chose not to impose a financial penalty so that creditors would not lose more money. Every other case has been a supervisory requirement, an insolvency or a court judgment.
How much do customers get back when a safeguarding firm fails?
It varies widely and is set by the court-approved distribution plan after costs. Court-reported figures include 7.7 pence in the pound expected at Rational FX, 48.64 pence paid at LCC Trans-Sending (Small World), about 65% of relevant funds recovered at Monneo before a top-up, and a shortfall of about £585,000 on £12.6 million at Supercapital. The FCA's figure for 12 failed firms between 2018 and mid-2023 is an average 65% shortfall.
What is a special administration for a payment or e-money firm?
It is an insolvency procedure under the Payment and Electronic Money Institution Insolvency Regulations 2021, designed to return safeguarded funds to customers quickly. The administrators identify the safeguarded pool, set a claims deadline and ask the High Court to approve a distribution plan. The first case was Viola Money in December 2021.
Are safeguarded funds covered by the Financial Services Compensation Scheme?
No. The FSCS does not cover e-money or payment services. The FCA required e-money firms to tell every customer this in writing by 29 June 2021.
What is the average safeguarding shortfall at failed firms?
65%, according to the FCA's consultation paper CP24/20 (September 2024) and its policy statement PS25/12 (August 2025), based on 12 firms that became insolvent between the first quarter of 2018 and the second quarter of 2023.
Which rules do these cases fall under?
Regulation 20 of the Electronic Money Regulations 2011 for e-money institutions, regulation 23 of the Payment Services Regulations 2017 for payment institutions, and regulation 24 of the EMRs for the asset pool on insolvency. From 7 May 2026 the safeguarding requirements sit in CASS 15 of the FCA Handbook under PS25/12.
How often is this tracker updated?
It is reviewed whenever the FCA publishes a new notice, news page or data release on a safeguarding firm, or a court hands down a judgment, and the review date at the top of the page is updated each time.
References
- FCA, Final Notice: Premier FX Limited, 23 February 2021
- Court of Appeal, Re Ipagoo LLP [2022] EWCA Civ 302
- High Court, Re Rational Foreign Exchange Ltd [2025] EWHC 1958 (Ch)
- High Court, Re Monneo Ltd [2025] EWHC 2818 (Ch)
- FCA, CP24/20 Changes to the safeguarding regime for payments and e-money firms
- FCA, PS25/12 Changes to the safeguarding regime for payments and e-money firms
About Safeheld
Safeheld reconciles client money every day, resolves every difference and prepares every regulatory return for sign-off, for regulated firms in the United States, the United Kingdom, the European Union, Canada, Australia, Singapore and Hong Kong. To discuss your operations, contact us at safeheld.com/contact.
This tracker is compiled from public primary sources for general information and does not constitute legal or regulatory advice. Figures are as stated in the source documents and may be revised by the courts, the administrators or the FCA.