With the implementation of new UK payment safeguarding rules now just six months away, more than three-quarters of financial institutions have yet to progress beyond the early stages of preparation.
From 8 May 2026, payment and e-money institutions will be required to comply with the Financial Conduct Authority’s (FCA) updated safeguarding framework, shifting expectations from recommended good practice to binding regulation. The measures introduce more stringent operational demands and closer regulatory scrutiny. Institutions must keep customer funds segregated at all times, carry out daily reconciliations on working days, maintain detailed records, and complete independent safeguarding audits, with the resulting reports submitted directly to the FCA.
A live poll of 68 payments professionals conducted at a safeguarding event hosted by Clear Junction and Howden underscored the readiness gap across the sector:
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Just 7% of firms report being fully compliant
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Fewer than 22% say they are in advanced preparation
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The majority (78%) remain in early preparation (59%) or have yet to begin (19%)
The event, held at Howden’s London headquarters, gathered senior leaders from payments, legal, and compliance fields to explore how firms are adapting to the new regime. Speakers included Teresa Cameron, Group CEO of Clear Junction; Hugo Thorp, Head of Fintech at Howden; Alison Donnelly, Director at fscom; Sam Robinson, Partner at CMS; and Riccardo Tordera-Ricchi, Head of Policy and Government Relations at The Payments Association.
Poll respondents highlighted several operational challenges in meeting the new standards:
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Next-day (D+1) reconciliations — ensuring that client funds are matched and verified by the following business day — emerged as the most pressing friction point, cited by 58%
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Other difficulties include managing UK and EU regulatory changes without duplication (19%), securing insurance wording that satisfies FCA criteria (13%), and improving the quality of monthly management information (10%)
Teresa Cameron, Group CEO of Clear Junction, commented: “Reconciliations are always at the top of the leaderboard, but they are only one part of the challenge. Firms also face the short supply of safeguarding banks, the issue of liquidity, and the requirement to keep resolution packs as living, breathing documents.
“The practical way forward is to diversify approaches: using a hybrid method of segregation where possible and insurance where banks are scarce, ensuring liquidity across 24/7 payment schemes, automating reconciliations to meet next-day requirements, and keeping resolution packs updated so they can be relied upon in an insolvency.”
Alison Donnelly, Director at fscom, said: “The poll results chime with what we also hear from firms. Many are still at the early stages; some are starting to safeguard from scratch and asking when obligations start and end. More mature firms are figuring through D+1 calculations and reconciliations, and seeking interpretation advice on what constitutes a material breach and what ‘without undue delay’ really means.
“The FCA has always said safeguarding is extremely important, but this May deadline is one you will be tested on; your homework will be marked. Every authorised payment institution and e-money institution will have its safeguarding arrangements tested by a qualified auditor. Stakeholders need to be prepared for that reality.”
Hugo Thorp, Head of Fintech at Howden, said: “Safeguarding needs to be right; there can’t be any gaps that leave customers unprotected. We’ve added an intent-to-renew clause to give firms certainty that there will be no cliff-edge scenarios. Insurance can sit alongside segregation, adding a layer of coverage and helping firms diversify their approach while maintaining liquidity.”
Sam Robinson, Partner at CMS, added: “Before it was guidance, and now it’s rules. That makes expectations stricter and more specific, including for insurance policy wording: funds should be paid promptly into safeguarding accounts with no impediments beyond proof of insolvency, with clear clauses on timing, non-cancellation and notice.”
With the deadline approaching, firms must translate regulatory expectations into day-to-day processes that can withstand audit scrutiny and ensure the protection of client funds.
Key actions ahead of May 2026:
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Introduce automation to deliver D+1 reconciliations across weekends and multiple time zones
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Ensure liquidity is maintained for 24/7 payment schemes
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Keep resolution packs continuously updated for potential insolvency scenarios
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Prepare for safeguarding audits by mapping internal controls to FCA requirements and arranging qualified auditors
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Review insurance arrangements to verify clauses covering timing, non-cancellation, notice periods, and prompt insolvency payouts
Clear Junction and Howden will continue supporting organisations across the payments and insurance sectors as they move from regulatory interpretation to operational readiness in advance of the May deadline.
