Why leading firms choose us as their partner.
We engaged Buckingham Capital Consulting to conduct an audit of our client funds safeguarding practices, and their expertise and thoroughness have been invaluable in ensuring the security and protection of our clients' funds.
Buckingham Capital Consulting demonstrated a deep understanding of the regulatory requirements and best practices related to client fund safeguarding. Their team conducted a comprehensive assessment of our processes, systems, and controls to identify any gaps or areas for improvement.
Through their audit process, Buckingham Capital Consulting provided us with a detailed report outlining their findings and recommendations. They helped us enhance our client fund safeguarding procedures, ensuring that we meet the regulatory requirements.
Why Buckingham Capital Consulting
Whether its compliance, FCA authorisation or something else,
its about being part of your journey.
Expertise from seasoned experts
Our team of seasoned professionals brings a wealth of expertise to the table. With years of industry experience, we offer tailored solutions and are committed to supporting you through every stage of your journey.
Regulatory
Credibility
We have supported firms through FCA safeguarding reviews, s166 skilled person reports, and voluntary requirements. We understand what the FCA expects to see and how they assess safeguarding adequacy in practice.
Preparing for 7th May 2026
The FCA's Supplementary Regime (PS25/12) introduces significant new safeguarding obligations for all authorised PIs and EMIs. These changes represent the most substantial overhaul of the safeguarding framework since the Payment Services Regulations 2017. Firms that are not operationally ready by May 2026 face regulatory intervention, including potential restrictions on permissions.
The key changes include mandatory daily reconciliation of safeguarded funds on every business day, monthly safeguarding regulatory returns submitted directly to the FCA, annual safeguarding audits conducted by a qualified auditor for firms safeguarding over £100,000, appointment of a named senior manager with direct responsibility for safeguarding, board-level approval of safeguarding policies including the definition of material discrepancy, and maintenance of a resolution pack enabling rapid return of customer funds within 48 hours' notice in an insolvency scenario.
Beyond the Supplementary Regime, the FCA's Post-Repeal Regime will eventually replace the existing EMR and PSR safeguarding provisions entirely with a CASS-style statutory trust framework. While the implementation date has not been confirmed, firms should be preparing their infrastructure now.
We help firms assess their current position, identify gaps, and implement the operational changes required to meet both the Supplementary Regime and the eventual Post-Repeal Regime.
Our services - Client funds safeguarding
As safeguarding requirements evolve, we ensure your firm stays ahead. From independent audits to ongoing compliance support, we provide the expertise and frameworks that give your board, your customers, and the regulator full confidence in your safeguarding arrangements.
Safeguarding Audits
We carry out independent audits of your safeguarding arrangements and provide a comprehensive report of our findings and recommendations. Our reports are designed for submission to your board and, where required, to the FCA.
Gap Analysis
We review your current safeguarding practices against the FCA's new requirements and provide a clear plan to address any gaps before the May 2026 deadline.
Policy and Procedures Review
We review and strengthen your safeguarding policies, procedures, and governance framework to ensure they meet FCA expectations and are operationally effective.
Ongoing Compliance Support
We provide retained safeguarding support to keep your arrangements compliant as regulations evolve, including periodic reviews, regulatory monitoring, and preparation for your annual audit.
Training
We deliver tailored safeguarding training for your compliance team, finance team, and board, ensuring your people understand their obligations and how to meet them in practice.
Remediation
If the FCA has raised concerns about your safeguarding practices, we help you identify the root causes, implement corrective measures, and engage with the regulator on your behalf.
Feel free to reach out if you need something more bespoke or have specific requirements that aren't listed above. We're here to help and would love to discuss how we can support you.
Frequently Asked Questions
When does the Supplementary Regime come into force?
The new rules take effect on 7 May 2026. Firms should begin preparation now, as the operational changes required for daily reconciliation, monthly returns, resolution packs, and auditor engagement are significant.
Do I need an annual safeguarding audit?
Under the Supplementary Regime, annual safeguarding audits are mandatory for authorised PIs and EMIs that have safeguarded £100,000 or more over a rolling 53-week period. The audit must be conducted by a qualified auditor. We can manage this for you.
What is the Post-Repeal Regime?
The Post-Repeal Regime will replace the existing EMR and PSR safeguarding requirements with a CASS-style statutory trust framework. Under this regime, customer funds will be held on statutory trust, providing stronger insolvency protection. The implementation date has not yet been confirmed by HM Treasury.
How often should we review our safeguarding arrangements?
We recommend a formal review at least annually, aligned with your safeguarding audit cycle. However, any material change to your payment flows, banking relationships, or business model should trigger an immediate review to ensure your arrangements remain adequate.
Can you support us alongside our existing compliance team or auditors?
Yes. We regularly work alongside in-house compliance teams and external auditors, providing specialist safeguarding expertise to complement your existing resources. We can act as your primary safeguarding adviser or provide targeted support on specific areas.
What if the FCA has already raised concerns about our safeguarding?
We support firms through remediation following FCA supervisory engagement. We identify gaps, implement corrective measures, and can engage with the FCA on your behalf where appropriate.