Do you need a CASS 15 safeguarding audit?

The FCA supplementary safeguarding regime came into force on 7 May 2026. A few questions and you will know whether it applies to you, and what happens next.

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FCA PS25/12 · In force 7 May 2026

Do you need a CASS 15 safeguarding audit?

Answer four questions to find out whether your firm has a legal obligation to appoint a registered auditor under FCA PS25/12 and SUP 3A. Your result includes the relevant regulatory references.

The dates that matter

  1. 7 May 2026
    CASS 15 in force

    Codified daily reconciliations, prescriptive books and records, a CASS resolution pack, counterparty due diligence and a monthly regulatory return.

  2. Within 53 weeks
    Your first audit period ends

    The period must not exceed 53 weeks from the date you became subject to the rules, or from the end of the previous report period.

  3. Plus 6 months
    First report due

    The FCA extended the first deadline to six months after period end, up from the four months consulted on. Subsequent reports are due within four months.

  4. Exempt if
    Under £100,000

    A firm that has not been required to safeguard more than £100,000 of relevant funds at any time over a period of at least 53 weeks does not need the audit.

Read the full explainer → Our CASS 15 service →

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In scope and need it done?

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