The FCA is tightening its grip on CASS compliance, and the data shows it. In 2024, nearly a quarter (24%) of CASS audit reports were returned as qualified or adverse. That’s not a marginal statistic. It’s a stark warning that systemic weaknesses remain across the industry.
Governance gaps, reconciliation errors, poor documentation, and weak oversight continue to trip up firms, and the regulator’s patience is wearing thin. What’s more, the FCA’s focus isn’t limited to newly authorised firms still finding their feet. Long-standing players, once considered low risk, are now firmly in the spotlight.
The message is clear: no one is exempt, and past performance offers no protection if current standards aren’t being met. The FCA is willing to act decisively when firms fall short.
CASS in 2025: A Higher Bar to Clear
The regulatory environment for CASS has shifted from box-ticking to business-critical. The FCA’s intensified scrutiny, coupled with a greater emphasis on consumer protection and operational resilience, means that firms need robust frameworks that stand up to both audit and regulatory inspection.
Survival now means going far beyond covering the basics. CASS compliance has to be embedded in everyday operations, not treated as an annual exercise before the auditor arrives. Those that get it right will not only avoid enforcement risk but also strengthen trust with clients and counterparties.
Your 10-Step Guide to CASS Compliance
At Thistle Initiatives, we’ve helped many firms respond to the demands of CASS audit reporting, from designing governance frameworks to remediating findings from skilled person reviews. Drawing on this experience, we’ve created a practical checklist of ten essential steps to help you stay compliant and confident.
You’ll learn how to:
- Get your governance right: Build clear accountability and oversight structures.
- Master your FCA reporting: Ensure accuracy, timeliness, and regulatory alignment.
- Perfect your banking relationships: Avoid costly gaps in agreements and operations.
…and seven more steps to strengthen your CASS arrangements and prepare for FCA scrutiny.
2.png)