CASS 7 vs CASS 15: Hiring the Right Client Money Skills

“CASS experience” has always been one of the least useful phrases in a regulated finance job specification, because it describes several genuinely different jobs. Since 7 May 2026 it has become less useful still. The FCA has brought payments and e-money firms into the Client Assets Sourcebook through a new chapter, CASS 15, and a wave of payments firms is now hiring for safeguarding roles at the same time as investment firms continue to hire for CASS 7. A candidate who has run client money reconciliations at a wealth manager under CASS 7 is not interchangeable with one who has run safeguarding at an e-money institution — the legal basis differs, the reconciliation cycle differs, the reporting differs and the failure modes differ. But a great deal of the discipline does transfer, and employers who understand which parts are the ones who hire well from a small pool.

This guide sets out what each regime covers, where they differ, and how to assess client money experience across the two. The rules themselves sit in the FCA Handbook’s CASS sourcebook; this is a practical account for employers and finance professionals, not a compliance opinion. If you need the foundations first, start with our introduction to CASS and client money.

CASS 7: client money for investment business

CASS 7 is the regime most people mean by “CASS”. It applies to investment firms, wealth managers, discretionary managers, platforms and brokers that hold money for clients in the course of investment business, and it usually sits alongside CASS 6 for custody assets — firms rarely have one without the other. Its legal foundation is the statutory trust: client money is held on trust for clients, not as the firm’s own money, and if the firm fails it is pooled and distributed to clients under CASS 7A.

The operational core is the reconciliation cycle. Each business day the firm performs an internal reconciliation, comparing its record of what it owes clients (the client money requirement) with the client money it holds (the client money resource), and any shortfall is generally made good from the firm’s own money by the end of that business day. The external reconciliation, against bank and third-party statements, is performed as regularly as necessary and at least monthly. Around that sit acknowledgement letters for client bank accounts, the choice between the normal and alternative approaches to segregation, the CASS 10 resolution pack, the Client Money and Asset Return (CMAR) — submitted monthly by CASS medium and large firms — and an annual CASS audit, in which the auditor reports on the firm’s compliance directly to the FCA. Our guide to the CASS audit and beyond covers that last stage in detail.

CASS 15: safeguarding for payments and e-money firms

Payment institutions and e-money institutions have always had to safeguard customer funds, but historically that obligation sat in the Payment Services Regulations 2017 and the Electronic Money Regulations 2011, supported by guidance in the FCA’s Approach Document rather than detailed rules. After shortfalls at failed payments firms, the FCA consulted in CP24/20 and published its final rules in PS25/12 in August 2025. The new CASS 15 chapter, together with amendments to the Approach Document, came into force on 7 May 2026 after a nine-month implementation period.

The FCA calls this the “supplementary regime”: binding Handbook rules that sit on top of the existing regulations and turn much of what was previously guidance into requirements. It applies to authorised payment institutions (other than those providing only payment initiation or account information services), authorised and small e-money institutions, and credit unions that issue e-money; small payment institutions can opt in. Its main requirements are:

• Daily reconciliations. Internal and external safeguarding reconciliations at least once each reconciliation day — business days, excluding days when the relevant foreign currency markets are closed.
• A monthly safeguarding return to the FCA covering the firm’s safeguarding arrangements and reconciliation outcomes.
• An annual safeguarding audit by a qualified auditor, with the first report due within six months of the end of the audit period and later reports within four months. Firms that have not had to safeguard more than £100,000 at any time over the previous 53 weeks are exempt, as are payment initiation providers, small payment institutions and credit unions.
• A resolution pack under CASS 10A, so an insolvency practitioner can identify and return relevant funds promptly.
• Stronger records, due diligence and contingency planning — including periodic due diligence on banks holding relevant funds and, for firms safeguarding by insurance or guarantee, a contingency plan in place at least three months before the policy expires.

