May 2026 marks a pivotal moment for payment and e-money firms. When CASS 15 enters into force, the industry will divide between those who prepared their infrastructure early and those scrambling to comply.
While many firms view CASS 15 safeguarding as a compliance exercise, the convergence of multiple regulatory pressures demands an operational shift—from reactive compliance to proactive resilience.
With five months remaining, the window for preparation is closing fast. Firms still relying on spreadsheets and manual processes need to act now.
The consolidation challenge
The payments industry generates around $2.5 trillion in revenue, supported by over 3.5 trillion global transactions. As digital payments become the default across markets, manual reconciliation is no longer a sufficient basis for operational resilience.
But the challenge isn’t just volume. Regulations are intensifying, and new asset classes are emerging. Firms that previously viewed compliance as a series of reactive, deadline-driven projects are discovering their infrastructure simply cannot scale to meet both growth and regulatory demands simultaneously.
The FCA’s CASS 15 will impose daily reconciliation requirements, mandatory audits, and comprehensive resolution planning on payment and e-money firms. As operations shift from periodic safeguarding checks to continuous monitoring, legacy systems built for monthly reporting cycles cannot keep pace.
The gap between regulatory timelines and organisational readiness is widening. Most firms are trying to meet new requirements with old infrastructure, adding manual processes and workarounds that prove costly, time-consuming, and operationally risky.
The FCA officially published its policy statement on CASS 15 in August, outlining the safeguarding changes required. When you consider what’s involved—assessing current capabilities, identifying infrastructure gaps, selecting and implementing new technology, migrating data, testing processes, and training staff—there’s little room for delay. Each step takes months. With the deadline now five months away, early preparation separates compliance from crisis.
Why infrastructure will fail
The root cause lies in how data is managed across financial institutions.
Consider the daily reconciliation requirement under CASS 15. Many payment firms currently reconcile funds weekly or monthly using spreadsheets and manual processes. Moving to daily reconciliation requires a complete operational overhaul.
Success depends on automated data pipelines, real-time tracking, and streamlined audit trails – capabilities that legacy systems are simply not equipped to provide.
Current data infrastructures are creating blind spots that only become apparent under regulatory stress. Until firms identify where these gaps lie, they’ll find themselves scrambling when the deadline arrives.
Data first approach
Data underpins every operation. Too many firms are using misaligned systems and working with inaccurate or incomplete datasets across their processes. This misalignment creates operational risk, meaning reconciliation struggles to deliver the real-time visibility regulators now demand.
Automation is no longer optional. Automated data pipelines, real-time exception monitoring, and continuous reconciliation aren’t enhancements – they’re prerequisites for compliance. Bolting compliance solutions onto existing infrastructure is a recipe for failure.
Firms need to consolidate data sources into unified systems that eliminate reconciliation breaks before they occur. They need validation rules that flag exceptions immediately, not days later during batch processing. They need audit trails that capture every transaction decision automatically.
The organisations prepared for CASS 15 are those already operating this way. They’ve invested in infrastructure that makes daily reconciliation routine.
The Bottom Line
Firms need to audit their reconciliation processes now to ensure they’re compliance ready. The cost of inaction – whether regulatory penalties, licence revocation, or operational disruption – will far outweigh the investment in getting infrastructure right.
May 2026 will reveal which firms treated regulatory change as a technology investment opportunity. The deadline won’t move. The only variable is how proactively you respond.
Those who act now will gain the competitive edge that separates market leaders from those perpetually playing catch-up.