Safeguarding audits for payment and e-money firms

With the FCA’s new safeguarding audit requirement taking effect from May 2026, firms must demonstrate that their safeguarding arrangements are designed, operated and evidenced to a high standard and are audited by a statutory auditor (a 'qualified auditor' in the FCA rules).

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We have listened to our clients and you have told us you need an audit that is:

  • delivered by people that understand your business model;
  • focused on practical outcomes, not theoretical findings; and
  • delivered by specialists who are highly skilled and genuinely easy to work with.

What you get from our safeguarding audit

An audit opinion you can stand over

Your audit opinion is issued by a qualified auditor – meeting your regulatory obligation while giving your board, the regulator, banking partners and customers confidence that your arrangements have been tested objectively. 

Assurance that reflects how your business actually works

As the Auditor’s Expert, fscom has over 15 years of safeguarding expertise across the e-money and payments industry, which assesses your arrangements in the context of your real business model, not a generic checklist. You get findings and recommendations you can act on immediately.

Clear, consistent reporting that removes ambiguity

You receive a report that is: 
•    clear; 
•    structured;
•    risk rated; and
•    easy to communicate internally and externally. 

This helps you brief your senior leadership team, answer board questions and engage confidently with the FCA.

The FCA will also receive a copy of the report directly from the qualified auditor.

Early visibility of process gaps and regulatory issues

Our reliable testing gives a clear view of where controls and process could, or have, failed.

We stress test to find weaknesses, so you can address them before they escalate.

We will raise identified breaches to you, in good time prior to the report going to the regulator.

A practical improvement roadmap

You will not only be told what the gaps are, you will also be shown:

•    what good looks like;
•    what needs to change;
•    how critical each finding is; and
•    what to prioritise first.

If you want support in implementing improvements, this can be done under a separate advisory engagement that maintains independence.

Why clients choose this model

Independent by design

The qualified auditor signs the opinion, ensuring full independence and credibility.

Insightful by experience

fscom brings over 15 years deep safeguarding expertise and a detailed understanding of the payments and e-money landscape.

Efficient in delivery

You get a streamlined process, coordinated through fscom with clear expectations from the outset.

Transparent in costs and scope

You know what is included, how findings are assessed.

What the safeguarding audit journey looks like

E – Establish scope.

An initial meeting with relevant personnel in the business to understand how your business works, your permissions, safeguarding model, reconciliation approach, operational structure and risk profile.

V – Validate evidence.

Review of records, reconciliations, evidence and documentation. fscom leads this work as the auditor’s expert, ensuring thentesting reflects the reality of your operations.

O – Observe operations.

Deploy audit team to conduct walk throughs, interviews and sample testing. fscom evaluates how your safeguarding controls operate day today. The statutory auditor validates reconciliation samples and financial controls independently.

Outcome: independent assurance that looks at both design and operation – giving you a balanced, accurate view.

L – Link findings.

Benchmark against regulatory requirements and industry peers. We identify areas of strength and areas needing improvement, always mapping to regulatory expectations and proportional to your business model.

Outcome: a set of insights that you can act on.

V – Verify conclusions.

All findings will undergo dual quality assurance:

  • fscom’s internal QA for technical accuracy
  • The statutory auditor’s QA for independence and assurance standards

The statutory auditor issues the safeguarding audit opinion.

Outcome: a high quality independent audit report that you can stand over with confidence.

E – Explain recommendations.

A report is drafted, providing opportunity for management response and a final report with recommendations.


Outcome: a clear practical improvement roadmap that enhances governance and reduces regulatory risk. 

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What happens next

Whether you need to understand audit timing, expected scope or fee ranges, our team can guide you through the process.

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Prepare with confidence knowing that your audit is grounded in safeguarding expertise and a clear understanding of your business model.