The Monthly Safeguarding Return: A Section-by-Section Guide

Key takeaways

• Every safeguarding institution must submit a safeguarding return within 15 business days of the end of each calendar month (SUP 16.14A.3R).
• The form is SUP 16 Annex 29BR, widely called REP027. It has 17 sections and 56 questions.
• Sections 1 to 9 cover e-money and related payment services; Sections 10 to 17 repeat the core questions for payment services unrelated to e-money.
• Most figures come from the last internal safeguarding reconciliation of the month, with non-sterling amounts converted at the closing spot rate for the previous day.
• A firm still files Sections 1, 2 and 9 in a month when it was not required to safeguard any funds.

What are the key facts on the monthly return?

The monthly safeguarding return is the FCA's standing monthly report on each firm's safeguarding position and controls.

Who must file the return, and when?

Every safeguarding institution files it every month, within 15 business days of the month end.

SUP 16.14A.3R sets the deadline and defines the month as a calendar month. The deadline is fixed by the rule itself; the FCA states that the return is submitted via My FCA, where firms can also check their individual reporting schedule, but that schedule applies the same 15 business day period. A firm does not submit a return for the month in which it becomes a safeguarding institution. SUP 16.14A.4R requires electronic submission by the means the FCA provides, and SUP 16.14A.5R applies the general rules on complete reporting, timely reporting and failure to submit (SUP 16.3.11R, 16.3.13R and 16.3.14R).

The return replaced the safeguarding questions that previously sat in other periodic returns for payment and e-money firms (PS25/12, chapter 4). It is part of the wider regime described in our CASS 15 and PS25/12 guide.

How is the return structured?

The form has 17 sections and 56 questions, split into a block for e-money and related payment services and a block for unrelated payment services.

What do Sections 1 and 2 ask?

They identify the firm, its audit status and how it safeguarded during the month.

• Question 1: name and category of safeguarding institution, chosen from eight categories such as authorised payment institution, e-money institution or credit union.
• Question 2: whether the firm was a relevant institution under SUP 3A.1.1R(1)(a) during the period, with the options Yes, No (not in scope) or No (exempt). This is how the FCA sees reliance on the £100,000 audit exemption.
• Question 3: if not a relevant institution, whether the firm will voluntarily arrange an audit under SUP 3A.1.3G.
• Question 4: the date of the last auditor's safeguarding report submitted under SUP 3A.9 and the audit firm's full legal name.
• Question 5: whether the firm was required to safeguard relevant funds during the period. A No answer skips Sections 3 to 8.
• Question 6: the method or methods used during the period (segregation, insurance, guarantee) and the method used at the last internal reconciliation.
• Question 7: the number of clients the firm was safeguarding for at the end of the period.
• Question 8: whether a non-standard method of internal reconciliation was used.

What do Sections 3 to 6 ask?

They report the size of the safeguarding requirement, where funds were held and how the last internal reconciliation came out.

Section 3 asks for the highest and lowest safeguarding requirement during the month (questions 9 and 10), so the daily series must be kept, not only the month-end figure. Section 4 lists where money sat: a row per institution and account type for segregated funds, with the number of accounts, the total held, any fixed term or notice period and the country of incorporation (question 11); relevant assets, marked against the UK CRR Article 114 paragraphs relied on and whether any asset falls outside CASS 15.4.2G (question 12); assets by custodian (question 13); and insurance policies and guarantees with cover, expiry and overdue premiums (questions 14 and 15).

Section 5 reports the safeguarding resource and requirement from the last internal reconciliation of the month, each broken into its components: items A to D of the resource under CASS 15.8.26R, and individual balances plus unallocated receipts under CASS 15.8.30R (questions 16 to 19). Question 20 gives the excess (positive) or shortfall (negative) and question 21 the adjustment made to correct it. Section 6 repeats the exercise for the D+1 segregation comparison (questions 22 to 25).

What do Sections 7 to 9 ask?

They confirm the reconciliations happened, reconcile the account inventory and disclose notifiable breaches.

Questions 26 and 27 ask whether internal and external reconciliations were carried out on every reconciliation day; firms answer Yes or No rather than reporting a count. Question 28 is an account inventory for each class of account: accounts held at the start of the month, opened, closed, held at the end (X), and the number covered by an acknowledgement letter (Y), with an explanation of any difference between X and Y. Question 29 asks whether any circumstance in CASS 15.8.60R arose in the month, and question 30 whether the firm complied with the notification requirement. See notifying the FCA of a safeguarding breach.

