Home › Services › Safeguarding › Safeguarding audit readiness

Safeguarding audit readiness

Your safeguarding ready for the annual audit, before the auditor arrives.

Reviewed by Harry Khan, Founder · 10 November 2026

Since 7 May 2026, authorised payment institutions and e-money institutions above a £100,000 threshold must have an annual safeguarding audit, reported to the FCA. We prepare firms for it: we test the arrangements the auditor will test and fix what would fail.

What we check

The auditor reports on whether your systems were adequate throughout the period and whether you complied at the period end. We check both.

See also: Safeguarding services · Compliance health check

How it runs

  1. ReviewWe test a sample of reconciliation days, records and breaches across the period, as the auditor will.
  2. ReportYou receive each gap with its likely audit impact and the fix.
  3. FixWe help put the fixes in place and document them, so the record shows the issue, the fix and the evidence.
  4. Hand overYour evidence is organised for the auditor before fieldwork starts.

The audit at a glance

ItemPosition from 7 May 2026
Firms in scopeAuthorised payment institutions (other than payment initiation or account information only) and e-money institutions
ExemptionNot required to safeguard more than £100,000 at any time over at least 53 weeks
Assurance levelReasonable assurance
AuditorEligible as a company auditor under the Companies Act 2006, and independent
First reportWithin six months of the period end
Later reportsWithin four months of the period end

Get in touch

Tell us where you are and where you want to be.

[email protected]
+44 7563 115980 (phone and WhatsApp)

Further detail

We prepare you; the auditor gives the opinion

The safeguarding audit itself must be carried out by an auditor eligible for appointment as a company auditor. We are not your auditor. We prepare the firm so the audit finds working arrangements and a clear record, and we can help you respond to the auditor’s findings.

Why the whole period matters

The auditor tests the whole audit period, not one date. A weakness in month three must be disclosed even if it was fixed in month nine. What counts is a clear record of the issue, the fix and the evidence that the fix worked. Our guide to safeguarding audits explains the rules in full.

Firms below the threshold

Firms within the £100,000 exemption, and small payment institutions that safeguard voluntarily, still need adequate arrangements and still file the monthly return. Many banks and partners ask for independent assurance, and a readiness review provides it.

Questions

Do we need a safeguarding audit?

Yes, if you are an authorised payment institution or an e-money institution and have been required to safeguard more than £100,000 at any time in the last 53 weeks. One day above the threshold is enough.

Can you carry out the safeguarding audit?

No. The audit must be carried out by an independent auditor eligible for appointment as a company auditor. We prepare you for it and help you respond to the findings.

When is the first report due?

For audit periods ending within 12 months of 7 May 2026, within six months of the period end. Later reports are due within four months.

What does the auditor test?

Whether your systems were adequate to comply with the safeguarding rules throughout the period, and whether you complied at the period end. Every breach found is listed in the report.

Can a breach be fixed before the audit?

It should be fixed as soon as it is found, but it is still reported. The auditor looks for a clear record of the breach, the fix and the evidence that the fix worked.

Sources

From the blog

All articles