FCA Safeguarding Return
The FCA’s safeguarding return is a mandatory monthly regulatory return requiring safeguarding firms to report how customer funds are protected, reconciled, and resourced.
- Applies to EMIs, APIs, SPIs (opt-in), and SEMIs (opt-in)
- Covers relevant funds safeguarded under the PSRs/EMRs
- Needs to be submitted within 15 business days after month-end
- Submission via the FCA RegData platform
- Legal Basis: SUP 16.14A / SUP 16 Annex 29BR — Safeguarding return (FCA 2025/38)
What’s the scope?
All safeguarding institutions are in scope, including API, EMI, SPI (opt-in) and SEMI (opt-in).
Deadline
Go-live: 7 May 2026 (first return due 15 business days after month-end)
Reporting frequency
Monthly reporting
File format
Key in via RegData platform, or automate via XML / API submission
Data fields needed for submission (Sections 1–9)
Core sections 1 – 9, covering:
- Firm + category (and audit details if applicable)
- Safeguarding method + client count
- Highest / lowest safeguarding requirement
- Where funds are held: accounts / assets / insurance / guarantees
- Resource vs requirement (incl. excess/shortfall + adjustments)
- D+1 resource vs requirement
- Reconciliation cadence (internal + external)
- Accounts + acknowledgement letters
- Notifiable CASS breaches (Y/N + compliance Y/N)
Sections 10-17 cover unrelated payment services (UPS)
Repeat the same checks as above for payment services unrelated to e-money issuance.
Considerations
(what applies to your firm)
- Sections 1 – 2 + 9: all firms
- Sections 3 – 8: only if you were required to safeguard in the period
- Sections 10 – 17: only for unrelated payment services i.e. EMI + UPS, SEMI (opt in), Credit union (opt in)
Steps to submission
A practical step-by-step overview of how to prepare, validate, and submit the FCA Safeguarding Return.
Confirm scope
Are you required to safeguard (or opted in), and do UPS sections 10-17 apply?
Automate reconciliations
You’ll be doing this monthly, so setting up a monthly pack will be essential.
Diarise submissions
Ensure you can submit the returns within 15 business days of month-end.