Resolution Pack Software: Meeting the CASS 10A 48-Hour Requirement
- Aug 6
- 7 min read
Buckingham Capital Consulting has advised payment and e-money firms on FCA authorisation, safeguarding and regulator engagement since 2013.
Resolution pack software maintains the pack required under CASS 10A from a firm's live safeguarding records, so that it reflects the current position at any point rather than the position as at the date it was last compiled.
The pack contains the documents and records needed to enable relevant funds to be returned to customers if the firm enters an insolvency procedure. It must be retrievable within forty-eight hours. The requirement was extended to payment and e-money firms by PS25/12 and applies from 7 May 2026.
This article sets out what the pack must contain, what the forty-eight hour requirement means in practice, why packs maintained as documents lose currency, and what a firm should expect software to provide.
The purpose of the pack
Where a payment or electronic money institution fails, an insolvency practitioner must establish what was safeguarded, where it is held, who is entitled to it, and how it is to be returned. Historic failures in the sector have shown that where those records are incomplete or held across multiple systems and individuals, the process is protracted and the costs are met from the funds otherwise available to customers.
The pack exists so that the information is assembled before it is needed rather than reconstructed from a firm that has ceased to operate.
That purpose informs how the requirement should be read. The pack is not a compliance document produced to satisfy a rule. It is an operational instrument intended to be used at a point when the firm's own capacity to assist has substantially reduced.
What the pack must contain
Safeguarding accounts. Each account holding relevant funds, the institution holding it, account identifiers, currency and balance.
Relevant assets. Where the firm holds relevant assets rather than or in addition to cash, the custodians, asset types and values.
Acknowledgement letters. The letters obtained from each institution confirming that the funds are held for safeguarding purposes, that the institution has no right of set-off or counterclaim against them, and that it will not combine the account with any other account.
Agents and distributors. Those through which the firm operates, their role, and their relationship to the flow of relevant funds.
Procedures for the management, recording and transfer of relevant funds. How funds are received, identified, segregated, recorded and transferred, and how customer entitlements are established.
The calculation methodology. How the firm determines the safeguarding requirement, including its documented treatment of the boundary questions specific to its business model: when the obligation begins and ends, fees once due, foreign exchange linked to payment services, funds held through agents and distributors, and unclaimed balances. An insolvency practitioner who cannot replicate the firm's calculation cannot verify the firm's position.
Records establishing customer entitlements. What each customer is owed, and how that is derived from the firm's systems.
Key contacts. The individual responsible for safeguarding compliance, senior management, and the firm's advisers.
Recent reconciliation records. So that the pack reflects a current position.
Insurance or guarantee documentation where used as a safeguarding method.
What forty-eight hours means
The requirement is that the pack is retrievable within forty-eight hours. It is a limit on retrieval, not a period allowed for production.
The distinction is material. A firm able to assemble a pack within forty-eight hours by drawing information together from current systems does not have a resolution pack. It has the capacity to produce one, which is a different thing, and which is the capacity most likely to be impaired in the circumstances the pack exists to address.
The circumstances are worth setting out. The firm has entered an insolvency procedure. Staff may have left. Access to systems may be constrained. Individuals who knew where information was held may not be available. The insolvency practitioner is working within a timeframe in which delay reduces the funds available for distribution.
A pack whose retrieval depends on an informed individual devoting two days to assembling it is a pack that is unlikely to be available when it is required.
Why packs maintained as documents lose currency
Firms that treat the pack as a document maintain it as documents are maintained: reviewed periodically, updated when circumstances prompt it, held on a shared drive.
That approach produces a pack that is accurate on the day it is compiled and progressively less accurate afterwards. Safeguarding account balances change daily. Reconciliation records change daily. Acknowledgement letters are obtained, expire and are renewed. Banking arrangements change. Agents and distributors are appointed and terminated. Customer entitlement records change with each transaction.
Twelve months after compilation, a substantial proportion of the pack's factual content is no longer correct. This does not require any failure of diligence; it follows from the fact that the pack describes a moment and the firm has continued to operate.
The obligation is that the pack is kept current. A pack that is out of date does not meet the requirement, whether or not the position has been reviewed.
Packs generated from live records
The alternative to maintaining a document is generating the pack from the systems in which the underlying information is held.
