CASS Accountant & Client Money Recruitment

Client money and client assets are among the most tightly regulated obligations that FCA-regulated businesses carry. The FCA’s Client Assets Sourcebook (CASS) sets out detailed rules for how firms must segregate, reconcile, record and report on money and assets held on behalf of clients. The accountant responsible for that process has to be technically competent as a qualified accountant and genuinely knowledgeable about the CASS regime: its daily and monthly reconciliation requirements, its record-keeping obligations, the Client Money and Assets Return (CMAR), and what the firm must do when a reconciliation break is found.

Accountancy Capital places CASS Accountants, Client Money Accountants, Client Assets Accountants and Heads of Client Money at FCA-regulated firms across the UK, typically at £50,000 and above. These are roles where the technical and regulatory requirements are specific enough that finding a genuinely capable candidate needs a specialist network rather than a generic finance search. This page explains who CASS applies to, what the roles involve, what they pay, how the new safeguarding rules for payments and e-money firms have changed demand, and how we run the search. If you need to talk a hire through now, call 0204 553 8893.

Who Must Comply with CASS

CASS applies to FCA-regulated firms that hold money or assets belonging to clients in the course of their business. The chapters that drive most finance hiring are:

• CASS 5 — client money held by insurance intermediaries, including brokers and MGAs operating statutory or non-statutory trust accounts.
• CASS 6 — custody of client assets (safe custody investments) held by investment businesses.
• CASS 7 — client money held by investment businesses, together with the client money distribution rules that apply if a firm fails.
• CASS 8 and CASS 11 — mandates (where a firm can control a client’s assets or liabilities) and client money held by debt management firms respectively.
• CASS 15 — the newer safeguarding chapter for payment institutions and e-money institutions, covered in more detail below.

The largest populations of CASS firms are investment firms, stockbrokers, discretionary and advisory wealth managers, platforms, custodians, fund managers and insurance intermediaries, with payments and e-money firms now a fast-growing group. Firms are also classified as CASS small, medium or large according to the client money and assets they hold, and the classification drives how much reporting, oversight and audit work the finance team has to support.

The rules specify precisely what records must be kept, when reconciliations must be performed and what must be reported to the FCA. A failure in the client money reconciliation — an unexplained break, an undocumented shortfall, a missed daily reconciliation — can trigger a notification obligation to the FCA. These are not administrative slips; they create direct regulatory exposure for the firm and for the individuals responsible for the process. For a primer on the regime itself, see our introduction to CASS and client money.

CASS Accountant Salaries and Day Rates

The figures below are typical London ranges for permanent base salary and interim day rates. Regional salaries are usually somewhat lower, and packages at larger investment firms often add a discretionary bonus. Our regulated firm finance salary guide covers the wider market.

Safeguarding accountants at payments and e-money firms broadly track the CASS Accountant and Senior CASS Accountant bands, with a premium for candidates who have already been through a safeguarding audit. For a fuller breakdown by role, see the CASS accountant job description and salary guide.

What a CASS Accountant Actually Does

The reconciliation cycle

The day-to-day work centres on reconciliations. Under CASS 7 the internal client money reconciliation is performed each business day: the firm compares its own record of what it owes clients (the client money requirement) with the client money it actually holds, and any shortfall must be identified, investigated and generally made good promptly, usually by the end of the same business day. The external reconciliation compares the firm’s internal records with the statements of the banks and other third parties holding the money, and must be carried out regularly — at least monthly. CASS 6 custody reconciliations follow a similar pattern for safe custody assets, with internal and external checks against custodians’ records. Every reconciliation has to be documented, reviewed and retained so that it can be evidenced to the auditor and the FCA. Our guide to CASS reconciliation in practice walks through the mechanics.

Breaks, notifications and records

Where a break cannot be explained and resolved quickly, the CASS Accountant typically leads the investigation and works with Compliance on whether the FCA needs to be notified. CASS requires firms to tell the FCA without delay about certain failures, including being unable to perform a required reconciliation or to make good a shortfall, and these sit alongside the general notification rules in the FCA’s Supervision manual. Alongside the reconciliations, the role maintains the firm’s client money records, acknowledgement letters for client bank and custody accounts, the CASS resolution pack and the client money policy, keeping them current as accounts open and close.

CMAR and regulatory reporting

The CASS Accountant prepares or contributes to the CMAR, which CASS medium and large firms submit monthly and which is now filed through the FCA’s RegData platform, the successor to GABRIEL. The return sets out client money and asset balances, reconciliation results and breaches, so the numbers have to agree with what the reconciliations show. In smaller firms the same person often also helps with prudential returns; where that work is substantial we usually recommend a dedicated regulatory reporting accountant.

The annual CASS audit

Firms holding client money or assets must have an external auditor report to the FCA on their compliance with CASS each year — the client assets report. The CASS Accountant is usually the auditor’s main point of contact: producing the population of reconciliations, evidencing breach logs and remediation, and responding to findings. A qualified or adverse report is one of the most common triggers for a new hire or an interim, and it is one area where candidates who have sat on the firm side of several CASS audits stand out. See the CASS audit and beyond for what auditors focus on.