What CASS 15 does not do is introduce a statutory trust. PS25/12 also set out a later “post-repeal” regime that would replace the safeguarding provisions of the regulations with a fuller CASS-style framework including a trust, but the FCA has said it will not take that forward without further consultation. Our guide to safeguarding for payments and e-money firms covers the regime from the finance function’s side.

CASS 7 and CASS 15 side by side

Other client money regimes still matter at the edges: CASS 5 for insurance intermediaries, with its risk transfer and statutory or non-statutory trust arrangements; CASS 11 for debt management firms; and CASS 13 for claims management firms. Each has its own calculation and its own talent pool.

Why the experience is not automatically interchangeable

Three reasons, and they compound.

The cycle and the money flows differ. A CASS 7 practitioner is used to a daily internal reconciliation and a monthly external one, built from individual client balances. A safeguarding accountant reconciles both internally and externally every reconciliation day, across e-money float, payment flows in transit, card scheme and acquirer settlements, agents and distributors, and often several currencies. The underlying discipline — reconcile, evidence, resolve differences — transfers; the mechanics and the volumes do not.

The failure modes differ. What goes wrong under CASS 7 tends to involve unallocated receipts, stale client balances and acknowledgement letters not in place. Under CASS 15 it more often involves relevant funds not segregated by the end of the business day after receipt, e-money and unrelated payment funds mixed, own funds left in safeguarding accounts, or insurance and guarantee arrangements allowed to drift towards expiry. An experienced person knows where to look in their own regime and does not in another.

The audit and the history differ. The CASS audit is mature and its findings well understood. The safeguarding audit under CASS 15 is new, and in practice very few people have yet been through a full cycle under the new rules. That makes candidates who have lived through several CASS 7 audits valuable to payments firms — they know what an auditor will want to see — provided they can learn the safeguarding rulebook quickly.

What transfers: the skills worth paying for

Qualification is the baseline — ICAEW, ACCA or CIMA — but it says nothing about regime experience. When the exact regime does not match, these are the skills that carry across and that we look for first:

• Personal ownership of a daily reconciliation — producing it, not just reviewing it, including chasing breaks to resolution.
• The client money mindset — the instinct that customer money is not the firm’s money, and the discipline to keep the two apart under time pressure.
• Breach handling — identifying, quantifying, escalating and reporting a breach promptly rather than resolving it quietly.
• Audit experience — having produced populations and evidence for a client assets audit and closed out findings.
• Regulatory reporting accuracy — a CMAR or safeguarding return that agrees to the underlying reconciliations and records.
• Resolution pack and records discipline — documentation that would stand up if an insolvency practitioner walked in tomorrow.

The things that need learning are narrower: the safeguarding methods (segregation versus insurance or guarantee), what counts as relevant funds, how e-money float and payment flows behave in practice, and the specific CASS 15 timings. A strong CASS 7 accountant can usually get there in a few months with support; the reverse move, from safeguarding into CASS 7, means learning the statutory trust, the client money calculation and the CASS 7A distribution rules.

Specifying the role properly

Four things to state, and the first two are where most specifications fail.

Name the regime. “CASS 7 and CASS 6 experience” or “CASS 15 safeguarding experience” is a filter; “CASS experience” is not. If you would accept the other regime, say so — it widens the pool considerably.

State what the role owns. Preparing the reconciliation, reviewing it, owning the calculation, owning the breach register, preparing the CMAR or safeguarding return, being the named contact for the audit — these are different levels of responsibility and candidates read them carefully.

Say whether there is an oversight function and whether this role is it. In smaller firms the finance person effectively is the oversight function, which is a significantly different job carrying personal visibility to the regulator. Where the senior manager role itself is the hire, our sister firm SMF Capital runs those appointments.

Describe the operational scale — number of client or customer accounts, transaction volume, currencies, banks and safeguarding methods, and what systems support the reconciliation. A candidate from a firm reconciling thousands of accounts daily has done something different from one at a small manager.

