We support payment and e-money firms to safeguard customer funds through expert audit, training and advisory services that establish robust controls, ensure compliance and build long-term resilience, in line with FCA Policy Statement PS25/12 on changes to the safeguarding regime for payments and e-money firms.
When is a safeguarding audit required?
If your business is authorised or registered by the Financial Conduct Authority (FCA) as a Payment Institution (PI) or Electronic Money Institution (EMI), a safeguarding audit is required where the firm meets the applicable customer-funds threshold and reporting-period criteria under the FCA safeguarding requirements.
For firms holding significant amounts of customer funds, safeguarding is a key regulatory requirement designed to ensure customer money is appropriately protected and segregated from the firm's own funds.
Because PIs and EMIs do not benefit from the Financial Services Compensation Scheme (FSCS) in respect of safeguarded payment or e-money funds, effective safeguarding arrangements are particularly important in the event of a firm's failure. Consequently, the FCA considers safeguarding a significant supervisory priority.
Our Key Service
Safeguarding audit services for payment and e-money firms. Abacus acts as a statutory auditor delivering safeguarding audits that meet FCA requirements (FCA SUP 3A — safeguarding audit requirements) while reflecting the realities of payments and e-money business models. This approach responds directly to feedback from clients, who have told us they want audits that are both genuinely independent and informed by deep sector expertise.
Supplementary Services
Safeguarding Audit Readiness
Preparing firms for annual safeguarding audits through gap analysis, remediation planning and alignment with FCA expectations and the Supplementary Regime of Safeguarding (in force from 7 May 2026).
Independent Safeguarding Reviews
Providing pre-audit assurance across governance, controls and operational processes — identifying risks early and supporting remediation.
Framework Design & Enhancement
Designing and upgrading safeguarding frameworks, including policies, reconciliation controls, account structures and governance oversight.
Funds Flow & Regulatory Analysis
Mapping end-to-end fund flows and assessing safeguarding obligations across complex business models and regulatory boundaries.
Automation of End-to-End Flow
Assessing safeguarding processes and helping organisations prepare for automation of day-to-day safeguarding activities.
Documentation & Policy Development
Safeguarding policy and procedures, including gap analysis, regulator-aligned procedure enhancements, board-level reporting and governance, and structured evidence packs aligned with FCA requirements.
To discuss your safeguarding audit requirements, contact us at info@abacusllp.co.uk or call 020 7538 5042.