Safer - but safe enough? Changes for payments safeguarding

Some payments and e-money providers do not have adequate safeguarding practices and present a risk to consumers, says the regulator. Final rules and guidance to address these problems are not as drastic as they could have been, but need focused attention for firms to comply by the deadline, report Emma Radmore and Laura Wiles.

Emma Radmore (emma.radmore@wbd-uk.com) is legal director in the UK Financial Regulation team at Womble Bond Dickinson. Laura Wiles (laura.wiles@wbd-uk.com) is a solicitor with the firm who works between Financial Services as well as Restructuring and Insolvency practices; in Financial Services, she acts for a variety of regulated clients, including banks, investment firms, insurers and insurance intermediaries, fund managers, fintechs and other financial institutions.

On 7 August 2025, the Financial Conduct Authority published its policy statement on changing the safeguarding regime for payments and e-money firms. Firms had been waiting for the results of the FCA's consultation on the changes with some trepidation, given the FCA's proposals to overhaul the traditional regime and replace it with requirements based on the longer-standing Client Assets Sourcebook (CASS) regime for investment businesses.