CASS 15 Compliance Checklist: What Do Firms Need To Do? Reconciliation Special.

With the CASS 15 deadline right around the corner, FCA-regulated firms are starting to make plans and introduce new systems and processes to ensure compliance. 

One area of focus is reconciliations. Almost every regulated firm will have some form of reconciliation process currently in place, but none of these are likely to fully comply with the CASS 15 regulatory requirements. We’ve put together the below series of key questions that you need to ask as you plan your response to the regulatory changes.

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Question 1: What are our reconciliation processes today?

As a first order question, this seems fairly straightforward, but there’s more to unpick here, with lots of questions underpinning this. We recommend looking at this in tabulated form, and feel free to use the below template as a starting point (we’ve populated some basic responses for clarity). At a high level, you should define:

• All reconciliation processes
• Scope of each reconciliation
• Which systems are responsible for each
• Who owns each process
• Any supporting teams (you may want to use RACI for this). 

Not only is this process breakdown useful to get ready for CASS 15, but also for operational resiliency purposes. Documentation will be critical in any CASS audits in the future, so investing the time in it right now sets you up for success. 

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Question 2: Why do we perform these reconciliations?

Once you’ve outlined each of the reconciliations, the key question to ask is why you’re performing them. Just because a process has existed for a while doesn’t mean it needs to exist in the same form moving forward - nor does it mean that you’ll be compliant when CASS 15 comes into effect on 7th May 2026. We’ve provided a few examples of why reconciliations are performed below (not an exhaustive list): 

• Existing compliance requirement
• Financial risk mitigation
• Operational risk mitigation
• Audit recommendation

Many firms have established that their existing reconciliations are still needed because they provide some value across one or more of these points. These firms will still need to comply with CASS 15 reconciliation requirements, so new reconciliations will also need to be adopted. 

Other firms have decided that now is an appropriate time to review reconciliation processes and systems in their entirety, and replace existing reconciliation processes. Consider both approaches before using the answers from this step and the following step. 

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Question 3: What is the gap between our existing reconciliations and the CASS 15 reconciliation requirements? 

Now you have a breakdown of your existing processes, it’s time to assess the FCA’s “PS25/12” policy statement (which you can find here) to see what you do today and what you need to implement before the 7th May 2026 deadline. 

If you’re not compliant, you face:

• Enforcement action and fines
• Licence suspension or revocation
• Reputational damage and customer loss
• Personal accountability for senior managers

We put together our “PS25/12 Guide for Regulated Firms” to help you find the gaps, which you can access here.

We recommend that you focus on several areas introduced with PS25/12:

• Reconciliations: There are four types of reconciliation being introduced with CASS 15: internal reconciliation, external reconciliation, D+1 segregation comparison and non-standard reconciliation. There are specific formulae provided by the FCA in PS25/12 for these reconciliations. 
• Reconciliation Day: A day which is not a weekend (Saturday/Sunday), a UK public holiday or a day when the relevant foreign market is closed (in the context of safeguarded accounts being held outside the UK). Mandatory under the new rules.
• Reconciliation Point: Reconciliations should relate to the same reconciliation point every “reconciliation day”. Additional documentation requirements where this is not possible. This is difficult to achieve without some automated system being introduced.
• Shortfall Remediation: If less funds are being safeguarded than should be safeguarded, the shortfall must be remediated on the day the reconciliation is performed, with relevant funds in the first instance, or with own funds if not possible with relevant funds. It is therefore imperative that you know any shortfalls as quickly as possible. 
• Mandatory Audit (Safeguarding balances > £100k consistently for past 53 weeks): Expect to be asked about each of the above points in detail. You’ll need reports, accurate and precise recordkeeping and the outcome of reconciliations. Difficult to achieve without an automated solution. 

Question 4: Can we leverage a technology solution to optimise our reconciliations and achieve CASS 15 compliance? 

Yes - Equali offers two CASS 15-specific products: 

• CASS 15 Standard: Simple CASS 15 solution with support for one of the mandatory reconciliations being introduced (internal reconciliation, reconciliation or D+1 segregation comparison).
• CASS 15 Premium: Comprehensive CASS 15 solution with all required reconciliations.

Many consultants and auditors are recommending certain regulated firms use technology to comply with CASS 15 requirements in advance of the deadline. Before the introduction of the new rules, firms would weigh up the pros and cons of a technology solution vs existing Excel spreadsheets, but these may not be sufficient for your compliance requirements moving forward. 

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If you would like to find out more about how Equali can you achieve compliance with the new CASS 15 rules, book a call with our team here. 

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