A pack containing a copy of the safeguarding account list as at January is incorrect by February. A pack that draws the safeguarding account list from the system in which accounts are maintained is correct whenever it is produced, because it is not a copy.
The same applies to each component. Balances drawn from the external reconciliation rather than transcribed. Acknowledgement letter status drawn from the register that records it. Customer entitlements drawn from the entitlement records rather than described. Reconciliation history drawn from the reconciliations themselves.
Where a component is necessarily a static document - a signed acknowledgement letter is a document rather than a data point - the pack tracks its status and identifies those requiring renewal, rather than including a copy and assuming continued validity.
Under this approach the forty-eight hour requirement is met by retrieval taking a matter of seconds, because no assembly step exists.
What software should do
Generate the pack from operational records. Each component drawn from the system in which the underlying information is held rather than from a stored copy.
Monitor completeness. A score or status indicating which components are present, which are missing, and which have not been updated within a defined period, so that gaps are visible before they become audit findings.
Track the status of static components. Acknowledgement letters, insurance policies and signed documents tracked for receipt, expiry and renewal, with alerts where action is required.
Record ownership and last-updated dates. Each component attributable to an owner, with the date it was last updated visible.
Produce the pack in a single action. Export suitable for provision to the FCA, an insolvency practitioner or an administrator, reflecting the position at the moment of retrieval.
Retain version history. So that the pack as it stood at a past date can be established where required.
Testing retrieval
A pack that has never been retrieved has not been tested.
Firms should periodically produce the pack as though responding to a request, and assess four points. Is every component present? Is every component current? Is anything referenced but not in fact included? And could retrieval be completed within forty-eight hours by someone other than the individual who maintains it?
The final point is the one most often overlooked. Where retrieval depends on a particular individual knowing where information is held, the pack does not serve its purpose, since insolvency is precisely the circumstance in which that individual may be unavailable.
The test itself should be recorded. Evidence that the pack has been produced and reviewed is relevant to the safeguarding audit.
Frequently asked questions
What is a CASS 10A resolution pack?
The set of documents and records that would enable relevant funds to be identified and returned to customers if the firm entered an insolvency procedure. It covers safeguarding accounts, relevant assets, acknowledgement letters, agents and distributors, procedures, the calculation methodology, customer entitlement records and key contacts.
Does the forty-eight hour requirement mean we have forty-eight hours to produce the pack?
No. It is a limit on retrieval. The requirement assumes a pack that already exists and is current, rather than one assembled in response to a request.
Does the resolution pack requirement apply to payment and e-money firms?
Yes. CASS 10A was extended to firms subject to the Supplementary Regime by PS25/12, effective 7 May 2026. It previously applied to investment firms under CASS 10.
How often should the pack be updated?
Continuously, in the sense that its contents should reflect the current position at any time. Components drawn from live records update automatically. Static components such as signed acknowledgement letters should be tracked for status and renewal.
Should the pack be tested?
Yes. Producing the pack periodically as though responding to a request is the only means of establishing that it is complete, current, and retrievable within forty-eight hours by someone other than the individual who maintains it. The test should be recorded.
Who may request the pack?
The FCA, an insolvency practitioner or an administrator. The firm should be able to provide it within forty-eight hours of the request.
A pack drawn from live records
The forty-eight hour requirement is met by retrieval where the pack exists and is current, and by assembly where it does not. The difference determines whether the obligation is satisfied in practice or only in principle.
Safeheld generates the CASS 10A resolution pack from the records the platform already holds. Safeguarding accounts, balances, custodians, acknowledgement letter status, third parties, agents and distributors, reconciliation history and customer entitlement records populate the pack directly. Completeness is monitored, gaps are flagged, and each component carries its owner and last-updated date. The pack exports in a single action, reflecting the position at the moment of retrieval.
About Safeheld
Safeheld is the safeguarding platform for FCA-regulated payment and e-money firms, covering daily reconciliation, breach management, regulatory reporting, resolution pack maintenance and audit evidence. Safeheld is a Buckingham Capital Consulting company. safeheld.com
About Buckingham Capital Consulting
Buckingham Capital Consulting is a leading UK and European financial services regulatory consultancy. Since 2013 we have advised payment institutions, electronic money institutions, investment firms and cryptoasset businesses on authorisation, prudential and conduct requirements, safeguarding, governance and regulator engagement across the UK and EU. Contact our safeguarding team
