The Monthly Safeguarding Return Under SUP 16.14A: A Practical Guide
- Aug 6
- 5 min read
Buckingham Capital Consulting has advised payment and e-money firms on FCA authorisation, safeguarding and regulator engagement since 2013.
The monthly safeguarding return is a regulatory report required under SUP 16.14A of the FCA Handbook and submitted through RegData. It covers a firm's safeguarding position across the reporting month, including relevant funds held, reconciliation performance, shortfalls identified, safeguarding accounts and assets, the method used and any breaches or notifications.
It was introduced by PS25/12 and became a monthly obligation from 7 May 2026. For most payment and e-money firms it is the most frequent safeguarding deliverable, and the one that most quickly exposes weaknesses in the underlying records.
Who must submit the return?
The return applies to firms subject to the Supplementary Regime: authorised payment institutions, authorised electronic money institutions, small electronic money institutions and credit unions issuing e-money. Small payment institutions that have opted in to safeguarding are also within scope.
The submission window follows the FCA's reporting calendar for the firm's permission. Firms should confirm their own due date in RegData rather than relying on a general rule, since timing varies with permission type and reporting period.
What the return covers
The return is structured around the firm's safeguarding position during the reporting period.
Relevant funds held. The total safeguarded at the reporting date, split between electronic money and unrelated payment services where the firm holds both. These are separate asset pools and must be reported as such.
The segregation position. The D+1 segregation requirement and the D+1 segregation resource across the period. The return is concerned with the pattern over the month, not only the position on the final day.
Reconciliation performance. The number of reconciliation days in the period and confirmation that internal and external safeguarding reconciliations were performed on each of them. Where a reconciliation was not performed, that is a matter requiring explanation and, in most circumstances, prior notification to the FCA.
Shortfalls. Shortfalls identified during the period, their value, and how each was remedied. A shortfall remedied promptly still occurred and is still reported.
Safeguarding accounts. The accounts held, the institutions holding them and the balances. Where accounts are held outside the UK, jurisdiction is relevant.
Relevant assets. Where the firm holds relevant assets rather than or in addition to cash, the custodians, asset types and values.
Safeguarding method. Segregation, insurance, comparable guarantee, or a combination. Where insurance or a guarantee is used, the provider and cover details.
Breaches and notifications. Breaches occurring during the period and notifications made to the FCA.
Where the data comes from
Every figure in the return originates in the firm's daily operational records.
The segregation requirement and resource come from the internal and external reconciliations performed each reconciliation day. The count of reconciliation days comes from the firm's reconciliation calendar. Shortfalls and remediation come from the break and breach records. Account balances come from the external reconciliation. Breaches and notifications come from the breach register.
This is the point that determines whether the return is straightforward or difficult. A firm holding these records in a controlled system assembles the return from data that already exists and has already been approved. A firm working from spreadsheets reconstructs the month's position from scattered files, email trails and recollection.
Common problems
Inconsistency between the return and the audit evidence. Where the return is compiled separately from the reconciliation records, the figures diverge. The auditor tests the underlying records; the supervisor reads the return. Divergence between them is visible and difficult to explain.
Reconciliation days counted incorrectly. Firms that determine the reconciliation calendar retrospectively often find the count in the return does not match the number of reconciliations actually performed. The calendar should be fixed in advance.
Asset pools combined. Firms holding both e-money funds and funds for unrelated payment services must report the pools separately. Combining them misstates both.
Shortfalls omitted because they were remedied. A shortfall that was identified and corrected within the day is still a shortfall that occurred and is still reportable.
Late identification of the due date. Submission timing follows the reporting calendar for the firm's permission. Firms that assume a fixed monthly date sometimes discover otherwise close to the deadline.
Preparing the return
Throughout the month. Perform and record the internal and external reconciliations on each reconciliation day, with the segregation requirement, resource, comparison and any action taken recorded as each is completed. Record breaks and their resolution as they arise. Maintain the breach register.
At month end. Assemble the return from those records. Verify that the number of reconciliations recorded matches the number of reconciliation days in the period. Confirm the asset pool split. Confirm shortfalls and remediation are complete. Confirm accounts and balances agree to the external reconciliation.
Before submission. Review the return against the underlying records and obtain approval from the individual responsible for safeguarding compliance. The review is not administrative: the return is a regulatory submission and its accuracy is the firm's responsibility.
After submission. Retain the return and the supporting records. The auditor will examine both, and consistency between the returns submitted during the audit period and the records supporting them is directly relevant to the audit opinion.
Frequently asked questions
What is the monthly safeguarding return?
A regulatory return required under SUP 16.14A and submitted through RegData, covering a firm's safeguarding position for the reporting month including relevant funds held, reconciliation performance, shortfalls, accounts, assets, safeguarding method and breaches.
When is the safeguarding return due?
The submission window follows the FCA's reporting calendar for the firm's permission and reporting period. Firms should confirm their own due date in RegData.
Do we report shortfalls that were remedied the same day?
Yes. A shortfall that occurred is reportable regardless of how quickly it was remedied. The remediation is also recorded.
How are e-money and payment services funds reported?
Separately. Funds held in respect of electronic money and funds held for unrelated payment services are separate asset pools and are reconciled and reported as such.
What if a reconciliation was not performed on a reconciliation day?
The firm should have notified the FCA where it knew in advance that it would be unable to perform a reconciliation. The failure is a breach, is recorded in the breach register and is reflected in the return.
Assembling the return from operational records
Safeheld assembles the SUP 16.14A return from the reconciliation records already held, so the figures reported are the figures approved during the month. The return is reviewed and approved in the platform before export for RegData submission, and the supporting records remain available for the audit.
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
The Monthly Safeguarding Return Under SUP 16.14A: A Practical Guide