Which figures and exchange rates should be used?

Use the figures from the last internal safeguarding reconciliation in the month, in sterling, converted at the closing spot rate for the day before that reconciliation.

The form's notes tie most balances in Sections 4 to 6 to the last internal reconciliation carried out in the reporting period, not to a separate month-end calculation. The highest and lowest requirement in Section 3 come from the full daily series. Where amounts are held or owed in another currency, they are converted into sterling at the closing spot exchange rate for the day before the relevant reconciliation. PS25/12 added this guidance on exchange rates so that firms report on a consistent basis; see safeguarding in more than one currency.

What does a completed return look like?

The example below is a filled return for a fictional e-money institution with no unrelated payment services, for June 2026.

The arithmetic must hold across sections. The resource in question 16 equals the four components in question 17, the requirement in question 18 equals its two components, and question 20 is question 16 minus question 18. The D+1 resource is items A and C only, which is why it equals £45,843,048 plus £3,000,000. The £8,273 shortfall came from a card settlement still in the operating account at the reconciliation point; it was paid in the same day, so no CASS 15.8.60R circumstance arose and question 29 is No.

Where should each figure come from?

Each answer should trace to a record the firm already keeps for CASS 15, so the return can be checked line by line.

A return assembled from separate spreadsheets at month end is the main source of error, because the figures then describe a different position from the one the reconciliation approved. Our guide to REP027 automation covers building the return from reconciliation data.

What should be checked before submission?

A short pre-submission review catches most errors.

• Confirm the reporting month and that the submission date is within 15 business days of its end.
• Agree questions 16 to 25 to the approved last internal reconciliation record, not a recalculation.
• Check that components sum to their totals and that question 20 equals question 16 minus question 18.
• Check that the D+1 resource equals items A and C only.
• Confirm question 26 and 27 answers against the reconciliation log, counting foreign market closures correctly.
• Reconcile the account inventory in question 28 to the acknowledgement letter file and explain any gap.
• Agree question 29 to the breach log, and attach the notification trail where the answer is Yes.
• Complete Sections 10 to 17 separately where the firm has unrelated payment services.
• Record who reviewed and approved the return before submission.

How does Safeheld help?

Safeheld produces the monthly safeguarding return in the FCA's structure from the reconciliations it has already run, and the firm reviews and files it.

Every figure links back to the reconciliation and break records behind it, so reviewers and auditors can trace each answer. See regulatory returns and audit evidence.

Frequently asked questions

When is the monthly safeguarding return due?

Within 15 business days of the end of each calendar month, under SUP 16.14A.3R.

What is REP027?

REP027 is the common name for the monthly safeguarding return in SUP 16 Annex 29BR.

Who has to submit the safeguarding return?

Every safeguarding institution: authorised payment institutions, e-money institutions, credit unions issuing e-money and small payment institutions that have opted in to safeguarding.

Is a return needed for the month a firm becomes a safeguarding institution?

No. SUP 16.14A.3R exempts the month in which the firm becomes a safeguarding institution.

Which reconciliation do the figures come from?

Most balances come from the last internal safeguarding reconciliation carried out in the month. The highest and lowest requirement come from the whole month.

What exchange rate is used in the return?

Non-sterling amounts are converted at the closing spot exchange rate for the day before the relevant reconciliation.

What if the firm did not safeguard any funds in the month?

It answers No to question 5 and still completes Sections 1, 2 and 9.

How is the return submitted?

Electronically, under SUP 16.14A.4R. The FCA states that firms submit it via My FCA.

References

• FCA Handbook, SUP 16.14A Safeguarding return
• FCA Handbook, SUP 16 Annex 29BR Safeguarding return
• FCA Handbook, CASS 15.8 Records, accounts and reconciliations
• FCA Handbook, SUP 3A.1 Application
• FCA, PS25/12: Changes to the safeguarding regime for payments and e-money firms (PDF)
• FCA, Safeguarding requirements for payment institutions and e-money institutions

About Safeheld

Safeheld is reconciliation and regulatory financial control software for regulated firms that hold client money. It reconciles bank and ledger records for each entity and currency and produces the FCA monthly safeguarding return in the FCA's structure from those reconciliations, ready for the firm to review and file. 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.