The CASS 10A Resolution Pack: What It Must Contain and How to Maintain It
- Aug 6
- 5 min read
Buckingham Capital Consulting has advised payment and e-money firms on FCA authorisation, safeguarding and regulator engagement since 2013.
A resolution pack is a set of records that would enable relevant funds to be returned to customers if a payment or electronic money institution entered an insolvency procedure. Under CASS 10A, firms subject to the Supplementary Regime must maintain one and must be able to retrieve it within 48 hours.
The requirement was extended to payment and e-money firms by PS25/12 and applies from 7 May 2026. It is one of the more commonly misunderstood obligations, because firms treat it as a document to be written rather than a set of records to be kept current.
What is the resolution pack for?
Its purpose is practical. If a firm fails, an insolvency practitioner must identify what was safeguarded, where it is held, who is entitled to it and how to return it. Historic failures in the payments sector have shown that where those records are incomplete or scattered, the process takes years and costs are deducted from the funds available to customers.
The pack exists so that the information is already assembled at the point it is needed, rather than reconstructed from a firm that has ceased to operate.
What the resolution pack must contain
Safeguarding accounts. Each account holding relevant funds, the institution holding it, account identifiers, currency and the current 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 the funds are held for safeguarding purposes, that the institution has no right of set-off or counterclaim and that it will not combine the account with any other.
Agents and distributors. Those through which the firm operates, their role and their relationship to the flow of relevant funds.
Procedures for 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 the treatment of the boundary questions specific to its model, and whether it uses the standard or a non-standard method.
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.
Reconciliation records. The recent safeguarding position, so that the pack reflects a current picture rather than a historic one.
Insurance or guarantee documentation. Where used as a safeguarding method, the policy and its terms.
The 48-hour requirement
The pack must be retrievable within 48 hours. This is the point where practice most often falls short.
Forty-eight hours is not enough time to assemble a pack from scratch, and the requirement is not satisfied by the ability to reconstruct one. It assumes a pack that already exists, is complete and is current.
The practical difficulty is currency. Account balances change daily. Reconciliation records change daily. Acknowledgement letters expire and are renewed. Agents and distributors change. A pack assembled once a year is accurate on the day it is compiled and progressively less accurate for the following twelve months.
Maintaining the pack as a living record
The more effective approach is to treat the pack as a live set of records rather than a periodic document.
The distinction is between a pack that contains a copy of the safeguarding account list as it stood in January, and a pack that draws the safeguarding account list from the system where accounts are actually maintained. The first is out of date within a week. The second is correct whenever it is retrieved.
Where the pack is generated from live records, currency is automatic and the 48-hour requirement is met by retrieval rather than assembly. Where components genuinely must be static documents, such as signed acknowledgement letters, the pack should track their status and flag those requiring renewal.
This is the approach the FCA has indicated it prefers, and it is what firms with mature CASS 10 arrangements in the investment sector generally do.
Testing the pack
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 whether it is complete, whether every component is current, whether anything referenced is missing and whether the retrieval could realistically be completed within 48 hours by someone other than the person who maintains it.
That last point matters. If retrieval depends on one individual knowing where things are held, the pack does not meet its purpose, because insolvency is precisely the circumstance in which that individual may not be available.
Common weaknesses
The pack as a Word document. Static, out of date, and typically last updated when it was created.
Missing acknowledgement letters. Firms sometimes have accounts for which the letter was never received, or was received in a form that does not meet the requirements.
Customer entitlement records described but not included. The pack states that entitlements are held in the firm's ledger without providing or specifying how they would be extracted.
No record of the calculation methodology. Where the firm's treatment of relevant funds involves judgements specific to its model, those judgements must be documented, or an insolvency practitioner cannot replicate the calculation.
Untested retrieval. The pack exists but has never been produced, and nobody knows how long it would take or whether it is complete.
Frequently asked questions
What is a CASS 10A resolution pack?
A set of records enabling relevant funds to be returned to customers if a payment or e-money firm enters an insolvency procedure. It covers safeguarding accounts, relevant assets, acknowledgement letters, agents and distributors, procedures, the calculation methodology, customer entitlement records and key contacts.
How quickly must the resolution pack be produced?
Within 48 hours. The requirement assumes an existing, current pack 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 resolution 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 acknowledgement letters should be tracked and renewed as required.
Should we test the resolution pack?
Yes. Producing the pack periodically as though responding to a request is the only way to establish that it is complete, current and retrievable within 48 hours by someone other than the person who maintains it.
A resolution pack drawn from live data
Safeheld maintains the CASS 10A resolution pack from the records the platform already holds. Safeguarding accounts, balances, acknowledgement letter status, third parties, reconciliation history and customer entitlement records populate the pack directly, so it reflects the current position whenever it is produced. Completeness is monitored and gaps are flagged.
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
