Hiring an FC for a Payments Firm: Safeguarding Skills

Safeguarding is the obligation that most distinguishes finance in an authorised payments or e-money firm from finance anywhere else, and it is the one most often under-tested when hiring. A Financial Controller who has never safeguarded relevant funds can produce immaculate management accounts while the firm carries a regulatory exposure nobody in the building fully understands. This guide is about the hiring question rather than the rules: what safeguarding experience actually looks like on a CV, how to test it properly at interview, where the common gaps are, and when adjacent experience is acceptable.

It is written for firms hiring a Financial Controller — the person who runs the whole finance function, of which safeguarding is one critical part alongside own funds, regulatory returns, the month-end, investor reporting and the wind-down plan. If you are instead hiring a specialist whose whole job is safeguarding, our separate guide to hiring a dedicated safeguarding accountant covers that role, its candidate pools and its pay.

For the obligation itself, the FCA’s payment services and e-money pages are authoritative, and our guides to safeguarding for payments and e-money firms and e-money and payments regulation cover the framework. This page assumes that ground.

Why the finance role is different here

Three things change once a firm is authorised and holding relevant funds.

The reconciliation is a regulatory obligation, not a control preference. Since 7 May 2026, CASS 15 has required internal and external safeguarding reconciliations at least once each reconciliation day, with any shortfall made good promptly, and the discipline is closer to client money than to ordinary treasury. An FC who treats it as a month-end task has misunderstood the requirement.

The segregation method has to be understood, not just operated. Whether funds are safeguarded by segregation in a designated account or by an insurance or guarantee method changes what the FC must do every day, and firms sometimes use both across different products.

And the audit is different. Safeguarding audits examine the arrangement, the reconciliations, the evidence and the acknowledgement position — a set of questions a commercially trained FC will not have encountered, and the CASS 15 chapter of the FCA Handbook is the reference point rather than any accounting standard.

The practical consequence: safeguarding is not a bolt-on to a standard FC role. It changes the daily rhythm, the control framework and the risk profile of the seat.

What CASS 15 changed for the FC

Safeguarding still rests on the Payment Services Regulations 2017 and the Electronic Money Regulations 2011. What changed is that the FCA, in policy statement PS25/12, added binding Handbook rules on top of the regulations through CASS 15, in force from 7 May 2026. For the FC, the operational requirements are:

• Internal and external safeguarding reconciliations at least once each reconciliation day.
• A monthly safeguarding return to the FCA covering the arrangements and reconciliation outcomes.
• An annual safeguarding audit by a qualified auditor — 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, so an insolvency practitioner could identify and return relevant funds promptly.
• Stronger records, periodic due diligence on the 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: relevant funds remain protected through segregation or insurance and guarantee arrangements under the regulations. A candidate who describes safeguarded funds as “held on trust” is probably speaking from a CASS 7 background, which is worth exploring rather than dismissing.

What genuine experience looks like on a CV

Four markers, in rough order of usefulness.

Named regime and method. A CV that says “safeguarding under the PSRs and CASS 15, segregation method, reconciliation of relevant funds each reconciliation day across three currencies” is describing ownership. One that says “experience of regulatory requirements including safeguarding” is describing proximity.

Reconciliation ownership. Look for who prepared it, who reviewed it, and at what frequency. Each reconciliation day is now the rule under CASS 15; anything less in a recent role needs explaining.

Audit exposure. Having been the firm-side contact for a safeguarding audit is a strong signal, and the findings tell you more than the fact of it.

Scale and complexity markers. Number of safeguarded accounts, currencies, whether funds pass through a scheme or acquirer, and whether the firm operates an agent or distributor network — each adds real complexity and narrows the pool.

Qualification — ICAEW, ACCA or CIMA — is the baseline and tells you nothing about the regime. Two things that are not evidence: working at a fintech (many are not authorised, or are agents of a principal firm and therefore do not safeguard at all), and holding a qualification. Neither implies the experience.

The rest of the FC CV

Safeguarding is the filter, but an FC at a payments firm is hired for the whole seat. Alongside it, look for the own funds calculation — under Method A, B or C for a payment institution, or broadly 2% of average outstanding e-money for an e-money institution; FCA returns submitted through RegData, now including the monthly safeguarding return; a board or investor pack for a VC- or PE-backed business; revenue recognition across transaction, interchange and float income; and a current, board-approved wind-down plan. Our page on the Financial Controller role in fintech firms sets out each of these in detail, and five things fintech FCs know about PSR safeguarding covers the instincts that separate experienced payments FCs from commercial ones.

Testing it at interview

Six questions. If you lack the expertise to assess the answers, involve your compliance lead in one stage — it is the most effective thing a non-specialist hiring manager can do.

1. Walk me through your safeguarding reconciliation, step by step. Sources, timing, what is compared to what, and where differences typically arise. Someone who has owned it describes the awkward parts — in-flight transactions, settlement timing, scheme funds — without prompting.

2. Which method does your firm use, and why? Segregation, insurance or guarantee. A candidate who does not know the method has not owned the obligation.

3. What counts as relevant funds in your business, and what does not? The scoping question, and where genuine understanding shows. Firms get this wrong at the edges — fees, own funds commingled in error, timing of when funds become relevant.

4. Tell me about a shortfall or a discrepancy. Anyone who has run this has had one. Strong answers describe identification, quantification, making good, and reporting — not a claim of a perfect record.

5. What did your safeguarding auditor raise, and what changed? Ownership of findings, and the same question that works throughout regulated finance.

