The purpose of the CASS rules is to keep client assets safe in the event of a firm's failure. The fundamental requirement is for firms to keep client money separate from their own in segregated accounts, and to register custody assets appropriately.

Traditionally investment, trading and asset management firms under CASS 6 and 7. Since May 2026, payments and e-money firms safeguarding relevant funds under CASS 15. From 25 October 2027, stablecoin issuers under CASS 16 and cryptoasset custodians under CASS 17.

CASS 15 went live on 7 May 2026 under FCA Policy Statement PS25/12, replacing the previous safeguarding approach for payments and e-money firms. It reformed reconciliations, books and records, monthly reporting and resolution packs, and introduced a mandatory annual safeguarding audit by a qualified auditor.

CASS 15 requires a safeguarding reconciliation at least once each Reconciliation Day, rather than each business day. A Reconciliation Day excludes weekends, bank holidays and days on which relevant foreign markets are closed. Firms running more than one internal reconciliation a day will have multiple reconciliation points.

The final rules call it a high-level comparison rather than a reconciliation, but the substance is unchanged: it compares two data sources to verify compliance with PSRs 23(6) or EMRs 21(2). The methodology is less prescriptive than in consultation, though the data you need to source is not.

Not always. Where a foreign exchange transaction is independent of a payment service, the firm acts as principal and those funds are not relevant funds, provided its policies keep them clearly separate. But if the exchanged currency is retained for a subsequent payment service or to issue e-money, it becomes relevant funds immediately. That distinction does not apply to currency transfers, or where funds are received to issue e-money in a different currency.

The FCA revised CASS 15.1.5G on this point, and the exclusion now applies only where a firm operates from outside the UK, through an overseas branch. Firms that previously excluded funds on a broader reading of territorial scope should revisit that interpretation.

CASS 16 requires stablecoin issuers to back every qualifying stablecoin 1:1 from the moment it is minted, hold the backing asset pool on statutory trust, and reconcile the pool against coins in circulation. CASS 17 requires cryptoasset custodians to reconcile internal records against the wallet addresses they control and against assets held by third parties, each business day. Both bring a CASS oversight officer, annual independent audit and regular regulatory reporting. Final rules were published in 2026 and apply from 25 October 2027.

Yes, where you hold fiat. A firm safeguarding cryptoassets under CASS 17 that also handles fiat currency, for example for on and off ramping, is subject to CASS 7 client money rules as well. Firms often underestimate this, and it widens the compliance obligation considerably.

Internal client money reconciliations are generally expected daily, with external reconciliations as frequently as practicable. Aurum runs reconciliations automatically as balances arrive, so daily, or several times a day, is the default rather than a stretch.

A spreadsheet can produce the calculation but not the control around it. There is no enforced segregation between clients, no immutable record of who changed what, and a breach is only visible when someone opens the file. Automation gives you the position continuously and the evidence automatically.