Safeguarding · 9 December 2025
FCA finalises major overhaul of safeguarding rules for payments and e-money firms
PS25/12 moves safeguarding toward a more prescriptive, audit-led regime. Here is what firms need to operationalise.
The direction of travel
The reforms raise expectations for reconciliation, governance, audit assurance, notifications and wind-down readiness. Firms should treat safeguarding as an operational control system, not a policy exercise.
What leadership teams should prioritise
- Map safeguarding processes, ownership and evidence end to end.
- Test daily reconciliation controls and escalation routes.
- Prepare governance for stronger board oversight and approval.
- Engage auditors early and close evidence gaps before review.
- Build a usable resolution pack covering accounts, providers, records and wind-down actions.
How AnyAccount helps
We support payments and e-money firms with regulatory reporting, safeguarding operating models, governance structures, compliance monitoring and readiness reviews.