Our CASS accountant job description and salary guide provides a template, and the guide to hiring a safeguarding accountant covers the payments version of the role.

Testing for it at interview

Six questions that separate genuine ownership from adjacency, whichever regime applies.

1. Talk me through your reconciliation, step by step. The single most revealing question. Someone who has owned it describes the sources, the timing, the differences that recur and how they are cleared. Someone who has reviewed it describes the output.

2. Which regime, and what does your calculation actually involve? Ask them to explain the client money requirement and resource, or how they establish relevant funds, in their own words. This is where regime mismatch surfaces immediately.

3. Tell me about a breach. Everyone who has worked in client money or safeguarding has seen one. Strong answers describe identifying it, quantifying it, reporting it promptly and the remediation — not a claim that nothing has ever gone wrong.

4. What did your auditor raise, and what changed? Ownership of findings rather than deflection, and the same question that works at every level of finance hiring.

5. Where would you look first in a firm you have just joined? Experienced people have a mental checklist: acknowledgement letters, unallocated receipts, stale balances, funds in transit, the age of differences. The answer reveals depth quickly.

6. For a CASS 7 candidate moving to payments: what do you think changes under CASS 15? You are not looking for a perfect answer, but for someone who has read the rules and can name daily external reconciliation, the absence of a statutory trust and the monthly return.

Our CASS interview questions guide sets out the full sequence including breach scenarios.

When a different regime is acceptable

Being pragmatic matters, because the pool is small in every regime and, for experience under the new CASS 15 rules, tiny. A candidate from the other regime is frequently the right hire where three things are true: they have genuinely owned a reconciliation and a calculation, not merely contributed; they have been through a client assets or safeguarding audit and can describe the findings; and there is someone in the firm — internal or external — who knows your regime and can support the transition. On that basis a strong CASS 7 candidate moving into a safeguarding role is a reasonable appointment with a learning curve of a few months.

Where it is not acceptable: a firm with no existing client money expertise appointing someone from a different regime as its sole resource. That combination puts an inexperienced-in-context person in a position of regulatory exposure with nobody to check against, and it is where breaches most often go unnoticed. In that situation an interim with direct regime experience, alongside the permanent hire, is often the better answer.

What the market looks like

Three realities worth planning around. The pool is small and largely employed — CASS and safeguarding specialists rarely appear on job boards, so searches rely on direct approach. The premium is real: in London, CASS Accountants typically earn £52k–£72k, Senior CASS Accountants £65k–£85k and Heads of Client Money £75k–£100k, with safeguarding accountants at £55k–£75k and interim CASS specialists at £380–£520 a day. Demand from payments firms since CASS 15 has pulled CASS 7 candidates across, tightening both pools. And the audit cycle drives timing — hiring in the run-up to an audit is the hardest version of it, and an interim covering the period is frequently better than a rushed permanent appointment. Full benchmarks are in our regulated-firm finance salary guide, and the CASS accountant recruitment practice covers the search.

CASS 7 vs CASS 15: FAQs

Is CASS 15 the same as CASS 7 for payments firms?

No. CASS 15 borrows the CASS disciplines — daily reconciliation, regular returns, an audit and a resolution pack — but safeguarding still rests on the Payment Services and Electronic Money Regulations rather than a statutory trust, and the reconciliation and reporting rules differ.

When did CASS 15 come into force?

On 7 May 2026, following the FCA’s policy statement PS25/12 in August 2025 and a nine-month implementation period.

Can a CASS 7 accountant do a safeguarding role?

Often, yes — if they have personally owned reconciliations, handled breaches and supported an audit, and if someone in the firm knows the safeguarding rules. Expect a learning curve of a few months.

Do all payments firms need a safeguarding audit?

Most do. Firms that have not had to safeguard more than £100,000 at any time over 53 weeks are exempt, as are payment initiation providers, small payment institutions and credit unions.