CASS 15 and Safeguarding for Payments and E-Money Firms

Payment institutions and e-money institutions have long been required to safeguard customer funds, but historically under the payments and e-money regulations rather than CASS, and with lighter reconciliation and reporting expectations than investment firms faced. After a period of supervisory concern about shortfalls at failed firms, the FCA consulted on and finalised a strengthened regime, bringing safeguarding into a new CASS 15 chapter. The new rules took effect in 2026.

The detail is set out in the FCA’s client money and assets material and the Handbook, and firms should take their own advice on how it applies to them. In broad terms the regime moves payments and e-money firms much closer to the CASS discipline familiar to investment firms: more rigorous and frequent reconciliations, better records, a resolution pack, regular safeguarding returns to the FCA and an annual safeguarding audit. For the finance function, the practical result is that safeguarding is no longer something a generalist Finance Manager can look after in a few hours a week at many firms.

That has created a wave of hiring for safeguarding accountants and safeguarding managers, and a real shortage of people who have done the work under an audit regime. Candidates from CASS 7 backgrounds transfer well, but they need to understand the differences — the segregation and insurance or guarantee methods, the treatment of relevant funds, and how e-money float works in practice. Our article on CASS 7 versus CASS 15 client money experience explains what transfers and what does not, and the guide to hiring a safeguarding accountant covers scoping the role. For wider payments-sector finance hiring, see our fintech finance recruitment page.

Qualifications and Background

CASS Accountants are typically ACA or ACCA qualified, or qualified by experience at the operational level, with previous experience at a regulated investment firm, custodian, platform or wealth manager where they have been directly responsible for producing client money reconciliations rather than supervising them. The distinction matters: a candidate who has overseen a client money function but has not personally produced the daily and monthly reconciliations will usually take significantly longer to become independently productive than one who has run the process themselves.

Some CASS specialists come from a compliance rather than an accounting background — they have worked in client assets compliance or assurance roles and developed operational finance capability alongside their regulatory knowledge. Others trained in the client assets assurance teams of audit firms. These candidates are valuable where the firm’s main need is policy development, gap analysis and regulatory engagement rather than day-to-day reconciliation. In most cases, however, the regulated firm needs someone who can run the reconciliation independently and accurately, which points to the qualified accountant profile. A good interview tests this directly with real break scenarios; our CASS accountant interview questions give examples.

CASS Operations and CASS Oversight

At CASS medium and large firms, responsibility for CASS oversight sits with a named senior manager under the Senior Managers and Certification Regime: it is one of the prescribed responsibilities, usually allocated to the CFO, the COO or the Head of Compliance. That appointment is regulatory work handled by our sister firm SMF Capital, which places senior manager function holders such as SMF16 Compliance Oversight and SMF17 MLRO. Where the CASS oversight responsibility sits with a CFO or Finance Director, the search typically runs with FD Capital.

Accountancy Capital covers the finance and accounting layer beneath: the CASS Accountant, Client Money Accountant, safeguarding accountant and Head of Client Money who run the operational process the senior manager relies on. Getting both layers right matters, and the boundary between them is explained in CASS oversight versus CASS operations.

How We Run a CASS Search

We start with a short call to understand the firm’s CASS classification, which chapters apply, how the reconciliations are currently produced and by whom, the systems involved, and what triggered the hire — growth, an audit finding, a resignation or a new permission. That tells us whether you need an operator, a remediator or a manager, which are three different candidate pools. Fees are agreed in writing before the search starts.

For permanent roles we typically present a shortlist within one to two weeks, with each candidate’s CASS experience set out explicitly: which chapters, what volumes, which reconciliations they personally produced and how many audits they have supported. For interim and remediation work we can usually introduce available candidates within days. We work with firms across the UK from our London office in Great Portland Street and our West Midlands office in Cannock, and alongside our financial services recruitment team for wider finance hires. Interim engagements are assessed for IR35 status in the usual way, and we help clients and contractors work through it.

CASS Accountant Recruitment: FAQs

Do we need a dedicated CASS Accountant?

It depends on volume and classification. A CASS small firm with a handful of client bank accounts can often run the process within a Finance Manager’s role, provided the person has real CASS experience. Medium and large firms, and most payments firms under the new safeguarding rules, usually need at least one dedicated person.

Can a commercial Finance Manager learn CASS on the job?

Some can, but the learning curve is steep and the cost of mistakes is high. Where there is no experienced CASS person already in the team to train them, we recommend hiring someone who has run reconciliations before.

When should we use an interim CASS Accountant?

The common triggers are a qualified CASS audit report, a backlog of unresolved breaks, the sudden departure of the person who ran the reconciliations, or preparation for a new permission or regime such as CASS 15. An interim can stabilise the process while a permanent search runs.

Do you recruit the CASS oversight senior manager?

Senior manager appointments are handled by SMF Capital, and CFO-level appointments by FD Capital, both part of FD Capital Group. Accountancy Capital recruits the finance team that runs the process.

Which qualifications should we ask for?

ACA or ACCA is the norm at senior level, and the ICAEW and ACCA both offer technical resources on client assets. For operational CASS roles, demonstrable reconciliation experience matters more than the letters after a name.