Key takeaways
- This template sets out the fields a daily CASS 15 safeguarding reconciliation record should contain.
- It covers the internal safeguarding reconciliation, the external reconciliation and the sign-off.
- Each pool of funds, e-money and payment services, needs its own record.
- A template helps structure the record, but the evidence must come from source data, not retyped figures.
What the template is for
Under CASS 15, UK payment and e-money firms must perform internal and external safeguarding reconciliations on every reconciliation day and keep a record of each. The record is what the annual safeguarding auditor samples and what the monthly safeguarding return reports. This template sets out the fields that record should contain, so that every day's reconciliation is complete and comparable.
The template below is written for heads of finance and safeguarding managers who want to check that their current record is complete, or who are building the process for the first time. It follows the structure of the rules: one internal reconciliation, one external reconciliation and, where needed, one internal deposit reconciliation per reconciliation day.
The template is a structure, not a method. Figures should be taken directly from the ledger, bank statements and custody records, not typed in by hand, and the record should be stored where it cannot be edited after sign-off.
Internal safeguarding reconciliation fields
The internal reconciliation compares the safeguarding requirement with the safeguarding resource at the reconciliation point. Complete one record per pool of funds per reconciliation day.
Where the firm holds funds in more than one currency, record the requirement and resource in each currency separately, together with any conversion used for total reporting. The reconciliation should show whether each currency is covered, not only the total.
| Field | Example |
|---|---|
| Entity and pool | Example EMI Ltd, e-money pool |
| Reconciliation day and point | Tuesday 6 October 2026, 17:00 UK |
| Safeguarding requirement and source | £48,212,070.66 from customer ledger extract |
| Resource by account or asset, with source | Bank 1 £30,105,220.40; Bank 2 £18,103,150.02 from statements |
| Insurance or guarantee cover in force | None |
| Total resource | £48,208,370.42 |
| Difference | £3,700.24 shortfall |
| Cause | Processor settlement in operating account after cut-off |
| Correction and time | £3,700.24 transferred at 17:42 |
| Prepared by, reviewed by, time | Named preparer and reviewer with times |
External safeguarding reconciliation fields
The external reconciliation compares the firm's record of each safeguarding account with the third party's statement. Record one line per account: the account and institution, the firm's record, the statement balance, the difference, the cause and the resolution. Insurance and guarantees are not part of the external reconciliation.
Where funds are received outside safeguarding accounts, add an internal deposit reconciliation record showing each receipt, the date received and the date moved into safeguarding, to show the end of next business day deadline was met.
Sign-off and record keeping
Each day's record should be prepared by one person and reviewed by another, with both names and times recorded. Any shortfall correction should show the approver and the payment reference. Store records so they cannot be altered after sign-off, keep them for the period the rules require, and make sure the monthly safeguarding return is built from them rather than recalculated.
Spreadsheet templates work at low volumes but become fragile as entities, accounts and currencies grow. Safeheld produces this record automatically each reconciliation day from source data, with preparer, reviewer and correction evidence attached. See the PS25/12 guide, safeguarding shortfalls and excesses and CASS 15 software.
Frequently asked questions
What should a safeguarding reconciliation record include?
Entity and pool, reconciliation day and point, requirement and resource with sources, difference, cause, correction, and preparer and reviewer.
Do e-money and payment services funds need separate records?
Yes. Each pool is reconciled and recorded separately.
Is a spreadsheet template acceptable?
It can work at low volumes if figures come from source data and records are locked after sign-off, but it becomes fragile as the firm grows.
Is insurance cover part of the external reconciliation?
No. Insurance and guarantees are included in the internal reconciliation but not the external one.
References
- FCA Handbook, CASS 15.8 Records, accounts and reconciliations
- 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 article is for general information and does not constitute legal or regulatory advice.