PS25/12 is the FCA’s May 2025 policy statement introducing a supplementary safeguarding regime for payment institutions (PIs), electronic money institutions (EMIs) and small payment institutions (SPIs). The rules go live on 7 May 2026.

Who does PS25/12 apply to?

The rules apply to authorised PIs (except PIS-only/AIS-only), authorised EMIs, small EMIs, and credit unions issuing e-money. SPIs can choose to opt in.

What are “reconciliation days” under PS25/12?

Reconciliation days are all business days excluding weekends, UK bank holidays, and relevant foreign market closures. Internal and external reconciliations must be performed once each reconciliation day.

What are the PS25/12 safeguarding audit requirements?

Most firms must arrange an annual safeguarding audit unless their safeguarded balances stayed below £100,000 during the prior 53 weeks. First audits must be submitted within 6 months of period end, then within 4 months thereafter.

What is the monthly safeguarding return in PS25/12?

Firms must file a monthly return via FCA’s RegData system confirming reconciliations and showing safeguarded funds vs resources (the D+1 test). EMIs offering unrelated payment services must report pools separately.

How does PS25/12 address third-party safeguarding providers?

Firms must show due skill, care and diligence in selecting banks, custodians and insurers, and explicitly consider diversification of providers. Acknowledgement letters remain mandatory.

What happens if a firm uses insurance or guarantees to safeguard?

The payout must be unconditional apart from insolvency certification. Firms must plan renewal decisions 3 months before expiry and notify the FCA 2 months before first use or any changes.

What is a resolution pack under PS25/12?

A resolution pack is a set of safeguarding records and documents that must be retrievable within 48 hours for administrators or regulators. It includes agreements, acknowledgement letters, and reconciliation records.

When do the new safeguarding rules start?

The supplementary regime begins on 7 May 2026, with a nine-month transition period and some relief for pre-existing third-party arrangements.

MG Marketing Ops Team - Macro Global

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