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N/A — Industry-wide guidance

United Kingdom

On August 7, 2025, the UK Financial Conduct Authority (FCA) published Policy Statement PS25/12, introducing strengthened safeguarding rules for authorised payment institutions, e-money institutions, small e-money institutions, and credit unions issuing e-money. Pure PIS/AIS providers are excluded. The statement establishes an interim 'Supplementary Regime' effective May 7, 2026, designed to improve compliance, record-keeping, and monitoring of client fund safeguarding. The new rules aim to prevent client fund shortfalls and enable faster regulatory intervention when issues arise. Small payment institutions may opt in to the new regime. This represents a significant tightening of the UK's regulatory framework for payments and e-money firms.

Verified from source: The FCA published Policy Statement PS25/12 on 07/08/2025 regarding changes to the safeguarding regime for payments and e-money firms, following Consultation Paper CP24/20 which closed on 17/12/2024.

Implications
  1. UK-based BaaS and embedded finance firms must prepare for significantly enhanced safeguarding obligations by May 2026
  2. E-money institutions and payment firms will face greater record-keeping and monitoring burdens
  3. Sets a regulatory precedent that may influence other jurisdictions to tighten safeguarding rules for payment firms
  4. Fintech partners of UK EMIs should assess whether their infrastructure supports the new compliance requirements
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