FRC publishes interim guidance to support safeguarding auditors during transition to the FCA’s new supplementary regime
News types: Guidance
Published: 17 March 2026
The Financial Reporting Council (FRC) has today published new Interim Guidance on Payment and E-Money Safeguarding Assurance Engagements, providing support for safeguarding auditors as payment and e-money institutions prepare to transition to the Financial Conduct Authority’s (FCA’s) new Supplementary Regime, which comes into force on 7 May 2026.
The FCA’s new regime introduces enhanced requirements for recordkeeping, reconciliations and governance to address weaknesses in existing safeguarding arrangements and strengthen consumer protection. Safeguarding auditors will play a key role in assuring firms’ compliance with these expectations during the first audit cycle under the new regime.
The Interim Guidance provides principles to support high quality, consistent safeguarding assurance engagements from implementation of the new rules until the FRC issues a dedicated safeguarding assurance standard following public consultation, expected in 2027. It is intended to help auditors exercise professional judgement, plan their work and determine appropriate procedures in a period where legacy rules and new requirements operate in parallel.
The FRC emphasises that the Guidance is nonmandatory and is not a performance standard. It does not create new requirements, nor does it replace or override the Electronic Money Regulations (EMRs), Payment Services Regulations (PSRs) or CASS 15. A formal assurance standard will be introduced only after consultation and will be issued as an appendix to the existing CASS Assurance Standard.
To support familiarity for auditors, the Interim Guidance draws on the structure and principles of the CASS Assurance Standard and signposts relevant paragraphs. These references are illustrative and intended to aid understanding, rather than forming an exhaustive or prescriptive list. The Guidance does not require safeguarding auditors to conduct CASS style audits under the Supplementary Regime, nor does it mandate application of the CASS Assurance Standard in full.
Overall, the Interim Guidance is a transitional resource developed to help safeguarding auditors prepare for the introduction of the FCA’s Supplementary Regime while maintaining quality, consistency and appropriate professional judgement. It remains in effect only until the dedicated safeguarding assurance standard is finalised and comes into force.