A reconciliation result is more useful when another person can understand how it was reached. For a safeguarding review, start with the records behind the calculation, the point in time being compared and the explanation for any difference. A dashboard total alone cannot answer all three questions.
This is a practical discussion guide for your team, rather than a complete statement of the rules or a claim that using software establishes compliance.
Start with the regulatory source
The FCA’s Supplementary Regime took effect on 7 May 2026. Its policy statement explains the changes to safeguarding recordkeeping, monitoring and reporting for payments and e-money firms. Check the scope for your firm in the FCA’s PS25/12 overview.
The published rules distinguish internal safeguarding reconciliation from external reconciliation and set requirements for frequency and reconciliation points. They also address non-standard methods. A resolution pack includes reconciliation records, but has wider content and retrieval requirements. Read the applicable provisions in PS25/12 and its made rules and the current FCA Handbook when reviewing your process.
Can someone identify exactly what was checked?
Choose one completed reconciliation and ask a colleague who did not prepare it to describe its scope. Can they identify the entity, accounts, currency and time covered? Can they find the source records without relying on the preparer’s memory?
A practical review note might explain which extract was used, where it is kept and why its cut-off matches the comparison. If two records use different dates, make that difference explicit before discussing whether the amounts agree. This is a suggested way to test the clarity of your evidence, not a prescribed record format.
Can the reviewer explain a difference?
Work through one unresolved item rather than only looking at the overall result. Record the question that needs answering and the evidence needed to answer it. “Timing” is a possible explanation, but a reviewer should be able to identify the records and dates supporting it.
For your discussion, ask:
- Which source record or amount is in doubt?
- What information is missing, and who can obtain it?
- What action has been taken, by whom and when?
- What evidence would support closing the investigation?
- Can someone distinguish an open question from a completed review?
Could another person retrieve the evidence?
Try a simple handover exercise. Ask a colleague to retrieve a recent record using the instructions available to them. Note where they need additional permissions, a missing link or an explanation from the original preparer. Use the findings to improve your own process.
This exercise is useful for discovering fragile dependencies. It does not certify that a resolution pack is complete or that every regulatory requirement has been met.
Continue with the practitioners’ discussions
The Four Reconciliations of CASS 15 features Dennis Cheng and Martin Burn discussing internal and external checks, D+1 comparisons and non-standard reconciliations. For the audit perspective, see the CASS 15 readiness discussion with Gillian Boston, Martin Burn and moderator Dwayne Gefferie.
The questions in this article are Equali’s editorial suggestions, not quotations from those sessions. To discuss the records and workflow your team needs, explore Equali’s safeguarding reconciliation workflow.
