The operating answer
The Supplementary Regime took effect on 7 May 2026. PS25/12 also discusses a separate end-state regime; the two should not be presented as one undifferentiated change. [FCA]
The workflow below is our editorial synthesis. Regulatory statements link to primary sources. Examples are hypothetical, and applicability requires a firm-specific assessment.
What the source establishes
The FCA policy statement is the starting point for the reform, its scope and commencement. Read it with the relevant Handbook provisions and the FCA safeguarding page. A summary headline is not enough to establish which obligations apply to a particular legal entity. [FCA] [FCA Handbook]
What the operations team should collect
Create a short entity-and-activity inventory. Then connect relevant funds, bank or other safeguarding arrangements, reconciliation records, reporting and assurance to named owners. Keep the source and version next to each obligation. The inventory is an editorial working method, not a substitute for the rules.
A useful first test is to select a completed period and ask a colleague to reproduce the reconciliation from the retained records. Document where they cannot identify a cut-off, adjustment or source balance. Those gaps are practical starting points for remediation.
What not to infer
A published policy statement does not mean that an individual firm has implemented it. A policy document, a bank balance and a completed report show different things. Keep implementation status and evidence of operation separate.
This note is part of the 12 November 2026 research edition. It is not a live feed, and a reader should reopen the primary sources before making a regulatory decision.
Method, assumptions and limits
We use official sources for regulatory facts and label our suggested workflows as editorial methods. Illustrative examples are hypothetical. The content does not establish the position of any individual firm and is not a prescribed regulator template.
Source review date: 12 November 2026. No automatic monitoring is running. Check the underlying document, applicable entity, activity and jurisdiction before using this material.
Read the full methodologyQuestions, answered.
Is this a live regulatory alert?
No. It is a dated research note with official source links.
Where is the practical checklist?
The safeguarding playbook includes a downloadable evidence checklist and an illustrative reconciliation example.
Sources & scope
Primary sources used for this research edition. Document dates and commencement dates are different fields. Recheck the issuing authority before acting.
- FCA: PS25/12: safeguarding reformPolicy statement · source reviewed 12 November 2026
- FCA: Safeguarding requirements for payment and e-money institutionsGuidance · source reviewed 12 November 2026
- FCA Handbook: CASS 15: relevant fundsHandbook · source reviewed 12 November 2026