6. If you joined us on Monday, what would you check first? Experienced candidates have a checklist: the acknowledgement letters, the account designation, the age and nature of reconciling items, whether own funds have ever been commingled. The answer reveals depth in about ninety seconds.

For an FC hire, add two questions that test the rest of the seat: how do you calculate own funds, and what headroom do you report to the board? and what has changed in your returns since CASS 15 came into force? The second should prompt an answer about the monthly safeguarding return, the audit and the resolution pack without further help. Candidates preparing for these interviews will find our interview preparation guide for regulated-firm finance useful too.

The common gaps

Fintech experience without authorisation. The most frequent mismatch. A candidate from a fintech operating as an agent of an authorised principal has never safeguarded anything, because the principal does. This is not on their CV as a caveat and it needs asking about directly.

Reviewed rather than owned. Common in larger firms where an operations team prepares the reconciliation and finance signs it. Perfectly good experience, but a different job from building and owning it in a smaller firm.

Client money conflated with safeguarding. A CASS 7 background is genuinely valuable and adjacent — the mindset transfers — but the regimes are not the same, and a candidate who uses the terms interchangeably has not worked in both. CASS 7 rests on a statutory trust with a monthly external reconciliation; CASS 15 has no statutory trust and requires both reconciliations each reconciliation day. See our comparison of the client money regimes.

And crypto without the perimeter. Cryptoasset firms may or may not hold relevant funds depending on their permissions and structure; ask what was actually safeguarded rather than assuming.

Senior manager assumptions. A further gap sits on the employer side. Payment and e-money institutions authorised only under the PSRs and EMRs are not SM&CR firms, although the FCA must be told who is responsible for managing them and assesses those individuals. Specifications that ask an FC to “hold the SMF function” at a pure payments firm signal confusion to experienced candidates. Where a fintech also holds FSMA permissions and does fall within SM&CR, our guide to SM&CR for finance teams explains the position, and senior manager appointments run through our sister firm SMF Capital.

When adjacent experience is acceptable

The pool is small, so pragmatism matters. Adjacent experience is usually the right hire where three things hold: the candidate has genuinely owned a daily reconciliation obligation in some regime — CASS, safeguarding elsewhere, or client money; they have been through a relevant audit; and there is existing expertise in the firm, internal or external, to support the first six months.

Where it is not acceptable: an authorised firm with no existing safeguarding expertise appointing someone without it as the sole finance resource. That places an unfamiliar regulatory obligation on an unsupported person, and it is the configuration in which breaches go unnoticed longest.

FC, safeguarding accountant, or both?

Where the FC candidate is strong on everything but safeguarding, the answer is sometimes not a different FC but a second hire. Firms with material balances, several currencies or agent networks often pair the FC with a dedicated safeguarding accountant who runs the reconciliations, the breach log and the audit file, leaving the FC to own the framework, the own funds position and the board reporting. Smaller firms more often hire an FC with genuine safeguarding ownership and add an interim specialist for a few weeks to test the design before the first audit. Our safeguarding accountant hiring guide sets out when the specialist role is justified, and interim and fractional finance in FCA-regulated firms covers the bridging options.

Specifying the role

Four things to state, and most specifications state none of them. Name the authorisation — authorised payment institution, e-money institution, small payment institution, or agent of a principal — because it determines whether safeguarding and CASS 15 apply at all (small payment institutions can opt in; agents rely on their principal). Name the method. State what the role owns: preparing the reconciliation, reviewing it, owning the monthly safeguarding return, owning the audit relationship, being the escalation point. And describe the operational shape — volumes, currencies, whether there is an operations team or whether finance does it all.

Doing so reaches a much smaller but far more relevant pool, and it filters out the fintech-but-not-authorised candidates before they reach interview. Our guides to building a finance function at a regulated firm and hiring for regulatory experience cover the wider specification question, and benchmarks are in the regulated-firm finance salary guide.

What to pay a payments-firm FC

Genuine safeguarding ownership carries a premium over the commercial FC market because the pool is narrow. Typical ranges, consistent with our fintech FC benchmarks:

Across fintech FC roles overall, London salaries typically run £65k–£95k. Firms that hire an FC without safeguarding experience and later add the specialist alongside usually spend more in total than they would have on the right FC at the outset — worth factoring in when a strong candidate’s expectations sit at the top of the band. Wider benchmarks are in our Financial Controller salary guide.

Hiring an FC for a payments firm: FAQs

Does every payments firm need its FC to have safeguarding experience?

Every authorised payment or e-money institution holding relevant funds needs someone who understands safeguarding. If the FC is the sole senior finance resource, that person should be the FC. Where a dedicated safeguarding accountant or strong external support exists, adjacent experience can work.

How often must safeguarding be reconciled?

Under CASS 15, in force since 7 May 2026, internal and external safeguarding reconciliations must be performed at least once each reconciliation day — business days, excluding days when the relevant foreign currency markets are closed.

Is a CASS 7 client money accountant a credible FC candidate?

Often, for the safeguarding part — the reconciliation and audit discipline transfers, though the statutory trust, reconciliation timings and returns differ. Check the rest of the seat separately: own funds under the PSRs or EMRs, RegData returns and investor reporting are not part of a CASS 7 role.

Does our FC need to be an approved senior manager?

Not at a firm authorised only under the PSRs and EMRs, which are not SM&CR firms, although the FCA assesses the individuals responsible for managing the firm. Fintechs with FSMA permissions may be in SM&CR, in which case the position differs.

Should we start with an interim FC?

Where an audit, an authorisation milestone or a departure makes timing tight, an interim payments FC at around £440–£600 a day in London can stabilise the reconciliations and returns while the permanent search runs. Interim candidates are typically available within days.