Reference Case Number: FOI2025/01062
Freedom of Information: Right to know request:
Please provide the number of Authorised payment institutions, Small payment institutions,Electronic money institutions and Credit Unions that are expected to come into the scope of the CASS regulation when CASS 15 comes into effect in May 2026.
FCA response:
We do not have a precise estimate of how many firms may fall within the scope of the amendments to the Clients Assets Sourcebook (CASS). However, we do have data on the number of firms currently safeguarding client funds, which would be affected by the changes to the safeguarding requirements under CASS 15.
As of 10 October 2025, there are 695 firms currently safeguarding that would therefore be in the scope of CASS 15. This includes 384 Authorised Payment Institutions and 275 E-money institutions.
As with our existing rules, our proposed rules will apply to Small Payment Institutions (SPIs) on a voluntary basis only. The number of SPIs in scope will depend on how many choose to comply with the safeguarding requirements. Currently, 36 SPIs opt-in to safeguarding.
We are not aware of any Credit Unions that are currently required to safeguard.